We don’t get too many folks calling up saying they want a document management system because they have document retention laws to follow. In fact, zero people in 16 years have called and ask me for that.
But unfortunately, document retention is a big part of meeting compliance for some of our customers. Especially the financial services industry, they are probably the most regulated when it comes to compliance with their documents.
I would say the healthcare industry comes next given all the HIPAA Rules. Government agencies come to mind as well.
In the paper world document retention can be a real pain in the you know what. Most probably just ship the boxes off to a warehouse, attic or spare room and forget about it until they need space.
Then the questions begin. What can we throw away and what should we keep?
A good retention capable document management system can certainly make this easier. Granted it is still an inconvenience as is any Government regulation. Sometimes it’s so inconvenient that companies just move their business to another country but we won’t go there. (no politics rule….noted)
So, in our world of document management we have to consider a few things when making the system retention capable.
What I will talk about here are the different retention types in document management systems and how you can get rid of the documents after retention is met.
Remember we are not printing paper anymore to be stored. Instead, we are creating Word, Excel, PDF Forms, PDF’s, TIF’s, Emails and others.
I can only address this from the standpoint of Cabinet Document Management Software since that is my favorite DMS. However, I think most enterprise systems will follow something similar.
First of all, we have the ability to create “Retention Policies” e.g. 3 years, 5 years, 7 years, etc.
These policies are then assigned to a “Document Template” that is used to create the document regardless of how it comes into the system. Document naming templates are a great way to systematically apply security, retention and naming schemes regardless of the number of users inputting documents.
So, documents may be assigned a retention policy upon creation and in some cases later. By default, documents do not have retention applied unless a template with a retention policy is used to create the document.
It is imperative that retention can be applied in different ways to meet various business processes.
There are different types of retention policies available in a document management system as noted by the Journal of Health Care Compliance January 2010 Edition:
Modifiable: This retention type allows for resetting the retention policy, meaning the time period. The policy can be set to any other retention policy including “none.” If set to “none” the document can be edited. It also allows changing the retention type in the management console from modifiable to another type.
Fixed: This retention type sets the retention for the defined period of time for the policy. The document can only be deleted or archived once the retention period expires. Editing of the document is not allowed. The retention type can be changed to another type in the management console.
Indefinite: This retention type sets the retention period to never ending. The retention type can only be changed to a policy with permanent type from this retention type. During the indefinite setting, the document cannot be edited or deleted from the system.
Permanent: This retention type, once set, cannot be changed to any other type or policy. The document assigned this retention type cannot be edited. It cannot be deleted or archived until the retention period has expired.
Retention is not hard to setup once we understand the need, but it can be inconvenient to users so we have to approach it very carefully. I think most people just take delete rights away and have plenty of drive space to store documents forever to avoid the inconvenience. However, if a user still has edit rights to those documents then compliance is not being met.
If retention is a big deal the only right way is to implement it through your document management system with one of the retention types above.
How do we get rid of documents that have met retention?
This is a question that always arises and rightfully so. The first thing people think is that they automatically go away. Not quite. We still need someone to make a decision that it is ok to archive or better yet delete these records.
Even if the capability exists, It’s never a good idea to leave that to technology. Remember, just because you can does not mean you should. It’s sort of like automatic backups where folks just swap a tape every day and never know if there is a good back up on the tape. We want to know for sure that this activity took place.
So, in the Cabinet System the way it works is you can search all documents that have met retention and then decide what to do with them. Delete or Export are the two options that come to mind.