The Records Room With No Retention Schedule
The records room of a cooperative institution in Berhampur is 20 sq m and holds files going back to 1998. Shelves are loaded to the ceiling, 60 per cent of the floor area is blocked, and staff say they need twenty minutes to find any file older than three years. A rough survey shows that 40 per cent of the files have not been called for in the last five years. Among them are loan files of closed accounts, title-related papers, service records of retired employees, internal audit reports and routine correspondence about meetings. The internal auditor is due in three months and has previously objected to missing documents. The office has no written retention schedule, and the head of office is unwilling to destroy anything because someone may ask for it later. Two clerks can be spared for record work for one month.
1. How would you categorise these records and decide what may be considered for disposal, given that no written retention schedule exists?
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With no schedule, the safe approach is to classify by the kind of value the record carries, and to treat 'not consulted recently' as a weak test rather than a decision rule.
Category A, never a disposal candidate: title-related papers and service records of retired employees. These protect rights and may be needed decades later, and an absence of recent consultation proves nothing; a title deed sits untouched precisely because it is secure.
Category B, retain for a defined period and then review: loan files of closed accounts and internal audit reports. These need to survive the audit cycle and the period during which a claim or objection could arise, so the retention period should be set with the auditor and legal advice rather than guessed.
Category C, disposal candidates after approval: routine correspondence about meetings, circulars and acknowledgements of past years, which have no continuing financial or legal effect.
Because there is no written schedule, the first deliverable is a draft schedule listing each category and proposed retention period, submitted to the head of office and the auditor for written approval. Disposal then proceeds rule by rule, not file by file on personal judgement.
2. Describe the procedure you would follow before and during the actual destruction of any records.
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Destruction without a documented trail is how offices create the very audit objection they fear. The procedure has five steps.
1. List. Prepare a disposal list giving file number, title, year and category, drawn from the shelves, not from memory.
2. Circulate for objection. Send the list to every section and to the accounts function for a stated period, with a clear instruction that any pending court, audit or departmental reference must be marked and the file withheld.
3. Obtain written approval. The competent authority signs the list, with the auditor's concurrence where financial records are involved. Approval is for the list as approved; later additions need fresh approval.
4. Destroy and record. Shred or pulp the approved files in the presence of two witnesses, and enter the list number, dates, quantity and witnesses in a permanent disposal register. Remove the corresponding entries from the index so that no one later searches for a file that officially no longer exists.
5. Keep the list permanently. The list becomes the institution's evidence of what existed and when it was lawfully destroyed.
The two spare clerks should be used for listing and indexing, not for deciding.
3. The head of office says nothing should be destroyed because someone may ask for it later. How do you answer that objection?
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The objection is reasonable in motive but wrong in effect, and should be answered on his own ground: protecting the office.
First, no space means misfiling of current records. Staff already take twenty minutes to find a file older than three years, and the auditor has objected to missing documents before. An overloaded room is itself producing the loss he wants to prevent.
Second, disposal under an approved schedule protects him more than indefinite storage does. If a query comes years later, the office can produce the approved list and disposal register showing that a specific category was destroyed on a specific date with authority. An unmanaged room offers no such answer; it offers only the possibility that the file is somewhere.
Third, offer a middle route to reduce his risk: doubtful files go to a review shelf for six months before destruction, and a summary index of destroyed files is retained permanently so the office can say what existed. Nothing is destroyed this quarter without his signature.
Finally, invite the auditor to comment on the draft schedule. Once the rule comes from the auditor rather than from the records clerk, the decision stops looking like a personal risk and becomes a compliance step.