I would treat this as two separate issues.
1. Keeping a record of what you destroyed, where and when - required to provide evidence in the future that records were destroyed according to company policy and retention schedules, and not in some kind of Emron-like purge.
2. What level of authorisation (or independent quality check) is required to destroy the different classifications of documents, e.g. None, Management only, Management plus Quality Assurance (in my industry), or delegated to RM department (if that’s what you want).
If you always require some formal authorisation then the documentary evidence of these two can be easily combined - and even if it isn't you could still use a combined form and put "Not applicable" in the unused form fields (which is what we do). Our form requires:
- Description and location of records to be destroyed (sometimes they were generated by and have been stored with a third party contractor)
- Explanation/justification for destruction, with reference to the relevant retention schedule and/or external regulation if not explicitly captured in a retention schedule
- Name of person recommending destruction (almost always an archivist, business departments don't go round reviewing their archived or even locally filed records against the schedules)
- Up to two approvers (one or both may be N/A for certain record types)
- Date and method of destruction
- Destruction certificate or at least an email confirmation if records were at a third party
- Destruction reference number (useful to enter in the archive database, spreadsheets etc)
We have some flexibility. Sometimes if only an informal approval is required we keep an email in lieu of the form and annotate with the last three items.
With regard to defining when and what authorisation is required, this could be in a more detailed addendum to your records management policy so you can tailor it as appropriate for different record types, e.g. as one or more standard operating procedures or working instructions. Or you could maybe write it into the retention schedules.
By the way, all the above applies only to what we call "critical records", often called "essential records" elsewhere. These are the original records that must be kept for legal, regulatory or business (including intellectual property) purposes. All working copies, most drafts (except in a Litigation Hold situation), and anything not listed in the retention schedules (e.g. travel arrangements), are excluded as they fall into the category of things that should never be archived in the first place (along with unused stationery, textbooks, nameplates, business cards, a pair of shoes - and all the other crap that gets put in archive boxes!). No authorisation or record is required for destruction of such records and artefacts.
Neil.
-----Original Message-----
From: The Information and Records Management Society mailing list [mailto:[log in to unmask]] On Behalf Of Nia Thomas
Sent: 21 November 2018 15:26
To: [log in to unmask]
Subject: [External] Records Disposal Procuedures
Good afternoon
Would anyone care to share their disposal procedures please? In particular relating to the process of verifying records to be disposed of. Many years ago we gave up asking departments for authorisation to destroy their records that were past the retention date since they either didn't reply or wanted to keep them for longer without good cause. We therefore take the Retention Schedules as authorisation, but not in all cases e.g. legal files, and rely on departments to inform us of any records subject to legal holds etc. This system has worked efficiently without any problems but our Internal Audit Team have queried our procedures regarding authorisation and regarding verification of the physical records to be destroyed i.e. someone double checking that the correct records are being destroyed.
I'm particularly concerned that if Audit's desire to expand the process is implemented it would be a nightmare to implement in the digital environment where retention periods are applied to document types in accordance with our Retention Schedules.
Many thanks
Nia
Cyngor Sir Gar
Carmarthenshire County Council
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