mmmm. I am not sure about the article. As much as I hate to say it, I don't think it really does present the facts.
The letter is a general letter related to yearly admin tasks designed to try and minimise the amount of personal data held about people.
The BOE have specific instructions on record keeping related to child abuse investigations.
There are of course plenty of worrisome things about the JW judicial process and record keeping. It's also true to say that there is a risk that some elders may ignore their own instructions and destroy some records they should be keeping but were the WTS to present their side of the story on this particular article it could be fairly easily rebuffed.
The real story here is about how the WTS have not taken the instruction to make sure no records are destroyed from the Inquiry seriously and formally advised the BOEs in the UK on the implications of this. The effort being led by Louise Goode would be a far better thing to see publicised in the press rather the fairly sensationalist nature of this report.
I would suggest it would be far more uncomfortable for WTS representative to have to respond to questions as to why they were not heeding the UK Inquiry instructions, why it was being left to a bunch of exJW activists to inform elders of the instructions and the clear demonstration that, once again, the Witness actions are opposite to their words.