Sharon,

The SEC is a fine resource for finding models that might be incorporated
into your operation.

http://www.sec.gov/about/offices/ocie/riskalert-socialmedia.pdf

http://www.globalrelay.com/uploads/resources/files/GlobalRelay-SEC-Compliance-Guidebook.pdf



Chris Flynn


On Tue, Sep 24, 2013 at 5:09 PM, Sharon Blackstock <[log in to unmask]>wrote:

> Greetings from Colorado! I have been resting from the listserv for a very
> long time and have missed you all, but alas, I have returned and want your
> advice and counsel. I searched the archives to see if this discussion has
> occurred and I'm sure I've blown it because I can't believe it hasn't, so
> here goes ... (my apologies if you've talked this to death; just point me
> to the right words for searching)
>
> We have been having a conversation in our organization about text
> messaging. Many employees have city-issued mobile phones (I do not) and
> many have personal mobile phones which they use to communicate when out in
> the field on city business. I'm working with a team on a variety of policy
> issues related to records. Our IT director maintains that text messages
> cannot be captured or archived because they are hosted by a service
> provider over which the city has no control and that any policy we adopt
> should advise employees not to use texting for city business; use email
> instead.
>
> I'm looking for help from anyone who has addressed this issue from a
> policy standpoint. My mind is stuck on a couple of things, such as the
> definition of a record: "any writing ... in the course of business" (you
> know the drill) and yet I understand and agree with the IT director's
> position. Most text messages are nothing, but if they rose to the level of
> needing to be retained for record purposes, we would be stuck with either
> collecting the phone itself or taking screen shots (iPhones do this, not
> sure about all others). I can only imagine confiscating a phone for some
> type of criminal matter and that's a whole other issue.
>
> Email is preferred because it can be captured (as long as either the
> sender or receiver is using the city email system). His point is that the
> city is protected if we have a policy prohibiting the use of texting for
> business purposes. I'm thinking that just because we declare something not
> a record doesn't necessarily make it so. And ... the IT director and I
> agree that the proposed policy is unenforceable, but he still thinks it's
> the right way to go.
>
> OK, friends, have at it!! Clearly I need help! My profound thanks in
> advance.
>
> Sharon G. Blackstock, CRM
> CENTRAL RECORDS MANAGER
> 303.987.7091
> 480 S. ALLISON PARKWAY
> LAKEWOOD, COLORADO 80226
> WWW.LAKEWOOD.ORG
>
>
>
> List archives at http://lists.ufl.edu/archives/recmgmt-l.html
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>

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