
If you’ve ever been involved in records management, you know that disposition can be harder than putting socks on a rooster. Retention-conscious folders and a good file plan are great tools to set yourself up for success, but you might run into an issue: What happens when we can’t predict the trigger date of a record? How do we make sure that those records with ambiguous trigger dates aren’t left behind?
But wait! What’s a trigger date? The trigger is the moment a retention period starts the countdown. Some are easy to predict, like FE, the end of the fiscal year. Others could happen at any time, like US, the moment the record is superseded. Here are some tips:
Periodically Review Ambiguous Records
Set a scheduled time to review these records and check whether the trigger date has occurred. That doesn’t have to mean every record, every time. For example, if you have an evergreen engagement agreement with your general counsel that hasn’t changed in a decade, you might only review it every two or three years. On the other hand, organization charts and emergency plans might need to be checked more frequently.
Find the Experts
Decide who in your entity should conduct the review. Those individuals should be able to determine whether a record’s trigger has occurred. If you’re stuck, try holding up a record and asking yourself: Who knows that this exists? Who would know if the trigger event occurred? If possible, build a well-rounded team to catch every angle. Consider people in centralized financial or administrative roles, records liaisons, division directors, and program supervisors.
Put it in Writing
Create procedures for the review, and update existing procedures to make sure it’s integrated appropriately. This could include procedures for disposition, terminating contracts, selling government-owned assets, or documenting an employee’s separation. Clearly establish who is responsible for what, appoint records custodians, and make sure everybody has a point of contact. Finally, encourage teams and employees to centralize their records, whether that be in a shared drive or the cloud.
Utilize Your Metadata
You can use metadata to add information like records series, retention periods, or an “ambiguous retention” tag to electronic records. When it’s time to review, use that information to search for and categorize records without clicking through each folder. Many electronic document management systems (EDMS) have built-in features that allow you to set alerts, designate custodians, and even automatically calculate disposition dates.
Managing unpredictable retention periods can be tricky, but prioritize clear, consistent procedures and documentation for disposition overall. Wherever you are in building your records management program, keep it up! There’s no such thing as too far behind.