4 Signs Your Document Disposal Policy Needs Work

Is your current document disposal policy whatever the previous employee verbally passed on to the new employee during on-the-job training? This verbal transferal of information is open for interpretation, may lack clarity and is likely incomplete. To make matters worse, the original source of this information may have been several employees previous.

A document disposal policy identifies the responsibilities of staff, volunteers, board members, and outsiders for retaining and documenting the storage and destruction of the organization’s documents and records.

Key Points of an Effective Document Disposal Policy

Do you have a written policy? If not, now is the time create one. If you already have a written document disposal policy, ask yourself these questions:

• Is it regularly reviewed?
• Is it current with the applicable federal laws?
• Does every applicable employee have access to it, and are they familiar with it?

4 Signs It’s Time to Clarify Your Document Disposal Policy

If you already have a written policy, here are 4 ways you may need to increase its clarity:

1. Application: Is it clear and obvious who the policy applies to? Are there any document exceptions? For example, are archival/historical and lawyer-client privilege documents exempt? What happens in the event your organization is served a subpoena or there is an investigation or audit? Consider various scenarios where documents may or may not fall under the policy as it’s written now.
2. Retention Period: Does your policy have a clear schedule of how long documents are to be retained? Some US states, certain types of organizations and documents have different retention periods. For each document, determine the beginning date of the retention period. For example, is it the date of creation, the last date used, or the expiration or termination date of a contract? Document retention periods are set by law and will help you avoid premature destruction and the risk of security breach if a document is held too long.
3. Responsibility: Does the policy make it clear who is responsible for ensuring the retention periods and destruction procedures are followed? Will they destroy the documents immediately or collect them until a specified destruction date? Is the staff knowledgeable about applicable state and federal laws like FACTA, FSLA and HIPAA?
4. Destruction: Does the policy clarify the document destruction process, including time constraints? Who gives permission for the destruction of documents? Is the destruction done in house, and what are the procedures for ensuring privacy and security? If the destruction is done by a third party, what are the requirements and expectations of the destruction company? Who should be notified following the destruction?

Having a well-organized and thorough policy is a great start to effective and compliant document destruction.

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