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Subject:
From:
Patrick Cunningham <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Thu, 9 Feb 2006 16:46:45 -0800
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In the corporate world, there are very few records that must be
retained in paper form. The term that I use is "retained originals". 

At present, I-9 forms are in a bit of limbo in this area. Legislation
was passed to allow electronic capture of I-9 data, but the rules have
not yet been written by DHS, so many organizations are in a bit of a
holding pattern. There's likely nothing wrong with imaging; but some
attorneys are antsy about tossing the paper.

Beyond that, there are some states that require original promissory
notes to be returned to the borrower when the loan has been paid off.
Companies that maintain fingerprint cards for employees may find it
useful to retain the original cards if the imaging system does not
render the detail on the cards at the selected resolution.

My experience is that many attorneys are still frightened about
retaining image only for certain signed documents, Best Evidence rules
or not. We can preach all we want about the nightmare of locating
certain paper documents or the cost, or the time, but they still want
to see that wet ink on paper. So sometimes you have to compromise with
them and retain a select group of document types in paper form. I try
to push really hard and get them to limit that list to "bet the
business" sorts of things like intellectual property agreements with
employees and significant contracts (without getting "selective").

Once you've narrowed down what is going to be retained in paper form,
the next question is, "How long is the imaged paper retained after
image capture?" My experience has been 30 to 90 days. The 30 days was
in a place where we wanted to be certain that the imaging system had
completed a full month of backup cycles and the need to pull paper for
QA purposes was very low. The 90 days assures plenty of system backup,
as well as use of the images by the end users and generally meets our
need to located imaged paper that requires rescanning or delivery to a
third party.


I've been doing a fair amount of work on costing of imaging. Our
operations area builds out fully loaded costs for prep, scan, deprep
(returning documents to their original filing order or retaining
certain original documents), and indexing (onshore manual, offshore
manual, automated -- via 2D barcodes). Our IS area has developed
costing for image import (when externally captured), fax in, document
class analysis and setup, ongoing storage, and custom programming.

I'm a little concerned about some of the numbers tossed around here.
Yes, you can get a document scanned for US$.02 an image. But as far as
I'm concerned, that's the cost for a service bureau to run the document
through a scanner -- clearly there is a lot more to it than scanning.

I'd also argue with anyone who says that it is cheaper to image a box
of paper than to store it offsite. Mularkey! By the time you do all the
things that you need to do to properly prep, capture and index the
documents, you're looking at a page cost that could be US$.40 to $1.00
per page (yes, in certain instances, with single page documents that
have barcodes for self-indexing and require no prep, you can get it
done, all in, for under US$.10 per page). 

When you embark upon imaging (either electronic or microfilm), you have
to look at why you want to do this and how the images will be used. If
you have a vital records issue, the cost equation pretty much goes out
the door -- you have to provide a good backup. But if you just want to
"save space", toss the files in boxes and send them offsite. 

Electronic imaging's greatest benefit is in enhancing the business
process. You can make processing document "placeless" (i.e. you can
leverage offshore resources). You can process in parallel. You can
resolve calls that require document or file review on the first call.

The decision to image (electronic or microfilm) should not be driven
solely by space concerns or by a need to "do work electronically". You
want imaging to add value or protect vital information. There are times
where you want a record protected and backed up. There are times where
you have to have instant access to a document. There are times where
you want to speed up a business process. These are good reasons for a
business case that leads you to imaging.

Microfilm is a perfectly good medium for retention of archival
documents that have long term value to an organization. But I probably
would never microfilm invoices to reduce file space. I would scan
invoices to facilitate the bill payment process, if scanning means that
the cycle time for a payment is greatly reduced and the payment
obligation can be lessened by faster payment (or if folks are regularly
losing the invoices -- or misplacing them -- and the bills are not
getting paid on time).

Any system of record-keeping requires care and feeding. Storage is
cheap; management is where the expense comes in. You have to maintain
hardware and software and ensure that your images are available for the
entire retention period. And never discount the value of good indexing.
You can't expect to take a 100 page file, image it as a single
miscellaneous document, and expect people to like looking through 100
images to find the page that they need.

Patrick Cunningham, CRM

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