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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 12 Oct 2005 09:26:46 -0700
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> Has anyone done a enterprise-wide electronic records cleanout
> I would like some advice and maybe some pitfalls to avoid in the
> process.

OUCH!

The concept of a "cleanout" in RIM, whether it's physical or digital
format records is a bad thing in most cases.   Destruction of records
is supposed to be an orderly process, based on the values assigned in
the retention schedule.

Every time I hear of someone having a "records cleanout day", I think
of things like what happened in the Andersen Case, or in the
Iran/Contra case. or other such situations where things were
inappropriately discarded.

If you have a retention schedule, a part of properly managing your
records includes proper destruction of materials that have met their
assigned retention period, in the course of normal business.  The idea
of a cleanout is more of a "OOPS! We forgot to get rid of some stuff
when we should have, so let's get rid of it all NOW" knee-jerk
reaction.

Care should be taken to ensure none of these materials are impacted bu
a possible legal hold, or other form of destruction moratorium, that
they have all met their assigned retention periods, that the owning
organizations agrees to the destruction, that they have been evaluated
for any possible historic or enduring value and that you properly
document the destruction.   Additionally, the records should be
evaluated based on their content to ensure the appropriate method of
destruction is used, especially if they include any financial data,
personal health information (PHI), or other privacy related
information.

The one major difference with any digitally stored information (which
would include electronic format records aka "born digital" stuff,
digital images such as scanned or imaged records, voice, video or
other forms of records that don't have a physical form) is that if
they reside on media, you can destroy the media and the records will
TRULY be destroyed.  However, if they reside on optical platters, hard
drives or some other sources and are managed within an EDMS, ERMS,
ECMS or some similar "system", you typically are only eliminating the
pointer to the record, NOT the record itself.  And that's an issue in
the event of a legal action where you are requested to produce
records, because a good computer forensic specialist will be able to
find those "deleted" records and recover them.

The other concern with records managed in digital formats is the
backup tapes... you need to understand the process used to generate
and manage the repository of backup tapes to ensure the records stored
there are also properly disposed of, or the records can also "come to
life" again by being restored to the system.

I'd like to hear what you ultimately decide to do.

Larry
--
Larry Medina
Danville, CA
RIM Professional since 1972

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