Records Management deserves our due attention
Records Management is understood as the creation, retention and discarding of records.
Many business records, irrespective of their media (paper, electronic, audio/video, microfilm etc.), that Roche employees create or receive in the course of their business are valuable assets for Roche. Therefore, efficient and correct Records Management is crucial for the protection of Roche’s interests.
Roche’s corporate records management program (“COREMAP”) defines standards to improve the management of records across the global Roche organisation.
Roche distinguishes between convenience records and official records. Official records are listed in the Roche Group records classification. They need to be managed in compliance with internal and external standards and regulations, and be kept for a specified period of time. Convenience records are only of temporary value and will need to be regularly disposed to avoid risks and costs.
Roche employees are required to adhere to the following standards of care whenever they create a record:
- think before writing and decide whether it is necessary to create a record (e.g. an e-mail) at all;
- make sure that the record is in compliance with applicable laws;
- be factual, do not make assumptions and avoid misleading and suggestive wording;
- never create a document for which we would not be prepared to take responsibility;
- be mindful of the recipients of a record – do not share a record with recipients, especially externally, if there is no need for them to have access to it.
Records that reach the end of their life cycle must be discarded in line with the Roche Records Management Directive, local records management policies and retention schedules.
Records that relate to any actual or imminent legal proceeding or regulatory investigation are subject to compulsory retention and disclosure pursuant to applicable laws (so-called “legal hold” or “law hold”); Roche employees are not allowed to destroy these records and must retain them until such hold is lifted.