Helping UK regulator get records disposal ready
Introduction
This UK regulator is responsible for assessing the performance of government service providers who regularly deal with children and young adults.
When the Independent Inquiry into Child Sexual Abuse (IICSA) was established, this had serious implications for the records that the regulator collected and managed.
A broad reaching legal hold was necessary to ensure that any records which may be subject to disclosure were preserved from destruction. Having applied a legal hold to the majority of their case files, this organisation needed some guidance on how to securely re-introduce a disposal review.
Business drivers
As many of their case records were subject to legal hold, this UK regulator had not completed an organisation-wide disposal review in many years and needed support to get this up and running again. The lack of case file disposal was causing issues with the findability of records and incurring substantial storage costs. A major concern was also the lack of compliance with records management and information governance requirements.
Key requirements
The regulator required a partner to review their existing retention and disposal programme to understand the extent of legacy records eligible for review, as well as identifying any gaps and challenges for disposal arising from the systems, processes, and technology. They also needed expert advice and recommendations to prepare a clear strategy to reintroduce retention management.
Metataxis has significant experience in the field of retention management within the context of IICSA and was a natural choice for the organisation to move things forward.
The Metataxis approach
As records and retention management experts, Metataxis was engaged by the client to help them define and create a comprehensive, clear and compliant retention management and disposal strategy.
Working closely with our client’s records team, Metataxis initially undertook a discovery exercise to understand records policies, procedures and retention schedule requirements. We also reviewed the technical systems used to manage and store records to evaluate what technical measures needed to be considered in order to implement the Retention Schedule. This included a review of the use of Microsoft Purview.
Part of our review of the retention management processes involved understanding the extent and method of application of the legal holds and current processes for managing these. This included understanding which records were no longer subject to legal hold on the conclusion of the Inquiry embargo on records destruction.
As there was a significant backlog of records which had not been reviewed in quite some time, Metataxis identified that an item-by-item disposal review would not be feasible because of the scope. Metataxis recommended a strategic approach be adopted for the legacy files, using risk-based decision making for records disposal.
To help our client take things forward we delivered:
- An assessment of their Retention Schedule and supporting implementation plans and processes
- An assessment of technology systems – considering the challenges they posed and how they might be used to implement retention
- A list of recommendations for making improvements to retention management
- An action plan setting priorities, identifying resource requirements and project timelines
Business benefits
Following our assessment, the regulator emerged with a clear view of precisely which records needed to be kept, and which could be processed through a disposal review.
Their engagement with us left them feeling confident enough to address retention management. Ultimately, our client had a comprehensive plan to take forward and begin to address issues of cost and compliance as well as new ways to improve the overall records management experience for their staff and customers.
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