Get Your Records Retention Schedule Under Control — And Keep It That Way: A Case Study in Global Retention Scheduling
Developing an international retention schedule is a major challenge, but for Zasio it’s what we do every day. During this co-sponsored webinar with ARMA International, our presenters will walk you through a case study on global retention scheduling involving a major pharmaceutical contract organization, PRA Health Sciences.
You’ll see the step-by-step process used, and see how we overcame challenges from global harmonization, expanding coverage to new jurisdictions, optimizing the number of record categories, managing citations and changes, and much more. You’ll learn how to manage your retention schedule and keep it that way!
Audio-described version
Transcript: A Case Study in Global Retention Scheduling
Duration: 1:08:20 · Recorded: 2020-12-10
Speakers: Ann Snyder, Manager of Content Development, ARMA International (host and moderator); Warren Bean, CRM, Senior Sales Engineer, Zasio Enterprises, Inc.; Jennifer Chadband (slide: Jenn Chadband Masingill), CRM, IGP, ECMp, Senior Analyst/Licensed Attorney, Zasio Enterprises, Inc.; Greg Dinklenburg, Associate Director of Records and Information Management, PRA Health Sciences
Lightly edited machine transcript. Slides are summarized where they carry information not spoken aloud.
Ann Snyder: Welcome to ARMA International's webinar, Get Your Records Retention Schedule Under Control and Keep It That Way: A Case Study in Global Retention Scheduling. Is everyone seeing my screen okay? I am. Awesome. Today's webinar is sponsored by the great folks at Zasio Enterprises, Inc. I'm Ann Snyder, Manager of Content Development at ARMA International, and I will be your host and moderator for this webinar.
For those of you who have attained your IGP, the Information Governance Professional certification, today's webinar counts toward one continuing education credit in the information management category. If you have questions during the webinar, feel free to ask in the Q&A box. We're unlikely to get to all questions, but we'll respond to remaining questions received after the webinar has concluded. Before we get started, I have a few housekeeping items I need to take care of. First up is professional membership.
If you haven't checked out your membership benefits lately, we are excited to offer online and virtual opportunities to get connected and resourced through your membership. If you aren't an ARMA International member yet, as you can see, there are a lot of great resources to take advantage of, and it's an affordable way to get resourced as an information professional. Information about ARMA membership and getting started can be found on our website at ARMA.org. Please take a few minutes to participate in ARMA's second annual IG Maturity Index Survey. In March this year, ARMA International published the Information Governance Maturity Index Report 2020.
That's quite a mouthful, presenting the results of the IG Index Maturity Survey that we conducted in the last quarter of 2019. The survey aligns with ARMA's IG implementation model, the IGIM, and is designed to measure IG program maturity overall and across the seven key areas of that model. This year, we're collecting our first year-over-year comparison data. Help us to build a useful benchmarking resource for your organization and the IG profession by completing the online survey and sharing it with your colleagues. Everyone's constantly asking for this kind of benchmarking research, so please help us build it.
Jen, would you add the survey link in the chat box? I encourage everyone to please take this, share this with your colleagues. Don't take it now, though, because we're about to open with some great panelists.
And without further ado, let me introduce them. We are joined today by two subject matter experts from our business partner, Zasio. We have Warren Bean and Jen Chadband Masingill. If you guys can just say a quick shout out, hello. Jen's not on video, I think, so.
Warren Bean: Yes. Hi, Ann. Hi, Greg. And yes, I'm Warren Bean. You can see my title there on the slide deck, but basically, I help out with the sales process here at Zasio and also with the development side.
So I help to manage the development products or projects and kind of guide where we take those projects. And I've been with the company for 20 years now, hard to believe, but it has gone by quickly. And I think I've known Greg for a good chunk of those years as well. So welcome, Greg.
Greg Dinklenburg: Thank you.
Ann Snyder: And so thanks for that introduction to Greg. We're joined by Greg Dinklenburg. He is the Associate Director of Records and Information Management at PRA Health Sciences. Greg is going to share with us some of his experience in tackling one of the harder kinds of retention schedules, a global retention schedule. Greg, could you just tell us a little bit more about PRA Health Sciences and your role there, just to give us some context?
Greg Dinklenburg: Sure. We're a global healthcare intelligence partner and consistently ranked among the top contract research organizations and best employers worldwide. We have developed life-saving and life-improving drugs with our comprehensive clinical development services, including data management, clinical trial management, medical writing, and regulatory and drug development consulting. Just to give you a little bit of scope, we have about 19,000 plus employees with 75 plus global offices in over 80 countries.
Ann Snyder: Great. Thank you so much for that, to give us that context for this discussion.
Speaker: [inaudible] as well.
Ann Snyder: Oh, I'm sorry. I thought you were going to. Yes, Jen, you can say hi, you're not on camera.
Jennifer Chadband: Hi. Yeah, I'm not on camera. Hi, everybody. Jennifer Chadband here. I am a senior analyst and licensed attorney.
I've been with Zasio nearly nine years in the consulting department, and I've had the pleasure of working with Greg and PRA, and we're going to talk a little bit more about that project here. But it's great to be here, and thanks for joining us, everybody.
Ann Snyder: Great, thanks. So let's go to the agenda here. If you are the person at your organization who's tasked with developing and maintaining your organization's records retention schedule, you know that this can seem, feel like a daunting task, but you can successfully tackle this challenge and get your records retention schedule under control and keep it that way. Today we're going to walk through the steps to tackling this challenge. And I think of it, I had a mentor who said when you're tackling this kind of problem, it's like eating an elephant: you take it one bite at a time.
Whatever visual works for you. Again, this is a piece-by-piece process, so we're going to begin first with an overview of the process. If you're working with an outside consultant, there's going to be an intake process, but regardless, you're doing some kind of initial assessment: what's your starting point? Then you'll have to create a roadmap. Most people can't tackle all of their challenges all at once; they have to prioritize and figure out the order of operations they're going to tackle them in.
Then there's the delivery. This is either an internal delivery or a delivery from a consultant of those things that you've mapped out as priorities over time. And then of course you get to maintenance and auditing, that's keeping your retention schedule up to date after all that good work you've done, and then operationalizing. We mean getting that out to your end users and also connecting it up to systems, if you want to take it to that level. Then we're going to move into a deeper dive into some of the common challenges that people face: schedules need to be updated or a refresh is required, there are jurisdictional issues or privacy concerns, and obviously there are some overlaps within those issues. You might be expanding into a new jurisdiction, and that creates some privacy issues.
The schedule's too complicated, and you see a repeat here, maintenance and auditing and operationalizing. We're going to do a deeper dive into them within the common challenges section, and we'll give them just a quick overview as we go through the overview of the process. But we promise that we're going to be doing a little bit of a live demo of the Zasio Versatile Retention tool to show you how this can be done using the services that Zasio offers. So let's start with this, our first, the intake process. It's okay. Warren, so let's start at the beginning here. A prospective client is coming to you and asking for help with their organization's records retention schedule, and I imagine you're seeing a wide range of clients.
Can you tell us a little bit more about what that intake and assessment looks like?
Warren Bean: Sure. So people come to us with all different levels of starting points, not only with experience but just where they're at in that journey of trying to get their records in place. In some cases they're very sophisticated; they know exactly what they need, they just need maybe some specific legal research. In other cases, maybe they're brand new in the role; they don't know where to start. They just know they've got to get compliant, but they don't know what that means. And so we've got to really, first of all, assess where is the client in that process. It is kind of a path, and so there's certain steps you've got to take; some come before others. We have to figure out where they're at in that journey, so to speak.
Ann Snyder: And I guess a sensible place to start is with that retention schedule itself, so starting with a look at that.
Warren Bean: Absolutely.
Ann Snyder: What are some common challenges you see when you begin that process?
Warren Bean: They come in a lot of different forms, but you're right, it is really good to start with the retention schedule. And sometimes we'll ask, can we see a copy of the retention schedule, and there's kind of a little, well, yes, we've got this Word document that was developed in 1982, and yeah, we'll send it to you, but it's not much. We have that level. In other cases it's very well thought out, very well reviewed, but maybe it just hasn't been updated in a long time. Sometimes it's really complicated. Sometimes it's oversimplified. So it is all over the map as far as the different things that we see with regard to the retention schedule.
Ann Snyder: So Greg, can you tell us a little bit more about your intake process, what challenges or what brought you to Zasio in the first place?
Greg Dinklenburg: First of all, I've been using Zasio Versatile Retention, which is their software that we'll see later, for about 15 years, and I decided to bring Zasio's product and services in when I came on board with PRA about four years ago. Not only do I know the software and I worked with it, but it made sense to utilize their consulting group in conjunction with the software, since I was really a one-man team at the time. So my bandwidth was pretty limited, and I had other pressing schedules to be created for GDPR.
Ann Snyder: So what I'm hearing is this is the way you were using this outside consulting service, as a way to augment your staffing limitations.
Greg Dinklenburg: Right, they were an extension of my staff.
Ann Snyder: Excellent. Exactly. So let's move on. There's this initial intake and assessment of your schedule. The next part of it is then, based on that intake and assessment, you have to plan a process of how you're going to tackle it.
And this is also not just making a roadmap overall, because sometimes this is a multi-year, multi-phase project, but also then digging into the specific statements of work for each of those parts of the process. Warren, can you tell us just a little bit more about how you help clients build that roadmap, and particularly how you help them prioritize? So you found all kinds of issues with the retention schedule; how do you help them decide what to start with first and how to phase that in?
Warren Bean: Yeah, I think that it mainly starts with looking at those pain points and the priorities that they have. So if the pain point is that they know they're not compliant with certain laws, then we've got to start there. If the pain point is that they really don't even know what records they have to apply the retention schedules to, then obviously we've got to start with maybe some kind of a data inventory. And so again, we kind of know what the path is and what steps people need to take, and so we can kind of develop the roadmap based on, maybe they've already done a data inventory, so we don't need to do that. Maybe they've already done interviews with stakeholders; we don't need to start there, but they really need to review their current schedule or have some different research. And so we have to customize that depending on the needs, but also the priorities, the budget. All of those issues come into play when you're trying to develop a strategic roadmap to get someone from point A to point B and make sure you fill in all the gaps. And obviously, fires first: if there's a major compliance gap, you want to put that out, rather than just something that's more cosmetic or about delivery and things like that.
Ann Snyder: So Jen, can you just share with us some common challenges that your clients face at this stage?
Jennifer Chadband: Yeah, absolutely. So I think some common challenges that we see is, first of all, just being realistic about your timeline. For instance, when you're getting into the research, if you're a multinational corporation, you might be looking at 50 plus jurisdictions or more, and those jurisdictions have hundreds of laws. So just be really realistic about the time that will be required to kind of go through all of that in relation to your retention schedule. And then I would say one of the biggest things, and this just gets more complex because there are so many moving parts, is the review aspect: lining up your resources, who's going to be reviewing, making sure that you're communicating with them on the front end and that you are able to effectively get time from them as part of that process. So I think those are some of the bigger challenges that we see our clients run into.
Ann Snyder: And I've encountered that as a practitioner: getting those, one, identifying and getting those resources lined up, but also just getting their time, because as streamlined as you can make it, this is still a fairly intensive process and requires sign-off and review. So, Greg, I understand that your organization took a multi-phase, multi-year approach to addressing its retention schedule updates. So at a really high level, can you just give us a sense of what your approach was and why you addressed it in phases like this?
Greg Dinklenburg: Sure. What we had in place was a little antiquated, so I decided to do three stages and committed to five years. So first we established the RIM program framework, which was creating our policy, and all the document life, involving the document life cycle, and then writing the process documents, including training, to support that policy. Next, which is what phase we're in now, is building the records retention schedules. That's the biggest part.
And then hopefully by the end of next year we will be completed with that, and then be able to get an educational training program together and then start auditing in 2022.
Ann Snyder: All right, let's move to the next phase here, delivery. So this is the phase where you do the actual work that you scoped out in the step we just saw. Again, of course, this is going to be an iterative process for multi-year, multi-phase projects, and there are certainly specific deliverables that are going to vary depending on what your pain points are. But at a high level, Warren, would you tell us what this process is like? What does this look like for a typical client?
Warren Bean: Yeah, so it can vary quite a bit as far as the process that you take. But essentially, the delivery involves those steps that have already been mentioned, as far as, in some cases, doing interviews, if you don't have an inventory of your records already. So we'd have to be able to talk to the stakeholders, find out what records they're keeping. And if they already have that in some form, then we can bypass that step in some cases and just go right to the retention schedule. But basically we take the records that they're keeping; from that we know what kind of legal research needs to be done, so we start the legal research depending on jurisdictions, depending on the scope that's needed. Then once we've done that legal research, then we have to apply that to the schedule, or actually, in some cases, build the schedule first, again depending on where they're starting from.
Ann Snyder: Right, so you have the extremes, someone's coming in without one or a minimal schedule. Okay.
Warren Bean: Exactly. So it might be that a draft schedule is created based on the inventory or the interviews that are done. That's shared with the client to make sure that we're on the right track. If that structure looks good, we don't have to adjust it too much, then we dive into the legal research side. Do all of the citation gathering. And then we have to apply or map those citations to the schedule, so that way you map the laws, the requirements, to the schedule itself.
And then that may lead into adjusting those retention periods. So you might find that you're over-retaining or under-retaining, and so you have to adjust, and you always want to bring it up to at least a minimum baseline. Oftentimes we'll divide out the process of making sure that people are keeping things for the minimum time. It might be a separate task to analyze if they're over-retaining, only because that's a more involved process, getting more into what operations they have on the business side that might require things to be kept longer. So that's part of that process. And then harmonization is a big step there as well, whether it's harmonizing different jurisdictions that might have competing requirements or harmonizing issues with privacy versus long-term retention. There's always going to be conflicts that you have to work out and find some compromise with. And we'll dig into that a little bit as we go into some of those specific problems as well. So again, very...
Ann Snyder: So what we're seeing is really client specific, depending on the specific challenges. And I think it's interesting that there's even a phased approach at these lower levels. It's not just a phased approach in terms of big swaths of the updating of your schedule, but even down at the level of the retention periods themselves. Jen, what are some common challenges that your clients are facing at this phase?
Jennifer Chadband: Gosh, I hate to go back to it, but I'm going to have to say kind of the human factor. So scheduling the interviews and making sure that you're getting people's time and getting responses from surveys, I think that's something that we see. I think there's some ways to mitigate that, for sure: making sure that you're really communicating clearly and letting people know what to expect, and kind of having a clear communication campaign with people that you're engaging with on the project. That's always really, really super helpful. And then it kind of goes back to this review aspect, and making sure that you're getting people to truly sit down and look at what you're presenting and think about it and provide any thoughtful feedback, and getting that buy-in.
So I would say those are some of the major challenges that we see during this phase.
Ann Snyder: Greg, can you tell us about your experience with the delivery phase? I know you said you're in your second sort of phase of this. Can you share any challenge that you faced when you were working with this outside partner, and what you did to ease the process? Or even if that went well, did you encounter this sort of internal challenge getting people lined up? Was that something you experienced?
Greg Dinklenburg: Yeah, the internal challenges we kind of faced, it was trying to, like Jen mentioned earlier, trying to keep our stakeholders on task, right, to review these things. Working with Zasio was rather smooth. We came in with a records inventory and provided that to Zasio. They did initial research and applied citation baseline retention periods, and then we went through the review process with our stakeholders, and then bounced the changes back to Zasio. What's really nice and what's really slick is the way the software works, being able to do a change request, and they actually apply all the citations to the records retention schedule I designed within Zasio's software.
Ann Snyder: Right, and we're going to do a deeper dive. We'll actually get a chance to do a little bit of a teaser; Warren is going to walk us through this so you can see what it looks like when we're using a tool to get these citations and updates to you, either to make the changes to your schedule or also that sort of ongoing maintenance and auditing part of it. Of course you can strong-arm it and do it using an Excel spreadsheet. Those techniques work if you're... Yeah, I see Greg's face there. I think we've all done that, and it works, but it's really difficult, and it doesn't give you the kind of visibility. But I don't want to jump the gun on that too much. I want to move to the next item here, which is maintenance and auditing. We're just going to zip through this again, because we're going to do a deep dive in the section. So once you've done all this work, once you've updated your records retention schedule, you want to keep it fresh. And whether you're pushing out, once you're actually pushing out this to your users and things like that, that's the next thing here we're looking at, which is the operationalizing. But you're going to want to do that on some regular basis, and you want to be able to keep at least the citations and updates coming in with some frequency. And you can do this on essentially an evergreen approach there again, where your policy is updated continuously throughout its life.
All right, let's move to the first item here on our deeper dive. A common challenge that's encountered by many organizations is that their retention schedule is outdated. It hasn't been updated in a while. You've already talked about this a little bit, Warren. It needs a refresh. Would you talk a little bit about this process, the kinds of typical challenges that you're encountering with clients?
Warren Bean: Yeah, again, it comes in all different shapes and sizes, but I would say a pretty common scenario is just that it's just been too long since the legal citations have been reviewed. There have been cases where people haven't assigned any kind of legal requirements, and maybe they inherited a schedule that was some time ago, not been vetted against actual legal citations. And so sometimes it's just a matter of saying, hey, can you look at this and tell us if we're up to date or not. You're really just kind of validating what's there. In other cases, it might be that there are new jurisdictions that a person or an organization is working in, whether that's new states within the US or new countries, and so they're not sure what the laws are in those different jurisdictions.
There also can be mergers and acquisitions, where because of a merger they've got new products, they've got new types of records that they didn't have before, maybe new operations. Maybe they're doing production now where they were only doing sales or something, so it's kind of a whole new realm. And so they need to update not only the citations, the research in that case, but also the actual schedules and the actual records.
Ann Snyder: And you're harmonizing in that case too.
Warren Bean: Yeah, the two schedules. Often if you have two organizations that are coming together, whatever the path to that is, they theoretically have been operating with a retention schedule on their own, hopefully, right? And then you need to merge those two into a cohesive whole and also just, again, keep track of how that process went.
Ann Snyder: So can you tell us a little bit more about identifying the gaps in the records retention schedule? You were talking about sort of an industry-specific look as well. Obviously there are common records retention categories that might be missed generally, but we had talked a little bit about industry-specific gaps.
Warren Bean: Sure. Yeah, so oftentimes on the consulting team, Jennifer has a lot of experience with this, they've seen enough retention schedules, they've seen enough research that they know pretty much right away what's missing. They can kind of look at something and say, oh, where are those hazardous materials records, or something along those lines. So you can have gaps with respect to just records that pretty much any standard organization, or maybe a pharmaceutical-specific organization, probably has but maybe they haven't accounted for. It might be gaps because it is an older schedule, so it might be technology gaps: they're now having to cover social media records that they weren't covering before.
Or again, new laws, GDPR, privacy laws, where it can create a gap and you have compelled destruction requirements that weren't being considered before. So those are all definitely concerns. I know with pharmaceutical, and Greg, you can probably speak to this more, but there's a difference between whether you're doing the direct research yourself as an organization or if you are contracting that out. That makes a difference with regard to how long you keep the records. There's an EU law that says you have to keep them for 25 years if you're the sponsor, but it's different if you're not the sponsor. And so those kinds of things can be sometimes misaligned or not caught, depending on what you know about the specific laws that govern that industry.
Ann Snyder: Yeah, and I know we're going to get into this again on the maintenance, but I just want to raise it here as a teaser too, that you can be delivering, so if you're refreshing this schedule, there are different ways that you could be delivering this information to the client. You can either be doing it in a very manual way using spreadsheets and things like that, or, again, we're going to talk about this a little bit, delivering it through a tool, like the Versatile Retention tool or something similar, so that people can track what's going on, and it's a little bit more manageable and auditable as well. So I just want to tease that. We do have a quick question, and I normally table these to the end, but somebody did ask a question in the chat of what do we mean by interviews. And my understanding is just basically this is the sort of excavation of the retention schedule and the types of records with the people at the organization, if that's not fleshed out. Is that correct?
Warren Bean: Yeah, that's a really good question. It's something we just kind of take for granted, but any time that you're going to, especially, build a retention schedule from scratch, you have to talk to the stakeholders and find out what they're actually keeping. And so we say interviews, but it can often be a combination of surveys and interviews, where the surveys might be sent out electronically to say, what records are you keeping, where, how long? There's a number of different questions you can ask, and you try to make that not too long, because then you don't get as much response. Try to hit that sweet spot.
But then, based on those responses you get from the surveys, you typically need to go back and then do follow-up interviews with the stakeholders or with the managers to say, okay, well, I'm not sure exactly what you meant here. Can you fill in the gaps? Can you help me understand what records you're actually keeping? And so the interviews really help to drill down into the specifics of what they're keeping and how long and all of those details.
Ann Snyder: All right, let's move on to jurisdictional issues. We've talked about this; this is one of the reasons that you might need a refresh, and arguably there's a little bit of overlap between the refresh needed, jurisdictional issues and privacy concerns. But this is, I think, a specific enough area. Certainly with organizations I've worked with, we've taken sort of a jurisdictional rollout based on the organization's needs, so say a proposed expansion or planned expansion into another jurisdiction, and getting ourselves compliant for that jurisdiction on an appropriate timeline. So can you just tell us some of the types of jurisdictional challenges that you typically see? Obviously privacy is one of them, but that's the next item on the list here, so separate from privacy specifically.
Warren Bean: Yeah, I think the biggest issue that people run into is when there are wide gaps between requirements of one jurisdiction and another. I mean, ideally, you try to look at, if you're in a dozen jurisdictions, and maybe some have four-year retention, some have five, some have six, you might say, well, it's easy to say, let's just go ahead and keep things for six years, so we just kind of cover all of those different bases. But what if one of those is 20 years or 30 years or 50? You see a lot of those, say, in China or Russia, where those retention periods are quite long and quite different than some of the other standards in the US, the EU, et cetera. And so what do you do? You don't want to keep all of your records for 30 or 50 years. So you have to find some way to either harmonize that or separate out some categories, or you simply create jurisdictional exceptions, where you say our baseline is X, but for these countries, or maybe the specific country, we're going to keep it longer.
And so you create that exception. And it's kind of a judgment call, because it depends on a lot of factors as far as the kind of records, how you destroy them, their confidentiality levels. All of those things can play into that.
Ann Snyder: And can you give us just an idea of the sort of magnitude of the challenge? I think we talked about the number of citations.
Warren Bean: Oh yeah. So in the US right now, in our database, we have over 80,000 citations just for the US alone. And sometimes you've got multiple citations referencing the same laws; that's why it tends to grow like that. And then worldwide we have around 128,000 citations overall. And so, as you can imagine, trying to sort out, if you're in every country, obviously that's a lot of data to sift through and to try and figure out.
Ann Snyder: And it's not just, obviously there's a language challenge. You have to be able to speak the language of that jurisdiction, and you need that sort of level of expertise. So in theory, unless you're geographically tightly defined, limited, limited geographically, and maybe not a heavily regulated industry, you can quickly get into these jurisdictional challenges, and then once it expands outside of the United States, it's a fairly daunting task to keep up with that as a full-time job, and it's a lot of man-hours. Right. So just to talk to Greg about this a little bit: as a global organization, I know that this was part of your refresh, was connected to some jurisdictional issues. Can you tell us more about how jurisdictional issues were part of your challenges and how you worked those into the roadmap?
Greg Dinklenburg: Sure. With about 80 countries, one of the most challenging records retention schedules we did was the human resources records retention schedule, in part due to the fact that we had to do research in 80 different countries, but also data privacy considerations as well. And this schedule actually has the most jurisdictional exceptions. And so what we did was we worked with the regional HR reps to manage language barriers and clarification on citations. Unfortunately, we don't have that sort of network with a lot of our other business units, so that's why we had reached out to Zasio's consulting group, because trying to do it ourselves would be very daunting, and they actually filled in as our subject matter experts.
Ann Snyder: All right, let's move on. You alluded to this: privacy challenges, privacy concerns. This is, again, obviously a hot-button topic for everyone right now. What's interesting, I think, is that historically you used to talk in, we even talked about it here, the minimum retention periods. And now we're getting into something that's cutting in the opposite direction: maximum retention periods, needing to get rid of your retention, excuse me, your records, in a timely fashion. Warren, how has the changing privacy legal and regulatory landscape added to the challenge of keeping your records retention up to date and also compliant?
Warren Bean: Quite a bit, because what I noticed when I was kind of starting off in this process, many years ago, is that it was pretty common for someone to say, well, I know the baseline for this type of record is seven years, and maybe I'm going to keep it 10 years, maybe I'll keep it permanently, just because I can, maybe I've got space. And so to say, oh, are you in compliance, you basically have the mindset that, well, as long as I've got the minimums, I'm okay. So shame on me if I'm not destroying things and saving that cost, that's great, but I'm not going to get in trouble legally. But now, if you have a compelled destruction requirement, especially for things like HR records or customer [inaudible], then that kind of baseline mentality just doesn't work anymore. You have to make sure that you know where the data is so you can identify it if it's requested, and you have to make sure that, if you can only keep it for one year, or worse, if it's only as long as needed, then you have to have those triggers in place, the ability to measure and quantify how long do you actually need it, and be able to identify those records after that period of time to ensure that they are destroyed on schedule and you're not violating that maximum.
Ann Snyder: And we're going to turn to the situation of schedules being too complicated, but I think touching on it here, there's also been a push for the big bucket approach, having a few categories, and it seems like with privacy, again, that's cutting in the opposite direction. It's pushing people to add more granularity out of necessity.
Warren Bean: Yeah, it used to be common to see schedules that were 1,000, 2,000 records long, and then with the big bucket approach that got minimized down to usually 100 or so. Some even went as far as saying, oh, I'm going to have seven or 12. Right. But when privacy started hitting, then they realized, okay, well, that big bucket contains some things that have to be destroyed sooner, and so you have to carve out or at least make exceptions. And that's always the rub: do you make an exception, or do you actually carve that out as a special record category?
Ann Snyder: Greg, can you tell us just a bit about how the recent changes in privacy have impacted your organization, and particularly with respect to keeping your retention schedule compliant?
Greg Dinklenburg: Sure. Well, we basically started by building our records retention schedules with privacy in mind. Back in like 2010, I could see that RIM and the data privacy disciplines were converging, right? That big bucket aspect was going away, or wasn't effective [inaudible]. And so now, with GDPR in full swing, it's imperative that your records group works very closely with your data privacy group.
Actually, ours is within the same functional organization, so that we share the same director. So yeah, we right away went in with the idea that we were going to have certain exceptions based on data privacy law.
Ann Snyder: Great. Let's move on to the schedule being too complicated. We sort of have already hinted at this. This is a situation where you have just way too many categories. And Warren, when we were preparing for this, you told me about how you encountered some real doozies. What's the worst you've seen?
I'm remembering a number, and I just want to make sure I have it right, or if my recollection is that it's worse than it really was.
Warren Bean: Yeah, the number that I told you earlier was 98,000 record types. And to be fair, it was really a much smaller set of the same record types, just duplicated over and over again every time a new property was purchased. They were replicated, and they had a lot of redundancy in the middle. They kind of had a three-tier structure then, and we needed to carve out the entire middle tier because it was just redundant. And so, redundancy, not actually real necessary... Well, I mean, I would suspect there would be some of that if you're up to 98,000. But it wasn't just granularity, it was duplicative categories and just a poor structure. So that one, we were able to gain a lot of simplicity, or a lot of efficiency, with that one by reducing it quite a bit.
Ann Snyder: So talk to us a little bit about... Okay, so not everybody has that kind of disaster. I'm sorry, that was a little judgy, that extreme of a condition. But we have sort of ranges in between, as we've talked about: the seven buckets, which seems too simplistic, but something that's less unwieldy than the 98,000 but still hard to manage. One, what do you think is the sweet spot generally for categories? And then also, can you tell us a little bit about what that process is about, paring that down and reconciling it?
Warren Bean: Yeah, I would say there's no perfect number that you're trying to attain, but it seems like the sweet spot is right around 100, 150. And again, that depends on the industry; it depends on how many jurisdictions you're in, things like that. But from my experience and seeing things, that seems to be kind of a nice middle ground, so to speak. And then, I'm sorry, you were saying another question there, and I've already forgotten the...
Ann Snyder: Oh, it's just, the other question is sort of, okay, so I came to you with, I'm somewhere out of that spot, I'm in a couple hundred more. What's that process look like? How do you help people pull those together? So I've come to you with this slightly unwieldy, hard-to-manage schedule. How do you help me eat that elephant?
Warren Bean: Yeah, the first step in that is obviously looking for redundancies. If you've got the same types of records covered by multiple categories, but they're all the same retention period, can you pull that together and say, really, you're going to destroy these at the same time, so why don't we pull those together into the same record type and simply put the detail, or the granularity, into the examples? So oftentimes, you have a lot of different record categories because each one is a different type of document or different type of record, but you can lump that into one group and then put the names of those different record types into a field that can be searchable, so that if someone's searching for their invoices, vouchers, work orders, whatever they might be, they can still find them. They just find it by searching the keywords, and they find it as part of that. So you're pulling those, like, common types of documents together into that one category, instead of having an individual line for each one.
And also it can be done by normalizing the retention periods themselves. So if you've got a lot of different variations, 10 years, seven years, three years, 20 years, a lot of times you can normalize those as well, so that you have maybe three, seven, or maybe three, 10 and permanent, or some scheme like that, where it's only always going to be one of those three or four retention periods. That can help to simplify the schedule also.
Ann Snyder: And can you tell us about the term harmonization? I think we may have said that a couple times here.
Warren Bean: Yeah, so we talked about global harmonization, and I mentioned that you can have different jurisdictions with different requirements, and it's a matter of either coming up with something that covers all of those or dealing with exceptions. But in terms of complex schedules, I would say one of the really common things that we see also is that if you have your schedule in, well, usually not a database but a spreadsheet, you might have replicated the retention schedule in its entirety for every jurisdiction. So if you take an example like Greg, you're in 75, 80 countries, and so you're really talking about 75 or 80 schedules. And so you can greatly simplify the complexity if you say, okay, we're going to have our [inaudible] 150 record types, and we're going to come up with a baseline wherever possible and then just call out exceptions where needed. You can reduce your schedule tremendously just by reducing that per-country complexity.
Ann Snyder: Just to build on this a little bit, I think it's important to emphasize how operational requirements can actually be the driver for retention periods. I think it's a common misconception, at least I've encountered this with stakeholders at organizations: they think it's all laws and regulations that are setting the specific retention period. Can you talk a little bit about that?
Warren Bean: Yeah, I was actually surprised to learn that as well, as I began working more with our consulting team. It varies, again, by industry. But if you take a typical retention schedule, maybe 40 to 60% of that is governed by specific laws, and the rest of it is operational requirements or just typical audit requirements, things like that, but not specifically regulated by some jurisdictional law.
Ann Snyder: And I think building a little bit on that is knowing what's driving it, that only part of this is legal and regulatory. You can establish the longest retention periods that are required and use this as kind of a recommendation for not keeping beyond that. So very often it's operational, the business is pushing to keep something longer. If you can go to them saying there's really no actual legal reason to do this, do you really need to keep it that long? It's a pretty good tool to make the argument. Do you agree with that?
Warren Bean: I do. And sometimes you see the number seven come up, like seven years is a magic number for some reason, and people just think that's the rule of thumb, which works in a lot of cases but can mean that you're over-retaining things. And I think it also emphasizes the call-out for the interviews, because those interviews are also where we learn about those operational requirements. What do you have for audits? What do you have for document reviews? When do your policies come up for review and updates? All of those things can affect those operational requirements.
Ann Snyder: And those business requirements and operational requirements are certainly important, whether or not there's a legal and regulatory one. I don't want to suggest otherwise, but I think sometimes people are arguing that I need this forever and kind of pushing a little bit too far beyond the actual requirement, from either a legal and regulatory perspective or even a legitimate business perspective. So I think it's good to say we don't need to sometimes. And Greg, I understand that harmonization was an issue that you addressed in your roadmap. Can you tell us a little bit more about that?
Greg Dinklenburg: Sure. When we're completed, we will have roughly 21 total records retention schedules, based on either a functional or a process level. Each might contain an average of seven to eight different category types, so we're right in that sweet spot, 170 or so. Some schedules which deal with our core business, which is heavily regulated, might have upwards of 12 categories, but others might only have four or five, based on that process. We have used baseline retention where we can, outside of the privacy aspects. We use the baseline retention with country jurisdictional exceptions, like Warren had alluded to.
We've eliminated redundancy by creating a separate records retention schedule, which is just general records. So there's like about three or four record types that are on everyone's records retention schedule: administrative, project management, what have you. So we can cut a lot of redundancy out by just pointing people there.
Ann Snyder: All right, now, as promised, we're actually going to go back to maintenance and auditing. So we're returning to this topic: once you've invested all this time, the resources and money to update and fix your retention schedule, you're going to want to maintain it. And the other part of this, the second half of this, is auditing: track the changes. And again, there are different ways that you can do this. I think everyone on this call, on this panel, has dealt with the situation of doing this in a very manual way, through an Excel spreadsheet, tracking changes and updates to it, and also the review process. But I'm going to hand this over in a second to Warren, and he's going to show us what this looks like in terms of the tool and how you can have this delivered to you in a more streamlined fashion.
I just want us to show you what this can look like in real time, if you're managing, again, the number of citations that we just talked about. Doing that in a process via a spreadsheet is incredibly complicated. We're also then going to just move right into sort of operationalizing as well, as we look into the Versatile Retention tool, because this is a way to push out the documents to your end users. At the end of the day, again, you can push it out as an Excel spreadsheet or a PDF of that. That's also a way people have done it, but there are tools that allow you to present this in software that's searchable and has some other functionalities, and we'll look at that.
So Jen, can we hand it over to Warren so we can have a quick walkthrough of Versatile Retention?
Warren Bean: And I'm already stealing the screen from you, so no.
Ann Snyder: By the way, sorry, I do see a bunch of hands raised. We are going to have some time to get to questions, so please bear with us; we're not ignoring you.
Warren Bean: Yes. And one quick note about just one other point in that last discussion, and that is simplifying can also be done by doing a really good job of analyzing the event triggers. That sort of ties into operationalizing as well, but it's something that we should really think about, as far as the more event-based retention you have, the more complicated your schedule is and the more difficult it is to actually put it into place. So, something we can touch on more. So I'm going to just show you real quickly here, just within a few minutes, the tool that we're talking about, just so you can kind of get a visual on it. I'm not trying to do a demo here, but we're talking about this tool called Versatile Retention.
We have it here as a desktop application or as a SaaS tool, that is, software as a service. I'm going to go ahead and use the software-as-a-service version just because it's just kind of cool. So I'm just going to my browser, launching it here. We can do single sign-on and so forth, but I'm going to go ahead and log in manually. And in terms of keeping your retention schedule evergreen, one of the things I always like to point out is this little pop-up here, because it's really kind of a minor thing as far as the software goes, but it's really important for keeping you up to date. And that is, we're constantly publishing new citations, the legal research team is, and so this little pop-up is just reminding me that I've got a bunch of batches that I haven't reviewed and processed into my database yet.
And I'm not going to go into great detail here, but you can see that we've got a number of jurisdictions that are being published multiple times per month. A lot of new citations, a lot of updated citations, and we also even give you details about things like, oh, we've got some of these updated citations that actually affect some schedules that those are linked to. So that would be one where I'd probably want to go into the batch details, look at them in particular, see if I've got discrepancies where maybe the retention period has changed and I need to update that schedule. So this is a really important piece of the program in terms of just keeping things up to date, and really being able to manage the ongoing maintenance of the schedule. So once you have that baseline established, you want to be able to keep it evergreen, so you're not going back to the problem that you started off with.
So the other thing I think that's important here is that all of these things that we've been talking about, as far as the building of the schedule, the legal research, the maintaining, publishing, managing changes, that's really sort of represented here by these four main icons. So obviously we talked about doing the legal research. We talked about doing interviews; this is a place to track that information if you need it. And then obviously a place to maintain the schedule and keep it yourself. And then when you review the schedule with your stakeholders, these change requests are where you can do that. In fact, one of the really cool things about this piece here is that it's not only the ability for, say, Greg to propose changes to his internal team and circulate that for review and comments and approval, but it's also a chance for him to actually push the schedule to Jen here at our office, have her apply research and send it back, so he can then review and approve that with the internal teams. It's actually a conduit between the software and the legal research team here.
Ann Snyder: So now, not every citation... So can you tell us a little bit about the frequency with which these citation updates are coming, and then also just, can you clarify that not every citation is necessarily going to lead to a change request or change in the retention period?
Warren Bean: Yeah, absolutely. In fact, in that screen we saw a moment ago about the citation updates, you can see, just sorting here by date published, that we're publishing these multiple times per month, depending on the size of batches and what updates we're doing. So these are coming on a regular basis. People are getting a feed, not only through this but also through email, so they'll be able to see those. And as I mentioned, you can dive into these batches and see which ones actually apply to the schedule, if they apply to your industry, to your business activities, all those kinds of things, to help you know exactly what that's about.
Ann Snyder: Now, there's actually a question in the chat here. Someone's asking, as a matter of best practices, how often should your schedule be reviewed? And I just want to say that what we're seeing here is that these things are being reviewed in real time, right? So this is an evergreening approach that is available. It doesn't mean that you have to push out an updated retention schedule every two seconds or something like that, but you might do that yearly. But do you have any sense of what is the, is there, again, I think it depends on your industry, and it depends on what kinds of changes you might want to push through pretty quickly, but is there a best practice out there, or a common practice at least, that you're seeing out there in the industry?
Warren Bean: It's interesting, because I would say the most common is an annual or bi-annual refresh, but we do have some customers who need a guarantee that they can get updates every 30 days when laws come out. And so getting those really timely updates is extremely important in those cases where it is a heavily regulated industry.
Ann Snyder: And Greg, just to bring you back into this conversation, I understand that you use Versatile Retention as part of your program, right?
Greg Dinklenburg: Yes, yes. And it's very efficient. With the weekly citation updates, you can set them for however long you want them, monthly, weekly; we get them weekly. And they get pushed to our database, and then we're able to go through them, like Warren's shown. We then can basically update our schedules on the fly. So although we use the desktop, the on-prem version, with our process, what we do is we consider Versatile Retention as a living, fluid entity.
So once we have a records retention schedule that is approved by our stakeholders, which includes legal and data privacy and others, we use the reporting output to convert that to a PDF, which I then digitally sign, and we upload that into our quality management system. That is our record, that is our records retention schedule. So then we have a two-year refresh on that, unless of course there's something that needs to be done right away. So with these updates coming in, we can then go in, and if there is a change in retention period, we can update the schedule and record the changes in the change request module. And then that way, when we go to look at this two years later, it's done. We don't have to do any further research, unless of course we've added countries too.
Ann Snyder: And to get to that, thank you for that. To get to the sort of second half of it, I just want to make sure we have some additional time, there are a lot of questions, to get to the second half of this, maintenance and auditing. So can you tell us a little bit more about that, Warren? One of the things that's important is understanding, not just keeping your schedule fresh and current, but also making sure that you understand what changes were made when, because there are going to be point-in-time questions that can be asked, for example in e-discovery, and for other reasons too.
Warren Bean: Yeah, excellent question. So one of the things that the software does really well is it keeps track of all those changes. So if I just take one schedule as an example, these are all of the changes that I've done over the course of time for this one item, and so each one of those I can open up and see the specific details of, and see exactly what happened at each point, highlighting the differences, whether there were differences in citations, differences in retention periods. And so each one of these is basically a snapshot of what that record looked like at any given time. Or I might go further and say, well, I want to know what was changed by a person or for a department over time, and so I can just basically go and choose someone here and do a search on all the changes, maybe for a specific time period, maybe for a specific department, and get everything that's been done during that time frame. So if I need a report of that change management process, or that audit control, it's really easy to reproduce. In fact, one of the things that's sort of a side benefit of keeping that snapshot is that when it comes to producing the schedule, you've got the current version, but I can also go back and say, well, what did my schedule look like as of some point in the past? Just pick a date and recreate that point in time. Exactly. And so it basically picks up all of the retention periods as of that time, the statuses, descriptions and so forth, and you can easily just report that as well, as Greg was mentioning that he does whenever he's publishing the schedule officially.
And again, that is certainly something that can theoretically be managed through a manual process, but it's a lot more difficult.
Ann Snyder: Yeah, you can, especially multiple spreadsheets. And yeah. So let's just, I want to keep this moving. The next piece is operationalizing your retention schedule. So you've refreshed it, you've filled the gaps, et cetera.
Your schedule is refreshed, and now you have to get it out to your end users. And the other sort of next part of that is not just getting it out to your end users, but getting it out to the systems within your organization. Everyone is talking about digital transformation, which requires the sort of connectivity in our technology ecosystem, but this is one way that you're going to talk in a couple seconds about, how we do that with a retention schedule.
Warren Bean: Yeah, so like you said, it can be initially just distributing or publishing it to your users. So it could be like Greg was talking about, where he generates a report of anything that's current, puts that into a PDF, maybe posts it on a shared drive or SharePoint, something like that. Or you can have a live, sort of interactive system. So we have an option here where that same schedule can be accessed by an end user just in read-only mode. You can have a landing page where you have instructions about your particular records program, and maybe allow them to search and say, oh, where are all of our accounting records?
What does that look like? And they can quickly find everything related to accounting, get the details, retention periods.
And as they click on any of those, they can see more specifics, including things like those citations that have been linked to the record category, or the country exceptions. So they know that, okay, in this case, Australia has a 10-year retention instead of the baseline seven years, for example.
Ann Snyder: One of the things I like about this is there's a single and clear... Well, one, it's searchable in a different way. I mean, you can do a Control-F in a static document, of course, but it's searchable in a different way; the user interface is a little bit more accessible than just a static document. But I like the idea also of a single point of truth. I think, Greg, you're handling it, I think, by having a quality system where people know where the single source of truth is and go there and get it. But a problem that I've encountered with people is the download of the retention schedule: someone's relying on something that's, yes, it is an accurate copy of a retention schedule from five years ago or something like that, because they've downloaded it, and they're not using the current one. So I'm sure you've followed the schedule, yes, [inaudible] the schedule's out of date.
Can you talk for two seconds? And we may run over time; if people can stay on, we're going to do some Q&A quickly. There's some great questions. So if people can hang on, that would be great. So can you quickly, for just two seconds, talk to us about this sort of next arm of it, a little bit about how you can take it to the next level and connect to your systems? So connect these updates to your systems where you're actually executing on your records and retaining your records.
Warren Bean: Sure, and that is a huge challenge, because obviously you've got a retention schedule like I'm showing here, and you have to be able to take those rules and those requirements and put those into the various platforms where you're actually storing records. And so some systems have that capability built in. In some cases they don't. But if you've got a handful of systems, it's probably pretty easy to just go ahead and manually update those as they come through, especially if they're just annual. But if you've got 200, 300, or in some cases 1,000 systems that you've got to manually update, it's just totally impossible. So you'll never be compliant unless you actually get the schedule into the systems that have the records. And that can be done through APIs, through integrations; there's a number of different tactics. I've got a blog post I wrote about this a couple months ago.
So there's a lot of different strategies you can take, but that really is kind of the final step to really becoming not only compliant, but getting it out there and actually automating the process of applying it to those repositories.
Ann Snyder: And again, that's one of those things. It's not uncommon for your technology ecosystem to involve hundreds of different systems where documents are being retained, and if you're doing a manual update on that, even if it's yearly, that's quite a bear. I'm going to take back the screen, if I may.
Warren Bean: All right. I will stop sharing. Thank you.
Ann Snyder: One second. And we're just going to open this up now to questions. And again, if people can stay on a little bit longer, that would be great. Is everyone seeing a screen that says Questions on it? I can't always see this [inaudible].
Excellent. All right, so let's look at some of these questions we have. [audience question] The first one here is: what tips do you have for companies that have combined retention schedules? So they're merging or doing that sort of merger-acquisition kind of scenario. Do you have any tips for people in that scenario?
Warren Bean: Yeah, I would say that when we've dealt with that, what often happens is that you can maintain both retention schedules, like in our software at least, have them both running, and then you basically, over time, can merge those together. So kind of that same process of consolidation that we talked about before. But basically you have both schedules in play; maybe the different groups that you're bringing together both use the ones that they're comfortable with until you get that harmonization process going, and then you come up with essentially either a third one, or you merge maybe the smaller or the less up-to-date one into the more current one, kind of depending on where they both stand.
Ann Snyder: [audience question] I think this next one is a quick yes/no, but: are archives part of the stakeholders in the interview and research process? I would hope that if you have an archives group, they are part of the stakeholders who are involved in this. Do you typically see them included, Warren?
Warren Bean: Yes. So obviously archives are going to be kept permanently, so it's not necessarily coming up with a retention schedule, but it is important in terms of considering when something is considered an archive, where it goes, who handles it. It gets managed like all the other records in many cases, but just with a permanent retention.
Ann Snyder: [audience question] Here's an interesting one. So how do you know if your retention schedule is too complicated or oversimplified?
Warren Bean: Can anyone figure out how to use it? Are they coming to you with questions?
Ann Snyder: Right. I think that's obviously, if it's unmanageable, if it's impossible to find stuff, you're getting an excessive amount of questions, those kinds of things. If you, as the person responsible for it, can't manage it effectively, I think that's a good sign too. Greg, do you have any thoughts on that?
Greg Dinklenburg: Yeah, I agree with both of you on that one. Yeah, and I think the other side of it, the big bucketing approach, I think one of the things would be, you're noncompliant, that you can't respond to some of the privacy concerns, for example.
Ann Snyder: Absolutely. Let me see what's the next one here. [audience question] How many countries? A specific question for Zasio: how many countries do you cover, what jurisdictions are you in?
Warren Bean: We have, I believe it's around 130 jurisdictions, and keep in mind that some of those break out into multiple. So like Australia, Canada and a few others, we break them out into their states or provinces. But overall, right around 130 jurisdictions was the last count I saw.
Ann Snyder: [audience question] Quick question here: do the citations, the legal research, include GDPR, CCPA, and ISO?
Warren Bean: All the above. Well, if they pertain to retention or to handling. So we have a whole section of our research that deals with privacy, signature requirements, cross-border requirements, what format the records have to be in, and so all that's considered part of the handling requirements. So that falls into GDPR, CCPA. Some of that would be ISO. I'd have to think about ones that would be specifically in that category.
Ann Snyder: So here's a pretty specific one, and then I'm going to wrap this, just because we're out of time, and maybe we'll do one or two more. [audience question] This is a question from an anonymous attendee: "We have historical paper records that relate to a function now handled by another company. They include private information. It's been suggested that we send them to the new company, as it relates to their organization's inception and history. Is it acceptable to send them to the new company to vet and destroy, even though they predate them?" This is pretty specific. I don't know if anyone wants to weigh in on that.
Speaker: You're right, that is pretty specific. I think a number of things come to mind, at least off the top of my head, which is: who is the true custodian of the records? What kind of information are we talking about? How secure are they? Probably not an easy question to answer right off, but maybe something we can follow up with.
Speaker: Yeah, and I certainly think it presents concerns for you. This is a common scenario, I think, that we encounter in any of these kinds of organizational transformations. It's, what are you retaining? And so obviously something here has been kept that maybe should have gone to the other organization, and now it's, I mean, again, this is just a suggestion, is to look to those documents that involve the reordering of your company.
Speaker: Yeah, we've seen some pretty ugly scenarios where there are splits, and you have to go box by box, folder by folder, and separate documents. It can be very, very time consuming.
Ann Snyder: So here's one. Well, I'll just close with one more here. [audience question] Is it possible to manage a global retention schedule on your own? And I have some specific thoughts on that, but I'm curious, Greg, as a practitioner who's doing this, would it be possible for you to manage that schedule on your own?
Greg Dinklenburg: No, it's really difficult. And like I said, HR we were able to do because we had representatives in each region that we're in, but there's other aspects of the business that we don't. And although we may, like for human resources, we could have people in the country but not an office, that country then has to be researched for jurisdictional purposes. So no, I truly believe that it takes a village to manage something like this.
Ann Snyder: And I know, Warren, you probably don't want to do too much of a pitch, but I think that, again, from a practitioner's perspective, I can say that I would think it's nearly impossible, again, if it's an unusual circumstance, if you're geographically defined and not an especially regulated industry. But once you get outside of, once you start even expanding within the United States, or you get outside of that, you're in multi-jurisdictions. It's not just the challenge of a language barrier, it's also the challenge of the expertise within that jurisdiction. So it's specialized skills on top of the language skills, and I think rapidly you get out of a manageable scenario, for example, if you're just in the EU. Do you agree with that generally?
Warren Bean: Yeah, I do. And I think it's not only an issue of expertise and the language issues and so forth, but just, if it were your only job, just to manage the retention schedule, that's all you had to do, eight hours a day, it might be feasible to at least keep up with it. But most people are doing multiple jobs; they've got multiple responsibilities. And so usually people just don't have that bandwidth.
Ann Snyder: All right, I want to wrap this up. We have a lot of unanswered questions, so we're going to try to follow up, either in a written format or maybe an alternative, we can do a live Q&A. Let's see if that's a possibility. I just want to thank all of our panelists today in today's webinar, Get Your Records Retention Schedule Under Control and Keep It That Way. I'd like to thank everyone here for their continuing service to this community and for sharing their knowledge with us.
Our next webinar will be announced very soon, so keep your eye on your inbox. And before we close, I'd like to remind you about becoming a professional member of ARMA International. Take some time to invest in yourself. Also, again, remember ARMA has an array of resources available: white papers, training, articles, our magazine and much more. And I also want to remind you to please, please, please be sure to take the survey. We need your input to create a really awesome resource. And on behalf of our speakers, the wonderful folks at Zasio, who give their time and money to sponsoring programs like the webinar today, and all of us at ARMA International, I want to thank you for joining us today and wish you the best in all your information endeavors. Have a great holiday season, stay safe and stay well.
Speaker: [multiple speakers] Thank you, Ann. Thanks, Greg. You as well. Thank you, Warren. Bye-bye.
We had so many great questions and comments after the webinar, we decided to add a bonus session dedicated to answering your questions and comments!