http://rhizomedigital.com.au/why-determine-community-obligations-in-business-records-retention/
Another hefty topic for a blog post, but it something that needs to be talked about more I reckon. And by the CSO sector as a whole, as it is too big for individual organisations to keep grappling with in isolation.
I was trained as a Records Manager at Monash University, which many people may know is the place where the Records Continuum Model was created. Our education is very much influenced by the lessons of the continuum. For me in particular, as I have continued my studies there and conducted a research project, my work heavily reflects this philosophical position. Position stated.
What this means in practice is that I attempt to figure out all the implications of recordkeeping across space and time. I have previously called myself a time travelling archivist, because I think what I do is to analyse how records were created – the processes involved, and then determine who might be interested in them far into the future and why. I take into account a variety of obligations that impact on recordkeeping – such as compliance with various authorities, what the business needs to fulfil its own requirements, as well as wider expectations of co-creators of records, their families, communities and society as a whole. This is why I call it strategic time travel. The time for archives and archivists being about supporting historians is over. Many people want to use archives for many reasons. I digress.
When I worked for the Brotherhood of St Laurence I undertook a DIRKS project to support the creation of multiple recordkeeping tools, such as a Business Classification Scheme, Disposal Schedule and Thesaurus. See the paper I did for the IQ on a BSC as a tool for change (and here for the free draft). During the DIRKS project I read lots of legislation and spoke to lots of people in the business about how they decided how long to keep records for. Most of the answers were straightforward and complied with legislation or accreditation purposes. However, many answers came from individual ideas about value in an immediate time frame, as well as into the future. Some people just knew what was important to keep, but could not articulate why.
In other organisations I have worked with since this time I have seen this pattern repeated. Some of the organisations were community based, but not big service organisations like the Brotherhood of St Laurence. Most often or not I have managed to speak to members of the community group, or employees who created records. Some organisations want to know their legislative and regulatory obligations only, but still get stuck on how to make decisions on what length of time to keep records – particularly client records.
The common feature I have noticed across all organisations I have ever worked for is the unwillingness to interact with community or stakeholders in relation to retention of records. I find this surprising for community organisations, but can understand that this interaction might be perceived as being counter productive and take far too long (and cost too much money). Yet I feel strongly that this is a vital part of determining a retention and disposal policy.
Of course community expectations can be gauged by looking at information requests to the organisations, or current issues in the media. But does this really provide enough information about community expectations? Does this process help to identify who the community and stakeholders are? I don’t think so. More and more people are understanding that they are part of a records creation process – co-creators of business records. Client records are a great example – with the client there is no record. A client is not the subject of the record, but with their information, they should be considered a co-creator.
So what does this mean for recordkeeping and retention? I have a few ideas. It is possible to conduct a survey of clients whose records already being held to gain a broad understanding and a potential common position on retention. There can be focus groups and other ways to gather information. But all of these are done after the record is created. In many cases these surveys might be sent out when a client no longer has contact with the organisation. And also with surveys, there is not a great response rate. How can a common position be established when on 20% of people responded? My response is – why wait?
Imagine if you were creating a client file you asked the client how long they expected this file to be held for before it was destroyed? What a radical idea! If the information about the client, or register of the client is in a database, how easy would it be to add another field? How many records managers out there evaluate a database for records ready for disposal and produce a list to be reviewed? This field would be just another way to determine when that entry was included in the list.
Of course there are issues and risks in letting clients determine the length of time their record should be held for. And of course there are legal obligations and wider social obligations, but imagine real inclusivity for clients, donors, employees. Its not a large technical change, just a cultural and process change. Our legal system is set up so that anything created in a business is owned by the business. I am not talking about ownership, but rights of the (co)creator.
And while we are at it, why not ask the co-creator about access and privacy? Yes we have legal obligations, but what if the client said they were happy to have family have access to their file?
I can see potential issues with clients saying they want their records held forever. Forever is a long time. Most people, even budding records managers I have taught, do not really understand what permanent retentions means. I wonder then why not ask if they want to keep certain parts of their record, rather than the whole thing? Or have a business policy which says there is no permanent retention with temporary retention of max. 99 years. After this time, if a client has indicated they want their record held for that time, the family is then asked if they want it. If they do not, then destroy.
At least one of the organisations I have worked with has decided that client records are held permanently because of community expectations. Now that is going to cost a lot of money in the long term. Imagine then if the business created lots and lot of client records because they provided aged & community care, or did a lot of family counselling? There are legislative obligations around health records and for children which might impact on the family counselling records in particular, but is the blanket permanent retention really that feasible? What about student records of a registered training organisation or financial counselling records?
What does it mean for an organisation to ask clients for input into recordkeeping practices? Its a challenging idea. Business records are considered assets and of course they are, but what are the obligations organisations have with others who are part of the records and the creation process? I would think a lot and things need to change to recognise and be more inclusive.
Hmmmm. Imagine lawyers and accountants taking up these ideas with their client records?
Comments