Does your record retention program produce real results or is it a pseudo program? A “real” record retention program has a measurable impact: It reduces risks, ensures compliance, drives down the cost of e-discovery and lowers data storage costs. Unfortunately, too many of the record retention programs I see are what I term “pseudo” programs. Pseudo record retention programs look like they should be effective, but don't produce any of these results and sometimes even actually increase risks and costs.

What makes a record retention program a pseudo program? A pseudo program is often focused on the wrong areas, is too narrow in scope, or does not address “real” world requirements or behaviors. Here are four common signs of pseudo record retention programs:

Exclusively Addresses “Official” Records, Ignoring Documents - Pseudo record retention programs only address “official” business records and they ignore the larger world of non-record documents. Documents are any type of business communication, including e-mails, files, paper, etc. A special, subset of business documents are records, or documents that support an organization's activities or decisions. Driven by regulatory or business requirements, records need to be saved for some period of time. While it varies from company to company, anywhere from 5 percent to 40 percent of an organization's documents are records.

It is a mistake, however, for a records retention program to stop at only addressing official records. In the event of litigation or regulatory inquiry, organizations must also identify, review and produce any relevant electronically stored information, not just the subset of records.

Real record retention programs address not only saving records, but also managing, controlling and deleting the larger world of nonrecord documents. This includes routine and defensible document deletion, e-mail usage standards, litigation hold policies and processes, etc. A simpler, more comprehensive program that addresses all documents is better than a detailed approach focusing only on records.

Focuses on Paper Documents, Not Electronic Information - Many record retention programs were originally developed when most documents were mainly printed paper. Yet today more than 96 percent of all documents created or received by organizations are in electronic media. Even most paper documents today are copies of source electronic documents. Too often I hear organizations explain that “we do a good job managing paper.” That's good, but what about the other 96 percent?

Significant Use of Offline E-mail “PST” Files - Good record retention is about exerting control, allowing organizations to search, retrieve, save, preserve and eventually delete documents. Too often, however, the de facto policy is to let employees save much of their e-mails in offline “PST” files (NSF files for Lotus Notes users). PST files are stored separate from the e-mail system on desktops, laptops, group file shares, and other places. Typically, once an e-mail is saved in a PST file, it is difficult to search, hard to ensure preservations in the event of a hold, and once the e-mail goes into the PST file it stays there forever. Good record retention strategies allow e-mail to be saved, but in much more controlled environments such as e-mail archiving systems. Companies that have extensive use of PST files have most of their documents out of their control. This increases litigation, and leads to ongoing accumulation of e-mail.

Employees Are Unaware or Ignore the Record Retention and Deletion Policy - Many organizations have developed records retention policies and schedules which are unknown or ignored by employees. Legal, compliance or records management claims “it's not my job to enforce the policy.” A policy that employees do not follow is worse than no policy at all. Policies are often the first item discovered in litigation, and a gap between intention and practice creates problems. If companies say they are doing one thing, and employees are doing something completely different, this creates significant risk. Real programs engage stakeholders and employees through training and change management, driving good behavior and measureable results.

Should companies care if they only have a pseudo program? Yes. Good programs both save money and reduce risks, lower e-discovery costs, enable more effective use of data storage and ensure compliance. Time to get real.

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