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From:
"Jones, Virginia" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 17 Nov 2006 15:15:16 -0500
Content-Type:
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I agree with those who have responded that RIM presence in an
organization and in the business/government world is based on how we
sell ourselves - both as a group and individually.  I do not believe
electronic records management is a mysterious "other" way of doing RIM -
it is based on the same RIM concepts we apply to any other record media,
including paper.  I no more need to know how to code an SAP
configuration than I need to have a CDL (Commercial Drivers License) in
order for my records warehousemen to deliver and pick-up boxes of paper
records for storage.  Yes, I need to understand how electronic
applications work, and how RIM concepts will function in the electronic
arena (and there is often a difference), but this is the result of a
partnership with the IT techies and programmers.  

Compliance is a big issue that we should embrace as our own.  One of the
best issues to use is the new Federal Rules of Civil Procedure.  There
is one statement, among many, that empowers RIM in any organization -
"...fend off a spoliation charge by demonstrating that it [the
organization] only deleted potential electronic evidence pursuant to an
ongoing retention/destruction policy that 1) was not instituted in
response to a litigation or other dispute; 2) was consistently applied
and enforced; and 3) contained a valid "litigation hold"
(destruction-suspension) provision that was issued and re-issued in a
timely and effective manner" (summary of Rule 37(f) changes as described
by Patrick E. Premo, Robert D. Brownstone, Esq. and Anthony P. Dykes of
Fenwick & West, LLP).

This truly re-enforces basic, tried and true, RIM policies, and puts the
development, monitoring, and enforcement squarely in our function.
Consistently applied means you do not have one retention rule for paper
copies of records and another rule for structured data query results
that represent the same record "series."  If you destroy paper expense
vouchers after 5 years as retention policy, you should not be keeping
the structured data that becomes or represents those vouchers for longer
periods of time, unless you specifically make that a part of your RIM
policy. In order to efficiently apply retention to electronic records
(including structured data), you need to have an understanding of how
that data functions to become a "record" and how and where the retention
can be applied - this embraces indexing, naming conventions, archiving
processes, purge processes, and so on. Every communication with the "C"
level should reinforce the role RIM plays in compliance with the big
issues (as they apply to your organization) - Federal Rules of Civil
Procedure, Sarbanes-Oxley, HIPAA, FOIA, Privacy Act, etc.  

We should also make sure we include references to national and
international standards and where our organization does or can meet
those requirements.  Play the ISO 9000, 9001 and 14001 cards as often as
possible (where pertinent).  All three of these standards have very
specific record-keeping requirements that can jeopardize certification
if not followed.

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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