Customer Misconception: Only Large Records Purges Need Destruction (not daily paper) – Selling Information Disposition by the Book (vol. 4)
Bob Johnson, NAID CEO
The third most costly misconception is when customers do not give appropriate attention to destroying the media that they discard on a daily basis in the normal course of business (usually waste paper).
In fairness, most of the data destruction industry growth in the U.S. market over the past 15 years is due to the fact that more and more organizations do destroy incidental media. In that regard, things are better. However, there is a still lot of room for improvement. Not only do too many organizations still neglect protecting the media they discard daily, even if they do provide a way to collect it, they do not make sure it all gets in the security container.
This usually boils down to one common denominator: The client doesn’t really think of the discarded daily media as an official business record.
The book, Information Disposition, spends considerable real estate on educating clients to understand that incidental records – those that never go into a box or are not retained – are business records in every way and that they require the same amount, perhaps even more security. Further, the book explains that employees should not be give the discretion to make a decision on what gets destroyed and what does not. It all needs to be destroyed.
On example of this language can be found on page 59 in Chapter 3: Records and Information Management Principles:
A discussion on proper information disposition requires an understanding of how records are created and that all information recorded by an organization has the potential to be considered a record. As described previously, such records may be incidental (having only a momentary lifespan), duplicate (copies of controlled records), or controlled (retained by the organization, preferably subject to a formally adopted retention schedule). These records exist independent and regardless of the media on which they are stored. While controlled records are conventionally recorded on paper or electronic media, something as casual as a handwritten note on a cocktail napkin can qualify as an official record in certain circumstances.
For purposes of this chapter, “record” will be defined as any recorded information created in the course of or as a function of an organization. It is admittedly a very liberal definition, however, when it comes how courts might interpret or define a “record,” it is prudent to anticipate the liberal definition as opposed to a more restricted interpretation. To that end, when designing an information disposition program, organizations should be mindful to comprehensively account for all potential sources and types of information including memos, duplicate or flawed forms, or even a casual planning note jotted in haste, regardless of whether that information is recorded on paper, computer, a removable solid state flash drives, email, or magnetic tape.
Later in the same chapter, the discussion resumes on the destruction of incidental records:
Disposition of Incidental Records
As previously defined, incidental records are those with a lifespan limited to their immediate usefulness. Common examples include memos, reports, surveys, drafts of correspondence, and flawed copies of forms. From a RIM perspective, the most important thing to remember is that they are as much an official record as those retained formally. Failure to identify incidental records and develop written procedures for their proper disposition is inconsistent with regulatory compliance and RIM best practices.
Due to their nature, no internal authorization is required for the disposition of incidental records.
As with all the examples provided in these blogs, I am providing only a couple samples of the type of education provided in the textbook that make the point. Information dispelling the misconception – or in this case omission – for the need to destroy incidental records is woven throughout much of the book.
May 8, 2017