Developing Your Retention Schedule
So you are ready to get started developing a retention schedule for your department! Here is generally what you can expect as next steps:
- Identify participants for the records schedule working group for your department. An Information Security Committee (ISC) liaison will be assigned to shepherd your department through the process of developing their retention schedule
- A Records Custodian for the department should be identified. This person should understand the record systems of the office AND be able to make decisions on retention and disposition of these records. In some cases, the Administrative Assistant is the Records Custodian, while in other cases a business office manager or assistant director is the Records Custodian for the office. Regardless of the position, the Records Custodian generally is the person who has the most direct knowledge and control of the records being produced.
- The department head and/or relevant senior staff member should be kept aware of developments and weigh in on key issues, but need not be involved in the minute details of the process. The department head should sign off on the schedule before it is finalized.
- Additional departmental staff and stakeholders may participate as desired.
- Hold an introductory meeting of the departmental records schedule working group. Introduce key concepts and considerations. Discuss “think like a records manager” queries. Review example retention schedules from peer institutions. Distribute Swarthmore College template.
- Take some time to begin crafting a draft retention schedule using the Swarthmore College template and referring to examples from other schools.
- Meet with ISC liaison to discuss the retention schedule draft.
- Refine the retention schedule based on feedback received from the ISC liaison, and schedule additional meetings of the records management working group as needed.
- Obtain approval by department head and/or senior staff.
- Submit the draft schedule to the Office of General Counsel for legal review.
- Once you’ve obtained final approval, you may begin your implementation!
Think Like a Records Manager
Developing a formal retention schedule takes time and thought, both about the specific documents and files used by your office, but also about the practices and procedures that revolve around those documents. As you begin to develop a retention schedule, it may be helpful to think about the following questions:
- What records/information does my department save (electronic and paper)?
- How long do we save it, and why? Are we following any specific laws, best practices from professional organizations, or other guidance?
- Are we the responsible office or are we duplicating records/information from elsewhere? Are we keeping drafts or only final copies?
- Do our records contain sensitive information? If so, are the records stored securely when in active use and when in storage? Are they securely disposed of? Sensitive information includes, but is not limited to, the following:
- Social security numbers
- Bank numbers
- Student academic records
- Health information
- Employment information
Consider this “HALF” mnemonic to evaluate how long records should be kept:
- Historical - Is this document historically important? Will it be of interest to future researchers? Is the historical information in this document unique or in a particularly convenient format?
- Administrative - How often do I use this document? Are there other ways to access this information? How do I balance the burdens of filing and storing this document against the likelihood I’ll need it?
- Legal - Are there external legal regulations that apply to the retention of this document? Does it contain sensitive information that poses a legal liability? Does it mitigate a possible legal liability?
- Fiscal - Do I need to keep these papers for a potential audit or taxes? Are they useful for budgetary planning?