Destroying records inappropriately can land any organization in hot water. For example, getting rid of a record that is subject to regulatory retention requirements or a legal hold can lead to serious consequences. That means it’s important to ensure that organizations enforce a “defensible” and responsible approach to disposing of records, as we discussed in our first article in this series, “Defensible Destruction 101: What Every Records Manager Needs to Know.” Today, we’re going to dig a little deeper into this topic and lay out a step-by-step plan for creating a defensible destruction process.
1: Consult with stakeholders.
It’s important to work with legal counsel and other relevant stakeholders when establishing a strategy for handling records disposition in general. It’s doubly important when determining, formalizing, and codifying the process by which you’ll identify which records need to be destroyed, when, and how.
2: Determine the criteria by which records will be evaluated for destruction.
Consistency is key to defensibility; if your organization handles records destruction in a haphazard way, it becomes too easy to make unintentional mistakes. Instead, a clear, formal, and written set of rules should govern how to determine which records are suitable for destruction – and how those records should be destroyed.
3: Determine how due diligence will be conducted.
A “defensible” destruction process is usually one that’s well documented and includes a series of checks and balances. For example, it might be a good idea to require at least one leader or stakeholder to approve the destruction. Then, the act of destruction itself should be documented in a log that notates:
- Record identifiers, including title and name and any associate record number
- Details about the records, including date range, quantity, type of record or media
- Date of destruction
- Signatures or other authorization to destroy
- Signatures or verification of completed destruction
4: Map your defensible destruction processes to your records retention schedule.
At the heart of any records management program is a records schedule that provides clear instructions on how to handle different types of records and identifies which personnel are responsible for what activities. Any policies or processes that govern the destruction process must align with your records schedule. For help creating or modifying a records schedule, follow our short step-by-step guide.
5: Automate with technology.
One major risk in any destruction process: human error. Thankfully, rules or criteria for government record disposition can be programmed into an electronic records management (ERM) system. The ERM can then ensure only those records are subject to disposal while facilitating the process of gathering necessary approvals.
About PSL
PSL is a global outsource provider whose mission is to provide solutions that facilitate the movement of business-critical information between and among government agencies, business enterprises, and their partners. For more information, please visit or email info@penielsolutions.com.