As ironic as it sounds, to a lot of companies the phrase Data Retention indicates as much when something should be deleted as what should be retained. For the Environmental Protection Agency, compliance with federal Data Retention policies means both aspects must be reviewed and acted upon regularly.
To comply with the Department of Defense 5015.02 Electronics Record Management Software Applications Design Criteria Standard and the National Archives & Records Administration schedules, records management systems like Qualtrax must be able to support deletion of records once they’ve passed their retention schedule, or lifetime of support. This means completely removed, rather than archived to another location. According to Angela Ockrassa-Davis, QA Coordinator at the EPA, “The ability to delete a record after the end of its retention period is important to us not only because we have a legal obligation to do so, but it may also cause problems with electronic discovery and FOIA if not implemented.” These requirements have a significant bearing on Qualtrax’s customer base as the DoD standard has become the accepted standard for many local, state and regional government entities.
During implementation of Qualtrax, the EPA team raised these needs as critical to their Quality Management System’s disposition of records. Understanding the value of this functionality, we worked closely with the EPA and other agencies to scope and build features to support the safe deletion of data across all modules in the system.
With the 2016 R1 release of Qualtrax, administrators with the Data Retention permission can delete documents, workflows, trainings and test records. In each case, a reason must be provided and the administrator must confirm by typing the item’s unique ID# to ensure the intent.
If older revisions of a given document should be deleted, while more recent ones remain, administrators can remove specific revisions too, as shown below. “Once our internal requirements for record destruction are met,” says Angela, “including but not limited to retention schedules and no litigation holds, the act of deleting electronic documents (e.g. SOP), especially by version, provide closure to our record management procedures in a productive and time efficient manner.”
A new report around Data Retention activity is also included to provide an auditable overview of how data retention policies are being enforced. Key information around when an item was created and when it was deleted, along with the deletion reason, is included to ensure disposition timeframes are followed correctly.
From the initial features in this release, we’re looking to add enhancements supporting business rules associated with each classification of data so automation can be added to perform these tasks without manual overhead at the proper frequencies. If uncontrolled records of exhibit materials need to be purged after 5 years, the system will automatically do that in other words. Approvals for mass deletions and exceptions for litigation holds are also planned.
As data retention policies and standards mandating them become more commonplace, quality management systems, like Qualtrax, must continue to evolve to meet these needs.