A lesson in transparency
Early in my career a project manager I worked with on a retention project said she found me to be mercurial when it came to advising stakeholders on retention. Flattering as it was to be referred to as “the oracle” on retention I was rather mortified to learn I was seen as something akin to a cold and unpredictable power dispensing mystical advice.
Over the next few months I introduced greater transparency to my approach, explaining why I was making the recommendations I made. Three months later the same colleague proudly told me she could always pick what sort of advice I would give users and even felt confident giving advice on retention herself. Result!
Demystifying retention and is really important to our colleagues and stakeholders. Demystifying how we arrive at the retention periods we advise for our users is probably one of the biggest things you can do to make retention much more approachable. Here are some tips on making your process for retention management much easier for colleagues to understand.
Explain the different drivers for retention
Explain to your colleagues that retention schedules are shaped by what the law requires and what the business requires. This may be disappointing news to some stakeholders who would prefer a hard and fast answer on how long things should be kept encoded in law. But business value is the biggest conversation to have with stakeholders. If people understand the basic principle of assigning a business value up front, the rest of the conversation will got a lot easier.
Talk to stakeholder about their business processes
One of stakeholders’ top concerns about retention management is that retention rules will mean records get deleted before the end of a business process. Projects are a classic example of this. Stakeholders might see a retention period of, say 6 years, and fear that records related to projects that run for decades will be deleted before the project has ended. This is the perfect opportunity to put stakeholders straight about retention triggers and the need to identify when the business process ends. This can be followed up with a discussion about how long records are needed after the business process ends.
Balance organisational interests with data subject rights
If stakeholders are managing personal data they may already have an awareness they need to manage this in line with GDPR. This stakeholder group is probably the most frustrated to learn that the GDPR doesn’t tell us exactly how long we can keep personal data, but uses slightly evasive legal terms like “legitimate purpose” and “reasonable” which can be somewhat subjective.
Sometimes you may have to tell stakeholders that the period of time they propose to keep personal data is unreasonable e.g. 20 years for former customers. It may be unreasonable because they can’t point to a legitimate business reason to keep things that long, because it’s a real outlier in terms of industry practice, or because if you asked the person on the street what they thought of the retention practices they might find it unacceptable.
Conversely, sometimes you need to reassure a stakeholder that it is perfectly acceptable to retain certain types of personal data for a long time because it protects the rights of the organisation, and more importantly it protects the rights of the data subjects themselves (for examples records which provide proof of ownership, benefits conferred or qualifications conferred).
Remember “we’re the professionals”
Counter to the idea records management is a dark art, there are standards for retention management. I’m constantly heartened by the fact that the more records managers I work with, the more consistent I find the advice and guidance we all give on retention. Making our stakeholders aware of the fact there are some industry standards records retention rules helps.
Many senior managers will ask what their competitors or equivalent agencies do for retention and this is where any review of retention schedules you have done for the your industry comes in handy.
Consistency is key
Like with parenting consistency is key. Of course you will be consistent in the retention advice you give, no matter who asks. However, situations sometimes arise where retention decisions are made through politics, not process. That’s life. Occasionally records managers have to accept decisions that are made much higher up the chain which aren’t necessarily what’s best for the organisation.
Of course I would not advise getting bogged down in a battle you’re not going to win. But it’s important to voice your recommendations and concerns about risks. It means your organisation is making an informed decision. And it shows you to be consistent in your approach. There’s nothing wrong with being predictable!
We want to be transparent and fair in our construction of retention schedules. Doing things openly and being consistent helps build better relationships with our stakeholders. And goes some of the way to winning hearts and minds along the way.
But there is also an opportunity here to nudge the shape of your retention schedule in a direction of your choosing. I will talk about this more in my next post.
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