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MANAGEMENT UPDATE.

THE RISKY BUSINESS OF RECORD RETENTION

Whether documents are stored in file cabinets or electronic form they must be inventoried, overseen protected and sometimes discarded.  While statutes commonly spell out data retention policies, imperfect implementation of these tasks can have serious consequences. Among them are difficulties complying with open record requests, succeeding in litigation, organizing critical personnel files, preserving stakeholder privacy, and maintaining government security.


Managers tasked with enforcing these policies have it hard enough, and the problems escalate when those responsibilities are really no one’s actual job – a hazard in agencies plagued by low staff levels and escalating demands. 



Last fall, an audit of the Louisville Metro Police Department spelled out some of the consequences of inattention to record retention policies, while offering a number of recommendations for improvement that could benefit other entities as well. Though the audit itself focused on the police department, “there is a lack of oversight for record retention organization wide,” Louisville Metro Government auditors noted in their observations.


According to the audit, one serious problem for the police department was that record retention responsibility had not been assigned “to a specific individual or unit,” and that annual reviews were lacking to make sure that records were added when new or obsolete ones were removed, even though statutes call for that process. 


The audit recommendations, all of which were accepted by the department, could be useful to other agencies and governments as well.


  • Determine the optimal oversight activities for the record retention process.

  • Make sure there’s periodic training.

  • Embrace consistent practices across different parts of the division.

  • Define and designate oversight responsibility to a specific individual or unit.

  • Review policies at least annually.

  • Make sure the list of department record coordinators is accurate and up to date.

  • Store hard copy records in secure storage areas.

  • Ensure that access to electronic versions is appropriately limited.

  • Develop minimum guidelines for record retention.

  • Perform periodic monitoring activities (like maintaining record inventories).

  • Make sure records are complete (such as investigation files, within the police department).


The audit also notes the importance of destroying records according to the record retention schedule. According to the audit, “Retaining records indefinitely increases the risk of unnecessary exposure of records and information, as well as an inefficient use of storage space (including electronic) and resources.”


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