Maintaining Document Retention on Cloud-Based Platforms
Questions often arise regarding how to enforce a records retention schedule after transitioning records to a cloud-based service provider. This is particularly common with HR records and other employee data due to the large industry of outsourced HR services, but it can be applied to other records as well.
The answer to these questions may not always be satisfactory, particularly when the data transfer has already been completed.
Your Data, Their Retention Approach
Typically, when records and data are transferred to another system, there are inherent limitations due to the configuration and capabilities of the chosen system. Unfortunately, it’s often discovered too late that the vendor or the system’s designer didn’t fully consider the concept of record retention schedules.
When this issue is brought to their attention, vendors are often caught off guard. It’s not uncommon for them to have considered the indefinite retention of all data as a unique selling proposition.
If this situation arises, the available options may be limited. If an organisation is large enough (which usually implies substantial expenditure with the vendor), it may have enough influence to encourage the vendor to consider potential solutions.
Additionally, if this problem arises, it’s probable that other organisations using the same vendor are encountering similar challenges. By networking and collectively lobbying, there’s a chance to influence the vendor to respond.
The Path Forward
An immediate concern is what steps the vendor can realistically take. If they’re managing a large SAS system not equipped to handle record disposition on a client-by-client or record-type-by-record-type basis, immediate or simple reconfiguration may not be possible.
The available options may be significantly constrained due to technological limitations. And if a solution is eventually found, its implementation could be a long and complex process.
Consider Before Committing
The essential point is that the records retention schedule should be a consideration before choosing a vendor and migrating data to their system. Inquiries about data purging and disposition, as well as retrieving data if there’s a need to switch vendors (a problem often overlooked) should be part of the request for proposal (RFP) or request for quote (RFQ) process. In this way, the options are clear before any commitment is made, thus helping to avoid potential complications down the line.