Wednesday, June 4, 2008

ATR: Records Management -- It All Used to be so Simple...

It's somewhat before 0800 EDT, it's raining and gloomy, and I'm sitting in the Red Carpet Club at LaGuardia Airport. My flight is at 1000 and is supposed to be on time. This is LaGuardia and I'm going to O'Hare, which is also rainy and gloomy. I rather expect a long day... As insurance, I've upgraded to a comfy seat for what will likely be a number of hours on the plane. (Which of course means everything will be on time and we'll arrive early.)

One of the cool things about my career is that it has been a continuous stream of learning opportunities. I have rarely felt like I had mastered everything. This past year has been no exception. It is challenging enough to take on a new job at a new company and have to learn all the players and the company culture, but add in to that whole new areas of focus. This does tend to keep you engaged in your job.

Anyway. I was at a seminar yesterday in Manhattan. The seminar, "The Intersection of Privacy, Retention and Discovery Obligations" was presented by CGOC. It was quite good and gave me a lot to consider.

To sum up some of what I picked up yesterday, I think the records management profession is at a very opportunistic inflection point. In the past year since I joined the Day Job, I've moved from the Law Department and just trying to work out the records management program to the IT department under the CISO and taken on Discovery and Forensics Support responsibilities. And there are more changes likely to come.

What I am experiencing is not unique. Records Management isn't just about retention schedules and filing systems anymore. That's the core, but there are other things that crowd into this space as well in many organizations.

The premise of the seminar was that the relationships between Records Management, Privacy, and Discovery (among several other areas of focus) are so strong that they need to be organized together. While most of the people in the audience reported that Records Management was organized under their company's Legal Department, there were a number of us reporting organization under IT. One speaker indicated that it is only logical for the CIO to actually have responsibility for all of the information in the company. In addition, the CIO tends to have troops in the field in many more places than the Legal Department, so the reach and opportunity to properly manage information is far greater.

So that is one data point to mull over. Another is that Records Management has to understand and have very close relationships with legal discovery processes and data privacy issues. The presenters at the seminar are seeing global regulatory trends which mandate that certain records must not be retained longer than necessary -- and that some regulations specify the maximum length of time that records can be retained. This is a fundamental change in our world. Historically, we have looked at a regulatory retention period as a minimum. Business need or some other reasonable internal need could trump the regulatory retention period and require that the record be maintained for a longer period of time. In addition, there are a number of pundits out there that advocate "keeping everything forever". (I'll rant on that later.) The reality is that in certain geographies, certain information will be required to be dispositioned under penalty of law. Now that clearly will be a challenge at times. For very large global companies, the IRS can be notoriously slow at resolving tax audits. Sometimes litigation takes forever. And sometimes regulations will simply be out of step with business requirements for certain information. But what this points to is a need for Records Managers to be aware of all of these issues and work hand in hand with experts in these areas.

The bottom line to all this is that Records Managers need to start looking beyond basic Records Management. If you are stuck in the file room or the records center and you aspire to do more, you will have to get out of those operational jobs. Build relationships. Learn more. Deliver more thought leadership in your organization. There may be times where the opportunities will come to you, but you also need to seek opportunity and demonstrate that you are conversant with these issues and be ready to take them on.

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