Organizations Believe More Training Needed in Records Retention Policies


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Organizations Believe More Training Needed in Records Retention Policies

Tom Aleman
National Product Line Leader Analytic & Forensic Technology
Deloitte Touche Tohmatsu

The results of an online poll released recently by Deloitte Financial Advisory Services LLP (Deloitte FAS) show that nearly 70 percent of the respondents said they need additional training on their company?s records retention policies and procedures.

Almost 45 percent said they would like training on all related company policies, while 25 percent said they would only like training related to the new rules. The online poll was conducted during a recent Deloitte FAS webcast on electronic discovery. Audience members included CFOs, tax directors, finance directors, attorneys and controllers, among others.

In April, the U.S. Supreme Court approved amendments to the Federal Rules of Civil Procedure that address the discovery of various electronically stored information. The amendments, scheduled to take effect on December 1, 2006, require that companies, under certain circumstances, promptly disclose categories and locations of electronically stored information (?ESI?) without waiting for a discovery request, in addition to other ESI requirements.

?Creating retention policies and procedures is not enough anymore,? said Tom Aleman, national product line leader of the Analytic & Forensic Technology group of Deloitte FAS. ?Companies need programs designed to help manage records and information, and the programs should include staff training and compliance auditing.?

The online poll also showed that while some organizations have made changes to their records retention policies in the past two years, others have not. Approximately 38 percent of corporate executives responded that their organization has changed its records retention/destruction policy in the past 24 months; of these, more than 12 percent said this change occurred based on their own internal litigation matters and 26 percent said it was based on matters in the marketplace. Approximately 39 percent of those polled said their company?s policies have not changed during this time frame and almost 20 percent said they did not know if their company changed its retention/destruction policies.

?The time is ripe for companies to inspect their records retention programs, and to consider whether changes may be necessary in light of the new federal amendments,? Aleman said.

The Deloitte FAS online poll shows that more than 50 percent of the participants said they have been asked at some point by counsel to identify and retain certain documents. More than half also said they do not make backups of their electronic data separate and distinct from what the company?s IT department provides. ?Corporate executives need to be aware of how their organizations and their people store and manage data to help minimize problems or surprises if litigation matters should arise in the future,? said Aleman.

The preservation of records has become increasingly complex in this digital age. According to Aleman, electronically stored information can reside in backup tapes, blind ccs and in employees? home computers, among others, which can often make trying to find data similar to finding a needle in a haystack. The new amendments for electronic discovery have provided a good opportunity for companies to discuss issues related to the preservation and disclosure of electronically stored information and to train employees on data management procedures.

Deloitte refers to one or more of Deloitte Touche Tohmatsu, a Swiss Verein, its member firms and their respective subsidiaries and affiliates. As a Swiss Verein (association), neither Deloitte Touche Tohmatsu nor any of its member firms has any liability for each other?s acts or omissions. Each of the member firms is a separate and independent legal entity operating under the names ?Deloitte?, ?Deloitte & Touche?, ?Deloitte Touche Tohmatsu? or other related names. Services are provided by the member firms or their subsidiaries or affiliates and not by the Deloitte Touche Tohmatsu Verein.

Deloitte & Touche USA LLP is the US member firm of Deloitte Touche Tohmatsu. In the US, services are provided by the subsidiaries of Deloitte & Touche USA LLP (Deloitte & Touche LLP, Deloitte Consulting LLP, Deloitte Financial Advisory Services LLP, Deloitte Tax LLP and their subsidiaries), and not by Deloitte & Touche USA LLP.

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