<interpret that to mean voice, email, snailmail whatever must be
retained.>

Which brings up a thought I encounter in my brain from time to time.  If
a law or regulation requires certain kinds of information or
communication to be retained, then does than equate in some way to
requiring the information or communication to be created in the first
place?  For example, if a broker has lunch with a client and is told
verbally to take a particular action, is the broker then required to put
that conversation in writing or even tape the conversation during the
lunch?  

Using another example, The Virginia Government Data Collection and
Dissemination Practices Act (formerly the Personal Privacy Act) requires
a record of all access (except access by Waterworks personnel) to our
customers' personal information be retained for three years or until
purged (Code of VA 2.2-3803A7) and to provide this information to the
customer upon request (Code of VA 2.2-3806A3c).  Generally, the
requirements to the first part is met by various behind the scenes logs
of every data transaction in every customer account.  However, these
logs are not very readable by a non-IT person (and even for some of the
IT folks) or easily accessible to produce upon request.  So, does the
requirement of the law to keep this information for three years and to
be able to produce it upon request by the customer somehow set a
requirement to create a "producible" version of the data?  And, if so,
does that in turn require the three years retention to be met by the
"producible" version or the data logs themselves or both?  And, if both,
does the term "or until purged" then require us to keep both versions
until the data on the log is purged from the system?

Ginny Jones
(Virginia A. Jones, CRM, FAI)
Records Manager
Information Technology Division
Newport News Dept. of Public Utilities
Newport News, VA
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