Dear Reader, I wish to reflect on some issues happening around us. Recent developments that keep on recurring in some institutions boils down to one fact – BAD RECORD KEEPING. This article was first written in 2017 but recent revelations have made me go back to amend and republish it.
A university lecturer’s pay slip was used recently to wrap roasted plantain being sold on the wayside! I witnessed a few weeks ago, a batch of banking documents on customers’ transactions being used to wrap “bofrot” by the wayside hawker at East Legon! The documents were from a high street global bank dated 2015! These are recent discoveries which made me ask: where do you keep your documents? What is your document retention and archival policy?
Confusion, Headaches
Imagine your company is about to enter legal proceedings over alleged failure to honour some parts of an international trade deal when your lawyers inform you that your copy of said contract differs from that held by the other party. Can you prove your copy is the correct version?
Or imagine your bank being sued by a customer for some unauthorized debits on the account and the court has asked your bank to produce some documents to substantiate claims going back six years. Unfortunately, your bank can only retrieve the relevant transaction records for the past two years. The earlier ones have been deleted in a migration exercise!
Finally, imagine there is a fire in the bank and the customer’s account opening documents, loan files, security documents, have been completely burnt. Are there any backup copies of the documents, systems data, customer information, title deeds or other sensitive information?
These are all real-life examples of what can happen when an organization’s records risk management is deficient. Most people see records as boring at best and an expensive nuisance at worst. Yethe time comes for you to retrieve them, the bitter truth hits you because they are just not there. An organization can lose millions of cedis in any court.
Coming nearer home, do you remember when a few years ago, The Sole Commisioner of the Judgement Debt Commission requested that the Central Bank submits some documents on some transactions performed over a decade ago? I am sure you remember the embarrassment that ensued….No details here…
Dear BANKERS, PLEASE REFLECT ON THE FOLLOWING QUESTIONS:
- Where do you keep your records?
- How seriously do you take the little pieces of stationery that you write on, read, the forms that you complete, the red marks that you make on some documents when you call over a transaction, and the signatures that you append on some documents?
- How well do you keep your records? Is it important to you? It should be if you know what can happen to you when you are “subpoenaed” to appear in court or in front of a Public Committee, to explain your role in a transaction that happened a decade ago.
- Do you think filing is only for Trained Secretaries and Personal Assistants? Do you know that a boss who does not take care of, or is disinterested in record keeping is digging his or her own grave?
- If you have left your office due to retirement, transfer or even resignation, can you remember every transaction that you worked on? OF COURSE NOT.
- Does your bank have an Archival Policy? What are the retention periods for documents?
- Do bank employees appreciate the need for the varying retention periods of various documents in the bank? (cheques, bank drafts, customer information and mandate files, loan files, circulars file, correspondence file, Agreements, Guarantees, vouchers, etc, etc)
- How are “PEP” accounts (Politically Exposed Persons) and transactions kept. Is it in accordance with the Bank of Ghana regulations?
- What is your bank’s e-mail policy? Is it regularly communicated to all staff?
- Are the staff aware that all e-mail conversations can be kept for at least six years, as it is the property of the bank?
- Are staff aware that all their private conversations through email is available for retention even after they have “deleted” them from their computers?
- Have you recommended or approved some loans that you shouldn’t have? Were you coerced by some one (internally or externally)? Was the influence on paper or verbal? Did you put your observations and cautions on the document in a professional manner? Remember that you are the technical person, and the boss is relying on you.
- Mr Operations Manager, have you been leaving your Teller’s vouchers loosely and not under lock and key? Stop tempting some one against fraudulent pull-outs!
- Do you keep both hard and soft copies of data? Do you have a back up of all data stored on your institution?
- Do you have a Disaster Recovery Process? Don’t tell me NO!!
- IT Manager, how do you dispose of the old computers in the bank? Do you innocently dash it to the under-priviledged institutions without replacing the ‘mother board”……….of course the mother board houses all the bank’s best-kept secrets! I am not an expert in this field but I have definitely heard of some embarrassing stories. Remember we owe a duty of confidentiality to our customers.
- Bank employees, whether senior or junior staff, do you keep a clean desk at the end of day, devoid of documents that can be used against you? Do you keep your customers’ letters, signatures, balances out of sight and under lock and key before you go home?
Let me share a true story with you. A bank manager was summoned to SFO, now EOCO during the late nineties when the government instituted a forensic audit of a state bank. Do you know what saved her? She had made some annotations about her concerns of the proposal on the original copies of some loan appraisal papers and of course there were extra copies on float. To cut a long story short, she was absolved from any implied misdeed on that customer’s loan appraisal. Don’t under-estimate the power of the pen and the signature as well as the “insignificant” record keeping.
Record keeping in the Digital Age
The explosion in digital information and accompanying technology experienced over the last two decades has transformed the job of record managers and archivists. The vast volume of digital data that are generated challenge some of the key questions that lie at the heart of records management: what needs to be kept, how long for and how to protect it. The records management landscape is changing. With the rise of digital content, and our increasing reliance on it, changes to the way we manage our records are inevitable, and thus the creation of the newly published ISO 15489-1.
Cassie Findlay, the Project Leader of the working group that developed the standard (ISO/TC 46/SC 11/WG 13), explains the basis for this new standard and the reason why records management is important.
“The creation and management of records has always been important – from ancient times to today. The key reasons for keeping records have not changed: accountability, efficient business, protection of rights and entitlements and the ability to reconstruct the past. Now, the rapidly changing digital and online world has simply introduced additional reasons to create, capture and manage records well: the shift to data-driven business, open government initiatives, shared and collaborative services, greater emphasis on corporate responsibility and more. You only need to look at the frequency of information management, access and accountability issues being reported in the news to see that the job of managing records is more important than ever!”
Finally my dear Readers, even though “to err is human”, at the end of every day, sit up, look around you, check whether there is any incriminating documents around you, check to ensure you have not unconsciously dropped any valuable document in your waste basket. Shut down all your systems and say a word of prayer to God, and go and have a good night’s sleep.
Let us pray that we are not called upon to meet EOCO, FIC, Judgement –Debt Commissioner, Courts, and wonder where the records were kept. POSTERITY WILL JUDGE US!!!
ABOUT THE AUTHOR
Alberta Quarcoopome is a Fellow of the Institute of Bankers, and CEO of ALKAN Business Consult Ltd. She is the Author of Three books: “The 21st Century Bank Teller: A Strategic Partner” and “My Front Desk Experience: A Young Banker’s Story” and “The Modern Branch Manager’s Companion”. She uses her experience and practical case studies, training young bankers in operational risk management, sales, customer service, banking operations and fraud.
CONTACT
Website www.alkanbiz.com
Email:alberta@alkanbiz.com or [email protected]
Tel: +233-0244333051/+233-0244611343
