June 24, 2009, 11:48 AM — It can be a struggle to wade through the labyrinth of industry regulations that pertain to records management—especially when you are focusing your resources on the day-to-day operations of your business. You might even be tempted to direct your time and energy towards other business-related endeavors that are likely to generate more obvious results. After all, it is difficult to see how prioritizing records management will increase your bottom line.
Unfortunately, that mentality is easily shattered if and when your organization has to undergo a litigation event. Penalties that are levied upon organizations that are unable to produce documents on demand can bankrupt a company. With records management requirements getting more stringent with each coming year, the time to enact a strategy is now. To help you implement a records management strategy that meets industry standards, we’ve included some answers to frequently asked questions.
Where do I start?
The temptation might be to start with the implementation of a software system that will address your records management requirements. Although this is a key component to a robust strategy, there is a critical step that must be undertaken first. Records management starts with a message from your executive leadership that resonates throughout your entire enterprise. This message should outline the need to manage and retain records, and should establish accountability measures. In short, your strategy should incorporate internal controls that are manageable and enforceable.
Make sure that you have a policy that is specific. It should spell out what constitutes a record, and what differentiates records from other documents. Set up classification schemes for your records, and outline measures that your organization will take to enforce your policy. Ideally, your goal is to make information transparent. Establish indexing guidelines to make records retrievable by authorized personnel, regardless of who created your records.
Establishing these rules should be the first step in your strategy. Provide documentation that will confirm that everyone in your organization is aware of your records management rules, and is mindful of the repercussions of noncompliance. Bear in mind, too, that it is worse to have a policy that is not followed than it is to have no policy at all.
I’m in the process of transitioning to EDM. Will that make my records management efforts any easier?
Heterogeneous environments, which contain a mixture of paper and electronic information, often present complications to record management efforts that go beyond those experienced in either a strictly paper or a strictly electronic environment. One way to address this difficulty is to enact policies that address incoming documents—especially paper and semi-structured documents—as they enter your work environment.
Incoming paper documents should be scanned, indexed, and either stored electronically or routed immediately. Semi-structured data such as email and Instant Messages—if they meet your organization’s definition of records—should be designated as such, indexed, and saved to your electronic document repository. They are then eligible to be treated with the same rules, audit capabilities, and lifecycle management strategies that you use for the rest of your records.
Archived paper records often pose retrieval difficulties. Storage can be cumbersome, and records can be easily lost, misplaced, or duplicated. The best way to ensure that your paper records are being managed according to industry standards is to scan and index them, saving them within your document management repository. This way, you are assured that retention and destruction schedules can be assigned and followed. By making the records electronic, you can assure privacy and also instill auditing capabilities. These provide information regarding who viewed specific documents, and when they were accessed.
What is the best way to ensure that my records management strategy complies with industry regulations?
In a word: vigilance. Be aware of regulations that affect your industry, and make sure that your policies conform to the stipulations of those regulations. Be aware, too, that in a heterogeneous environment, compliance can be difficult. For example, HIPAA mandates strict privacy measures that are difficult to achieve if your records are still paper-based. Regulations are rarely static; industry demands often become more stringent. You need to stay abreast of changes, and have a system and the resources in place to accommodate them.
Be aware also that different record types have different retention requirements. An electronic document management (EDM) system can simplify your efforts that are geared toward scheduled retention and destruction schedules. By automating this process, you remove the potential for human error and ensure that records are accessible throughout their entire lifecycle. Automation also ensures that records are not kept beyond the time for which destruction is warranted.
Unfortunately, EDM in and of itself will not guarantee compliance. The tools associated with EDM, however, can demonstrate that your organization is making sincere efforts to ensure conformity with regulations. Storing your records in an electronic repository—by definition—makes compliance far more attainable and verifiable than paper processes will allow.
How does records management prepare me for E-discovery?
If your organization finds itself in a litigation situation, it will be required to produce information on demand. The longer it takes to locate and access your records, the more likely it will be that your business will incur costly penalties. With the ability to automate retention and destruction schedules, your organization is assured that it will be able to access and produce documents when required. A records management strategy that includes records migration will also save storage costs, enabling you to use inexpensive storage media for long-term storage. With a strategy that allows you to maintain, protect, store, and properly destroy your corporate records, you can be assured that you will have the ability to confront and comply with litigation requests.
Aside from compliance, what are some of the other benefits of records management?
A records management strategy can dramatically improve your business processes by ensuring that information is accessible to authorized personnel at all times. Records are no longer duplicated, misplaced, or lost; and your organization can be assured that information will not be destroyed prematurely. Data that is housed in legacy systems is also available to organizations that use EDM as a component of their records management strategy.
Furthermore, a solid records management strategy guarantees that your company is protected in case of a disaster. Having a single electronic repository for your information makes it possible to access records and share information from any Web browser—whether your employees are across town or on the other side of the world. In the event of a catastrophe, your business has a far greater probability of continuing without interruption.
Internal audits, tracking, and other monitoring applications that are associated with records management assist with periodic review of your system. In addition, they improve accountability as well as decision-making. This allows management to gain a wide overview of your processes at any given moment. Inefficiencies can be addressed proactively, before your bottom line is affected. Customer service, too, is positively impacted with the ability to provide immediate answers to queries.
Albert Einstein said, “Life is like riding a bicycle. To keep your balance you must keep moving.” Managing your records, too, is an intricate process. You must continually evaluate your strategies, and adjust them according to changes in compliance requirements. Make sure that you have an established policy that dictates to every employee your management strategies surrounding records creation, maintenance, use, and disposition. Have measures in place to enforce that policy. Transition your paper processes to electronic so that they are eligible for auditing, privacy, and security measures, and can be assigned retention and destruction schedules. There has never been a better time to establish a solid foundation. The only certainty that the future brings with respect to records management is that requirements will only become more stringent and challenging. With a solid records management policy and system in place, you will be prepared.