Get stuck in! A six part series on big bucket retention. Part six.

Part six

Where the rubber hits the road: implementation

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 which outlines 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 records held in systems.

Document the practicalities

It’s inevitable when talking to stakeholders that they will flag up concerns about practical implementation of retention 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 improve the process so that new records can be managed appropriately and the legacy 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 both to newly created records going forward and to 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.

Leverage simple systems rules

This is just one element of planning for retention implementation. There are numerous practical considerations to take 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

The two classes stem from different functions, but require the same retention treatment. This means that a retention rule may be created in systems that says “delete content 7 years from end of financial year”. It will do the job for both classes, as long as disposal is done in line with the retention schedule (meaning also metadata 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

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 have to be. Complexity costs. And frankly even your users will get confused by a schedule with too many caveats. Save these up 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 about retention in general, do get in touch using the contact form above or email info@metataxis.com.

Get stuck in! A six part series on big bucket retention. Part five.

Part five

Herding cats: Dealing with "just in case"

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 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.

Isolated incidents

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 info@metataxis.com.

Get stuck in! A six part series on big bucket retention. Part four.

Part four

Beautiful and unique snowflakes: dealing with complex requirements

The struggle against complexity

Trying to keep your retention schedule 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 schedule will be your retention schedule stakeholders. People really do complicate things. Sometimes legitimately, sometimes not so much.

Valuing subject matter expertise…

Generally your stakeholders are the best people to talk to about how long records should be kept, especially for those record types whose retention is determined by business need 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 – that 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 will explain the, to their minds, dire consequences if incorrect retention is applied to the records they produce. You can trust stakeholder direction a lot of the time, 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’s a need to tread carefully. This is a challenging conversation 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.

Dealing with complex 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’s are some common concerns or misconceptions you can head off at the pass if you’re prepared for them. Here’s 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. Lack of understanding of evidential requirements and/or personal data requirements; or even
  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 look at the dreaded “just in case” requirement that often arises when having these conversations with stakeholders. 

If you want to know more about how to develop and manage retention schedules, or have any questions about records management, use the contact form on the right, or contact us via email info@metataxis.com.

Get stuck in! A six part series on big bucket retention. Part two.

Part two

Demystifying retention for your stakeholders

Records classification

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. 

If you have any questions or comments you want to share please use the contact form on the right or email us info@metataxis.com.