A fundamental approach to making data retention work

Metataxis shares key recommendations for data retention at ARA 2023.

The Archive and Records Association (ARA) Annual Conference took place from 30 August – 01 September 2023 in Belfast – did you get to go?

This annual three-day event welcomes people from the global records management and archiving community who get together to network with peers, attend a range of practical workshops and hear from high profile speakers and influential players of the record keeping sector.

Our very own Records Management Expert, Company Director and Information Management Consultant here at Metataxis, Noeleen Schenk, took to the stage to deliver a focussed presentation featuring practical strategies to successfully design and apply retention and disposition rules for business records, as well as sharing a compelling case study and lessons learnt from a recent records management project for a major multinational company.

Don’t worry if you missed her, simply get in touch and we can share her records management recommendations and data retention strategies with you too!

How to implement retention schedules

Where the rubber hits the road: Implementation

In her latest blog series, Siobhan King, Senior Consultant at Metataxis, addresses the value of big bucket data retention and how to ensure complex records management requirements are accommodated.

Here’s part 6 – the final blog in the series, where she looks at how to successfully implement your retention schedules into the organisation.

Retention implementation plan

During this series, we’ve been looking at ways to simplify the retention schedule into bigger buckets. A retention schedule will usually take the form of a table which can then be applied to systems and communicated to staff. The retention schedule may be supported by a written document, usually a retention policy or records policy, and this will outline the governance, scope, roles, responsibilities, compliance expectations, etc. The last piece of the puzzle is the implementation plan, which is the practical application of the retention schedule to the records held in your systems.

Document the practicalities

It’s inevitable when talking to stakeholders that they will flag up concerns about the implementation of records retention policies very early on. In fact, they are likely to identify practical issues as reasons why longer retention periods should be applied to certain records. In an ideal world, these practical limitations should never dictate the retention period for a records class. Instead, steps should be taken to improve the metadata, or to improve processes, so that new records can be managed appropriately, and legacy records dealt with more strategically.

Adopt a risk-based approach

Because we work in complex environments, it is necessary to have some kind of strategy to apply retention to both newly created records going forward as well as older records created in the past. This means having a good information architecture that supports retention management and a risk-based approach to the legacy records.

big bucket data

Leverage simple systems rules

This is just one element of planning for retention schedules implementation. There are numerous practical considerations that can be taken in order to get through the bulk of retention management. And yes, you guessed it, opportunities to lump things together in the implementation plan. For example, your retention schedule may have the following two rules:

  1. Financial management – 7 years from end of financial year then delete
  2. Annual strategic planning – 7 years from end of financial year then delete

These two classes stem from different functions but require the same retention treatment. This means that a retention rule may be created in systems that states: “delete content 7 years from end of financial year”. It will do the job for both classes and if disposal is done in line with the retention schedule (meaning metadata also is collected) it doesn’t matter what the technical mechanism. This is also helpful for more manual applications of retention where searches for eligible records are done for anything older than 7 years in relevant system areas for both functions.

Capture stakeholder intelligence

Finally, remember those tricky discussions with stakeholders where they provided masses of detail? An implementation plan is the perfect place to capture all that valuable intelligence. Not the retention schedule. Retention schedules need to be super simple.

Avoid complex rules for your retention schedules

While there’s some scope to have lots of detail in a description field to help users identify the right retention period for their records, there’s not much room for nuance in your actual schedule.

The more “ifs”, “ors” and “except fors” you have in the schedule, the more complex your retention rules will be. Complexity costs. And your users will get confused by a schedule with too many caveats. Save these for the implementation plan – it will be valuable intelligence for dealing with those legacy issues! And the plan is the thing that will make your retention schedule real!

So that’s the final entry of the series. I hope you have found it useful. If you want to know more about what implementation plans should look like or would like to learn more about practical data retention and records management, simply contact us.

How to deal with “just in case” retention requirements

Herding cats: Dealing with “just in case”

Trying to keep your retention schedules simple is an ongoing battle against the forces of complexity. And one of the major things that will hinder your plans to simplify your retention requirements will be your retention schedule stakeholders. People really do like to hold on to things. Sometimes legitimately, sometimes not so much.

In her latest blog, Siobhan King, Senior Consultant at Metataxis, reveals ways to ensure complex records management and retention requirements are accommodated.

Here’s part 5:

Herding skills

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 data retention schedules, I often think back to the steeliness of two 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 must 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 that needs to be adhered to, rights that are protected, or business processes which require the records to be referred to at any point in time.

But then there are 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, it could be just about anything.

And herein lies the problem. With enough imagination, you can dream up any worst-case scenario where an obscure old record saves the day.

just in case retention requirements

Isolated incidents

And what is even worse… is when there actually has been a freak occurrence where this exact situation has happened. Someone has managed to save your organisation a great deal of money or embarrassment with an email they’ve had stored 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 that your stakeholders understand that information will not be disposed of before they are 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.
  1. Consider the personal data and data subject rights: Look at the personal data that is held in each record and whether you can reasonably argue that there 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.
  1. Measure the risk: Ask your stakeholders “what is the likelihood of the just in case scenario happening (again)?” and look at 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 in order to prevent the organisation potentially incurring costs from a complaints process, However, it turned out that the actual total cost was just £24. What’s more, the likelihood of this risky event recurring was also very low. It had only happened once, and this was over six years ago. Ask how often, how likely, and how much it would cost to apply a risk management evaluation to your retention requirements.
  1. Get the full story on that “save the day” scenario: In the case where a record “saved the day” do not be afraid to probe (in a neutral way) to get some more information about the full scenario. It is 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 have been 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 data “just in case.”

Getting to the bottom of the underlying concerns that drive such a requirement can help you to guide your stakeholders 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 your retention rules. We’ll be looking at implementation in the final of this blog of this series next time.

In the meantime, if you need some help talking to your stakeholders about records management, or would like to learn more about practical data retention and records management, simply contact us.

How to avoid complex retention requirements

The struggle against complexity

Trying to keep your retention schedules simple is an ongoing battle against the forces of complexity. And one of the major things that will hinder your plans to simplify your retention requirements will be your retention schedule stakeholders. People really do like to complicate things. Sometimes legitimately, sometimes not so much.

In her latest blog series, Siobhan King, Senior Consultant at Metataxis, reveals ways to ensure complex records management and retention requirements are accommodated.

Here’s part 4:

Valuing subject matter expertise…

Generally, your stakeholders are the best people to talk to regarding how long records should be kept, especially for those record types whose retention is determined by business needs over legal or regulatory requirements. Stakeholders are a great source of information about how the business works and what records are produced. But their insights shouldn’t be taken as law when it comes to the retention schedule. Stakeholders are not records managers and do not have the expertise to classify and manage records – this is where we add value. 

…and records management

When consulting with your organisation on the retention schedule, you will encounter users who are keen to press upon you the vital importance of their records. They are likely to explain the dire consequences that will occur if incorrect retention is applied to the records they produce. You can trust stakeholder direction a lot of the time, as they will often identify those exceptional record types that need to be kept longer because their early destruction will significantly impact the organisation. But occasionally, people make distinctions that don’t really matter from a retention management perspective.

Challenging conversations about values

When responding to the above concerns, there is, of course, a need to tread carefully. These can be challenging conversations to have. No one will respond well to the argument that they are not beautiful and unique snowflakes. Everyone needs to know that their contribution to an organisation is important. But the difference is that the retention value you place on the outputs of the activity is not a reflection of the value of the activity to the organisation.

challenging retention requirements

Dealing with complex retention requests

For some, simply acknowledging the complexity of business functions and activities is enough. This can be done verbally or incorporated into documentation. Appropriate places to capture this knowledge might be Retention Schedule class descriptions, Information Asset Registers, user guides or retention implementation plans. 

Some things you can counteract, some you have to accept. There are some common concerns or misconceptions you can head off at the pass if you’re prepared for them. Here is a list of some common issues I have encountered:

  1. Over-retention of records arising from poor internal processes which need to be amended
  2. Concerns about technical or practical application of retention, for example where records have insufficient metadata
  3. An over-estimation of the importance of their function and the records they produce within the organisation as a whole
  4. A lack of understanding of evidential requirements and/or personal data requirements
  5. Belief that retention will prevent uncommon or unlikely events which would cause problems for the organisation 

A matter of perspective

The small differences that people see in their work are important to ensure the job is done well. However, it’s not always important from a retention perspective, your job is to weight user expectations within the broader context for the organisation so you can create a simpler retention schedule.

Next time, we’ll look at the dreaded “just in case” requirement that often arises when having these conversations with stakeholders. 

Retention management can be challenging. Here at Metataxis, we’ve helped many organisations address these challenges. If you would like to learn more about practical data retention and records management, simply contact us.

Retention schedules made simple

Simplifying retention schedules for your big bucket data

In her latest blog series, Siobhan King, Senior Consultant at Metataxis, addresses the value of big bucket data retention and shares some ideas how to simplify your retention schedules to minimise complexities across your organisation.

Here’s part 3:

It’s not all about class

Organising your retention schedules into big buckets is not about trying to create large all-encompassing retention classes. While this is of course a really important step, there are a number of other parts to your retention schedule that you will want to simplify. Simplifying all aspects of your Schedule reduces the number of factors, which in turn reduces complexity.  

When talking to your stakeholders, the following could be considered to maintain simplicity for stakeholders:

Retention periods

If you can, try to corral your stakeholders to agree to a small number of retention period types in your schedule. There are common regulatory time periods that can help you choose which ones you want to use. For example: Financial records are usually kept for 7 years, as is the catch all retention mechanism the Limitation Act. So, try to nudge people towards choosing 7 years as a retention period for records that need to be kept for a moderately long period of time. Try to avoid having retention periods of 6 years, 8 years, or 9 years. These will involve much more effort to implement.

Triggers

If you ask a stakeholder to define when a business process is over, they can be very specific. For example: “the Quality Review of the inspection process is completed once the B488 form has had its second review by the fourth-tier quality reviewer.”

When really, a trigger such as “end of quality review” would suffice.

Specific triggers like this will make your retention schedule very complex, and extremely difficult when you try to apply this to systems. We can trust that the people doing the work would know how and when to mark something is closed. But we do not need to know the exact detail of the process to execute retention.

Having more general triggers, such as “end of programme/project” or “contract closure” can be really useful as they can be used in a number of different contexts. So, we suggest you try to have as few triggers as you can, and make them as broad as possible.

Disposal authorisers

Identifying an appropriate and reasonable number of people to be responsible for disposal review at the end of lifecycle for records is by far this most challenging aspect of any data retention schedule.

The challenge arises from needing someone with a sufficiently senior role to make a decision, while being operational enough to understand the content of the records to be disposed of.

Unless your organisation is really small, this is unlikely to be the same person. This is because, for example, the head of HR is concerned with governance and strategy and not likely to know the operational ins and outs of say, recruitment campaigns and applicants.

retention schedules disposal authorisers

Traditionally, this has meant that there is some form of delegation of decision making to the subject matter experts. Or conversely, some sign off of decisions are made by the head of department. This is a frustratingly difficult aspect of a retention schedule to simplify. Setting up workflows to incorporate a lot of people is really difficult and costly, so it is important to try to keep the number of authorisers low – even though this is challenging.

Disposal actions

As with the above, we recommend keeping these as simple as possible. Delete or archive may be sufficient for most organisations.

The question “what is an archive?” is a whole other conversation. Some organisations will deposit data to a national repository such as TNA, some will have their own in-house archive. Others will have records that have long-term value and need to be kept permanently even if the organisation does not have an archive.

Minimisation leads to simplification

When your retention periods, triggers, actions and authorisers are simplified, something beautiful happens. With a smaller number of factors in play, it makes it much easier to lump record types into much larger retention classes. This makes big bucket retention that much more possible! 

So don’t just go straight for classes when simplifying your Schedule. Think about minimising all the moving parts as well. It will make things much easier in the long run.

Next time, I will talk about dealing with the complexity that people will inevitably want to introduce to your schedule and how to deal with “snowflake” requests.

Retention management can be challenging. Here at Metataxis, we’ve helped many organisations address these challenges. If you would like to learn more about practical data retention and records management, simply contact us.