<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?>

This is similar to a recent conversation on the list where someone was
asking about keeping data in an unalterable state in case one day it is
called for in litigation (but not because business needs or the law
demanded it).  My opinion there, and again here, is I don't think so.
The requirement is to produce it when requested, and so long as that can
be done (whether it is a painful process or not) is the key.

Now, if you wanted to look at it from a business standpoint, if there
are many of these requests happening, that may create an environment in
which it would be less costly overall to create a process to more easily
produce this data.  The legal requirement hasn't changed, but the
business value in adopting this type of process is much more clearly
visible.

<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?>

Again IMO, you can either retain all versions/formats/copies for the
same length of time (3 yrs or until purged), or you can address the
issue in your retention policy.  For example you might consider
classifying the "producible copy" as a kind of "convenience copy" that
can be purged separately than the data itself.  Again, the law requires
that you be able to produce the data, and so long as you can continue to
produce it (again, whether or not it is a painful process) then you are
covered.

The answers to all of these questions will take some evaluation to
determine the best balance between legal requirement, business need and
available resources (and in your case those resources are tax dollars so
please spend them wisely!).

Have a great Monday everyone!
Julie
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