Growing up in New Zealand a television favourite of mine was a local version of A Man and his Dog which was named with typical kiwi literal-mindedness The Dog Show. When designing retention schedules I often think back to the steeliness of dogs named Zip and Jess as they stared down particularly toey sheep to nudge them into their pens. Just like the pens on A Man and his Dog, you have to gently, but firmly, guide your users towards the right retention management decisions.
The dreaded “just in case” argument
“Just in case” is the kind of phrase most records managers dread hearing from their stakeholders. There are many perfectly legitimate reasons users give for wanting to hold on to records for a certain period of time. There may be a law or regulation to be adhered to, rights that are protected, or business processes which require the records to be referred to.
But then there is the more nebulous reasons people give for holding on to records – just in case something happens and I need them. Just in case what? Well just about anything. And that’s the problem. With enough imagination you can dream up any worst case scenario where an obscure old record saves the day.
And what is even worse is when there has been a freak occurrence where this exact thing has happened. Someone has managed to save your organisation a great deal of money or embarrassment with an email they’ve had in their mailbox for nine years.
Take a deep breath, hold your nerve and have some of these questions ready when talking to someone who presents you with a “just in case” argument:
1. Check they understand triggers
Check first that they understand things won’t be disposed of before they’re triggered. “Just in case” may arise from a misunderstanding of triggers and a fear that you’re going to delete records out from under people while they still have a legitimate need for them.
2. Consider the personal data and data subject rights
What personal data is held in this record and can you reasonably argue this is a legitimate business need that outweighs data subject rights? Remind people that your organisation does have to meet data protection requirements which does not accept “just in case” as a reason for retention.
3. Measure the risk
Ask your stakeholders “What is the likelihood of the just in case scenario happening (again)?” and “What is the actual risk? i.e. what does it cost the organisation?”
As an example, I’ve had a stakeholder tell me that a record type had to be kept to prevent the organisation incurring costs from complaints process, only for it come out that the actual total cost was £24. What’s more the likelihood of the risky event recurring was very low. It had only happened once and this was more than six years ago.
Ask how often, how likely, and how much – applying a risk management evaluation to your retention requirements.
4. Get the full story on that “save the day” scenario
In the case where a record saved the day don’t be afraid to probe (in a neutral way) to get some more information about the full scenario. It’s quite possible you are not getting the full story. For example:
- Did the record in question only help because it was a proxy for something else that should be retained but was too difficult to find in a time-critical situation?
- How long ago did this happen? Did it happen so long ago, things have moved on and it’s no longer relevant?
- Was the person telling you this story involved enough to understand what actually happened? Could it even be an urban legend?
Helping people find more appropriate retention rules
These are just some of the ways you can begin to unpick the requirement to keep things just in case. Getting to the bottom of the underlying concerns that drive such a requirement can then help you to guide your stakeholder to more appropriate retention rules.
It can often feel like herding cats, but with patience and understanding it’s a rewarding result once it’s done. All that’s left to do is implement. We’ll be looking at implementation in the final of this series next time.
If you need some help talking to your stakeholders about records management, or are looking for general advice about information management, please do use the contact form on the right, or get in touch today firstname.lastname@example.org.