The act of disposing of a record is not one which should be carried out in an ad hoc or unmanaged manner, but according to pre-defined criteria and clearly articulated processes. This will ensure that you can justify why the records in question where destroyed, as well as proving beyond refute that no trace of them remains.
Why is this important?
Even if carried out with completely innocent motives, the uncontrolled destruction of records without proper authorisation or due process can easily be interpreted as an attempt to avoid releasing damaging information and prevent the cause of justice. Notorious cases of deliberate unauthorised destruction of records such as at Enron have increased the need to be seen to exercise suitable control over this aspect of records management.
The introduction of the Freedom of Information Act in the UK has also increased the importance associated with the need for transparency and accountability during the disposal process and the requirement for an institution to be able to defend its actions if challenged.
Finally, if carried out according to a clear and defined process, the chances of either valuable records being destroyed in error, or the wrong records retained, should be significantly reduced.
How to appraise and destroy records
- Have your records retention schedule officially approved by senior management, providing high-level authorisation for the activities carried out according to its content
- Although your retention schedule will provide the basis for your selection and decision-making process, also be aware that the schedule only defines minimum retention periods. Be prepared to consider any special circumstances which may alter the situation for individual records (for example, any record which is the subject of an ongoing FOI request should not be destroyed, even if due for destruction according to the retention schedule)
- Turn the appraisal and destruction process into regularly scheduled business processes, rather than ad hoc events. Establishing a department-by-department timetable can help embed this into the institutional calendar. Likewise, specially organised ‘black bag days’ can be successful in ensuring scheduled retention actions are actually carried out within offices
- Ensure all copies of records scheduled for destruction are destroyed (including those stored off-site, or electronic records stored on back-up tapes or servers).
- Ensure records are destroyed in a confidential and non-recoverable manner (i.e. incinerated or cross-shredded)
- Consider the level of approval required to destroy records and ensure a documentary audit trail is in place which records the process from selection through to confirmation of destruction.