Records management (RM) is the systematic control of recorded information throughout its lifecycle, from creation and receipt through processing, storage, and eventual disposition. This function focuses on maintaining authenticity, reliability, and usability for business and regulatory purposes. While many assume records oversight resides in a single team, accountability is widely distributed. Effective information governance requires shared ownership and coordinated action across multiple departments and all levels of the workforce. Understanding this shared accountability is the first step toward building a robust and compliant information program.
The Foundational Role of Executive Leadership
The ultimate responsibility for information governance and records compliance resides with an organization’s executive leadership, including the C-suite and the Board of Directors. These individuals are charged with establishing the enterprise-wide culture of compliance and setting the overall strategic direction for records control. This strategy requires approving the formal records management policy or charter that defines the organization’s legal and procedural obligations.
Leadership must also allocate the necessary funding and resources to support the required technology, staffing, and training programs. By prioritizing information integrity, executives effectively mitigate regulatory and legal risk across the organization. Accountability for potential fines, litigation discovery failures, or data breaches ultimately stems from the top level’s commitment to establishing and enforcing the standards.
The Operational Accountability of the Records Manager
While the executive level sets the policy, the Records Manager, or the dedicated RM team, holds the operational accountability for the day-to-day function of the program. This specialized role involves translating the high-level governance directives into practical, repeatable processes that govern the flow of information. The RM team is responsible for designing and implementing the specific program elements that employees interact with daily.
The Records Manager develops and maintains the organization’s retention schedule, which dictates how long specific record types must be kept based on legal, financial, and administrative requirements. The Records Manager acts as the program’s central liaison, ensuring seamless communication between the legal teams, the IT department, and the general employee population. They also manage the entire ecosystem of records, including both physical files and digital assets within the Electronic Records Management System (ERMS).
The RM team promotes compliance through continuous education and training programs for the workforce. They monitor the program’s effectiveness by conducting regular audits and compliance checks across various business units to identify and correct procedural gaps. When records reach the end of their lifecycle, the Records Manager oversees the defensible disposition process, ensuring records are either securely destroyed or permanently archived as dictated by the policy.
Key Specialized Support Functions
Legal and Compliance Teams
Legal and compliance teams provide the interpretation necessary for the records program to meet external mandates. These groups translate complex regulatory requirements, such as those related to financial reporting (like Sarbanes-Oxley) or privacy laws (like HIPAA or the GDPR), into specific rules for information handling. They work directly with the Records Manager to authorize the organization’s official retention schedule.
The legal department maintains accountability for the proper handling of information during litigation or governmental investigation. This involves issuing and managing legal holds, which are mandatory instructions to preserve specific records immediately, overriding standard retention policies. By providing legal counsel on defensible disposition, they ensure that the destruction of records does not expose the company to future liability.
Information Technology Department
The Information Technology (IT) department is responsible for providing the technical infrastructure for digital records management. Their operational accountability lies in ensuring the systems are secure, reliable, and accessible to authorized personnel across the enterprise. This includes managing the Electronic Records Management System (ERMS) or other content platforms where official records are created, stored, and retrieved.
IT teams implement security protocols, such as access controls and encryption, to protect sensitive information from unauthorized access, loss, or corruption. They manage essential functions such as data backups and disaster recovery planning, which guarantee the long-term preservation and availability of records, even after a catastrophic event. The IT department also maintains system performance and ensures integration with other business applications to promote user adoption of official record-keeping practices. As technology changes, they manage records migration, ensuring that older information remains usable and authentic despite changes in software or hardware platforms.
The Universal Responsibility of Every Employee
Despite the existence of dedicated RM and IT staff, the daily success of any records program depends on every employee. Each individual acts as a creator and user of organizational information. Accountability begins at the point of creation, where the employee determines if a document or communication qualifies as an official record of business activity.
Employees are responsible for accurately capturing records into the designated systems, such as the ERMS or shared drives, rather than storing them locally on personal devices or email inboxes. This capture process includes properly classifying or tagging the record with appropriate metadata, which allows the retention schedule and search functions to operate correctly. Incorrect classification can lead to the premature destruction of required records or the indefinite retention of unnecessary, costly information.
Adherence to the retention policies requires employees to use the established systems for collaboration and storage instead of creating shadow IT systems. Compliance involves immediately halting the destruction or alteration of any records when notified of a legal hold by the Records Manager or legal team. Employees must also notify the RM team of any potential records issues, such as unauthorized retention or system vulnerabilities observed during their routine work, fostering a culture of proactive compliance.
Managing Records Held by Third Parties (External Vendors)
Organizations often hold records in the custody of external vendors, particularly due to cloud services and outsourced functions. While the physical or technical control of the information is outside the organization’s walls, the legal and regulatory accountability for that information remains with the contracting business. The responsibility for managing these outsourced records shifts to rigorous contract management and oversight.
The organization must ensure that service agreements explicitly define the vendor’s obligations regarding security, confidentiality, and records disposition. This includes stipulating the right to audit the vendor’s compliance with internal retention policies and external regulations. The contracting company must maintain the ability to retrieve all records in a usable format and authorize their secure destruction at the end of the retention period.