1. Revising a Records Retention Schedule: Rocket Design (It’s Not Rocket Science—It’s More Complicated!) Phil Brady Regulatory Projects Coordinator Department of Financial Institutions

2.  This was my experience. Your mileage may vary.  I’m a huge nerd, but *I* didn’t pick the theme. FLAG ME DOWN! Caveats

3. Why the Saturn V? -Low-Earth Orbit (LEO) was too much for a single engine, so broken down into three stages (like my process). -A lot of moving parts, and a lot of cooperation among different groups. -Used as long as it served its purpose, not longer. -The Saturn V is just plain COOL. The Saturn V

5.  NASA didn’t design, build, and use the Saturn V because it was an awesome piece of technology (though it totally was). It was a means to an end.  A records retention schedule is similarly a means to an end with little intrinsic value. It’s there to make your records management processes compliant and useful. The Biggest Reason

6.  First Stage: the initial legwork.  Second Stage: Analysis (this is the yeoman’s work)  Third Stage: Approval Throughout:  Consult with Archives  Communicate with management  Think about change management plans The Overall Process

7. Key Questions:  What are your agency’s core functions?  What does your org chart tell you about your records?  Is your current schedule arranged by core activities, or by your organizational chart? Both? Neither?  Are there good legal or business reasons to have units doing similar work keep records differently?  Are there any general series that don’t work for your agency? First Stage: Initial Legwork (ground – 36 miles)

8.  Not WHO you serve or regulate, but HOW you serve or regulate them.  NOT administrative functions.  What are the meaningful distinctions? For DFI:  Licensing  Examination/auditing  Enforcement What are Your Agency’s Core Functions?

9. What Does Your Org Chart Tell You?

10. DFI’s schedule was organized by Org Chart, then sort of by core activities. Does Your Current Schedule Mirror your Core Activities or your Org Chart? Both? Neither?

11. DFI’s Old Schedule

12.  Legal (statutory), litigation-based, or business reasons?  Historical reasons? DFI:  Investigations vs. Complaints  Securities vs. CS investigations (15 vs. 6 years)  Bank & CU examinations, vs. non-depositaries Are There Good Reasons for Similar Business Units to Keep Records Differently?

13. Are There Any General Series that Don’t Work for You?  DFI amends each of its five CS WAC Titles most years.  Cutoffs of “until superseded” don’t work for us.

14.  Your records staff (people doing the day to day management) can probably tell you if:  There are any glaring holes in your existing schedule.  Any series are underused or overused, or over-broad.  Any series definition is unclear or unhelpful, or where a record doesn’t have a good fit. Subject matter experts may be able to predict with some accuracy the new records types that may be coming down the pike. Talk to Your People!

15. Key Activities: 1.Sort your existing series by the core activity they are closest to (including an administrative category for records that are non-core activity related) 2.For each core activity, analyze and sort the existing schedules according to commonality. (it may be easiest to sort your series by retention period first) 3.Identify the broad record types that appear across multiple organizational groups (these are the lowest-hanging fruit). 4.Identify unique series that don’t overlap with anything else. 5.Identify the unique series that are obsolete. 6.Build your outline, starting with core activities and broad record types identified above and work down. 7.Crosswalk the new and old schedules, and have them reviewed by your staff that conducts the core activities (KEY). 8.Fill out the records retention schedule draft form. 9.Prepare educational materials. 10.Vet it! Second Stage: Analysis (36 miles – orbit)

16.  If your schedule is not already sorted by core activity, sort it by core activities.  It may be helpful to sort by retention period too, as similar types of series may have similar retention periods. 1. Organize By Core Activities

17. Organized by Core Activities

18. 2. Sort and Analyze Existing Schedules

19. 3. Identify and Group Commonalities

20. 4. Identify Unique Records Series Outside the Common Groups

21. 5. Identify the Unique Series that are Obsolete

22. 6. Build Your Schedule, Starting with Core Functions and Broad Types Identified Earlier

23. 7. Crosswalk Old Schedule With New Analogs and Obsoletes

24. 8. Draft New Titles, Descriptions, and Proposed Cutoff and Retention

25. 9. Create Whatever Tools You Need to Explain it

26.  Internally with:  Management  Legal  Public Records  Externally with:  State Archives  AAGs  Stakeholders It’s okay to push back where appropriate, but crucially important to actually LISTEN and REVISE where necessary. 10. Vet This! Then Vet it Some More!

27.  Get an appointment with the State Records Committee, and submit your forms!  Show up to the Committee meeting if you anticipate any questions or difficulty.  Bask in the unmitigated glory of your new, simplified records retention schedule.schedule Third Stage: Submission and Approval (a.k.a. welcome to space! Now what?)

28.  Remember, retention schedules are only good as long as they’re useful.  REVIEW!  REVISE! Stage Four: Maintain

29. Questions?