In my previous post on this subject I noted that:
Organisations that have complex records retention schedules/disposal authorities should consider grouping retention classes that have the same retention period into a single generic policy
This post provides examples how this outcome can be achieved based on real life examples from the private and public sectors.
Note – I have spent over 20 years creating and managing records retention schedules and disposal authorities, as well as the application of those schedules, for a range of private and public sector organisations.
What are complex records retention schedules / disposal authorities?
There are two main types of complex records retention schedules or disposal authorities. For ease of reference, I will refer to both as ‘retention schedules’.
Complex retention schedules usually contain a (very) large number of ‘classes’ that (a) describe various types of records across the organisation, and (b) define how long those records must be retained before they can be destroyed.
They have two common features:
- Multiple classes for different types of records, with the same retention period.
- Repetition of the same class (type of records) found across multiple business areas. For example ‘Policy’, or ‘Procedures’, or ‘Reporting’.
What are Office 365 records retention labels/policies?
Office 365 records retention labels are created in the Office 365 Security and Compliance admin portal under the ‘Classifications – Retention’ section. Retention labels describe types of records and define how long they should be kept before disposal.
Labels become active when they are published as retention policies. The publishing process includes a decision on where the labels will be used, for example ‘All locations’ or specific locations such as SharePoint only (or a SharePoint site).
When Office 365 retention labels/policies are applied to a document library in SharePoint, any policy that has been assigned to all of SharePoint and to that specific site, will appear in a drop down list.
In organisations with complex retention schedules, a very long drop down list of retention policies will be visible, but only one can be selected per library.
A private sector example
The retention schedule used in this example has around 150 classes grouped by recognizable business ‘subjects’ or ‘functions’ (e.g., Executive, IT, Property, HR, Finance, etc).
Many of the classes in this schedule require records to be kept for a minimum of 7 years. For example:
- Records of company meetings and committees. (Executive)
- Final versions of the official minutes of all other organisational meetings and committees. (Executive)
- Official correspondence between the organisation and other organisations, including government agencies, not covered by any other class. (Executive)
- Any document that is used to prepare financials. (Finance)
- Staff rosters. (HR)
- Records relating to the preparation or delivery of training to employees. Includes training needs analysis, competency and training profile, training and session plans. (HR)
- Records relating to WHS management system and system maintenance. Includes: document issue and review forms, document control register, and schedules. (HR)
- Records relating to the registration of the organisation’s vehicles. (Fleet)
- IT System related documents, including documents detailing system parameters, usage patterns, system specifications. (IT)
- All tender records relating to the design, construction, or fit-out of a property. (Property)
- Register of visitors. (Property)
- Records relating to the notification of notifiable diseases in any facility operated by the organisation. (Core business)
- Plus many others.
Office 365 retention labels for private sector organisations
All the classes with the same common retention period could be grouped into a single Office 365 retention label named ‘Company records – 7 years‘. Other labels with the same retention period may also be created if it is necessary to specify certain types of content. The screenshot below (example only) shows how this might appear in the drop down list when the label is applied to a library:
End-users would not normally be responsible for assigning a retention policy to a document library; that job would probably fall to the Site Owners or the Site Collection Administrators (SCAs).
If the site or library contains a specific type of records that are defined by a distinct label, that label would be selected. Otherwise, the ‘generic’ 7 year retention policy label can be applied. If the Owners or Administrators are unsure which label to apply, they can check the full retention schedule to confirm the required retention period.
Note – as soon as a retention label is applied, no record in the library can be deleted. It may therefore be better to apply a label only to inactive libraries.
A public sector example
Many records retention and disposal authorities used by government agencies in Australia are based on the ‘function’ and ‘activity’ model that was introduced in the late 1990s.
- Each agency has ‘core’ business functions that are often defined in enabling legislation. (Local government agencies are the exception; their functions are similar).
- Each agency also has a range of general, or ‘common administrative’, functions that are common to most agencies, for example Financial Management, Information Management, Personnel, Property.
- A range of activities are undertaken within each function. These activities are (usually) what produce records. Some of these activities are common to multiple functions; for example, ‘Agreements’, ‘Planning’, ‘Policy’, ‘Procedures’, ‘Reporting’ and ‘Reviewing’ are found in many business functions.
- Each activity includes one or more classes (descriptions) of records, each with their own retention period; some of these may be the same.
- Activities that are common to multiple functions (e.g., ‘Policy’ or ‘Procedures’) often have the same retention period defined.
Consequently, a single function may have hundreds of retention classes, many with the same retention requirement.
For example, the disposal authority for the ten core functions of the NSW Department of Corrective Services, listed on the NSW State Records website, has around 225 separate classes. The department also makes use of the General Disposal Authority for administrative type records that are common to all agencies, a further 200 or so classes.
The only way to reduce this number of classes, to make it more usable in Office 365/SharePoint, is to use the model developed by the National Archives of Australia.
Office 365 retention labels for public sector agencies
Records Authorities (RAs) produced by the National Archives of Australia (NAA) are based on the same underlying structure (function/activity) but with a much simpler structure.
For each business function, all activities with the same retention period are grouped. In some cases, this may mean increasing (or decreasing) the retention period for some records in order to simplify the model. For example, if records are to be kept for 5 or 6 years, increasing this to 7 years.
This results in a more streamlined retention model for each function. Typically, each function will have 4 – 5 retention classes, for example:
- Retain as Archives (e.g. transfer to the Archives agency)
- Keep for 30 years (in the agency)
- Keep for 7 years
- Keep for 3 years
However, even with this model, agencies with multiple functions could still potentially end up with a lot of retention labels/policies. To get around this and reduce the number of retention classes, classes with the same retention requirement in different functions could still be grouped. For example ‘Retain as Archives’ is completely understandable, as is ‘Keep (for a long time)’ in the agency – often defined as ‘Retain permanently’.