Iron Mountain Digital Authority

payable and accounts receivable might be two distinct processes, but in a Big Bucket scenario they fall under one classification—accounting records—because their retention requirements are both informed by the same body of law.

In fact, employees work better with fewer buckets. “It reduces the options from which employees have to choose, which in turn reduces the chance of misclassification of records,” says Trombley.

By making the categories few

and simple enough, and through

instruction, employees can adhere to

the classification of records policy.

Might it make sense to automate classification, taking the responsibility out of employees’ hands? Some Iron Mountain customers swear by it, but Trombley is cautious. “In my client base, autoclassification technology has not yet proven to be a solution for categorizing eRecords,” she says. “Legal and compliance departments are not yet comfortable with the autoclassification applications’ degree of accuracy.” By making the categories few and simple enough, and through instruction, employees can adhere to the classification of records policy.

The Migration

The transition to eRecords is not easy. As part of its service, Iron Mountain creates a “crosswalk” that maps the relationship between legacy retention categories and a Big Bucket retention schedule. Most companies still classify documents by department, then perhaps by job function, which has not failed them in hard-copy storage. But most still rely on large numbers of classes.

The U.S. Government Accountability Office (GAO) has taken the lead on bucket reduction. Over the course of three years it migrated from 300 records series to three big buckets and 33 sub-buckets, reducing the number of classifications by a factor of nine. This vastly simplified its retention schedule, as each of the three buckets has its own retention period. The buckets are:

n Mission or Engagement (five-year retention) n Administrative (seven-year retention)

n Policy, Publications and Special Collections ( permanent)

To accomplish this, GAO employees were trained in records management to identify what is and is not a record, how to apply retention rules and how to retrieve records once they are filed.

Iron Mountain also recommends to its clients opportunities for merging classes of records based on common

retention requirements and other considerations. Records thus become classified by regulations like HIPAA or those set by the Office of the Comptroller of the Currency. “They’re informed by the same body of law,” says Trombley, “so the classification morphs into the retention schedule and enables the eventual destruction of that record.”

Destruction in an Electronic Age

Many regulations call for the secure destruction of records. The destruction of hard-copy records typically means shredding or incineration. With eRecords, it more likely means the erasure of electronic media or physical destruction of that media.

Ensuring that all copies of a record are destroyed is a challenge in an electronic age because employees have different records management styles. One may systematically purge his or her email and files, while another retains every document and email. “The retention of convenience or unofficial copies of records are guided by the records retention schedule, just as is the official copy,” Trombley says. “The copies should never be kept longer than the official version of the record.” Companies should continue to educate their employees about proper records management procedures in order to decrease the number of convenience copies kept on many different media.

Records Management Program
Development

Given the complexities of the records management environment, many customers take advantage of Iron Mountain’s Consulting Services expertise in order to develop and implement a comprehensive records management program that consists of a policy and supporting procedures, a records retention schedule, an intranet site on which all related materials are made available to all employees, and training materials.

There are several advantages to having a records management program. First, customers have access to industry best practices developed by Iron Mountain through its experience with its Fortune 500 customer base.

Second, a legally credible enterprise-wide records management policy implemented through training and the establishment of a supporting infrastructure reduces the risk of negative exposure for an organization.

Trombley encourages the migration to Big Buckets wherever practical. “What we can do is take advantage of opportunities to review these classes and merge them into bigger buckets in order to increase the accuracy of classification and simplify retention rules in electronic content management systems.”