The challenge, of course, is that there really can be no such thing as
"magnetic WORM". Barring some magical process that ensures only one
opportunity to create the magnetic fields that are read by the storage
system's drive -- and cannot be degraded by other magnetic fields -- I
doubt that there can be such a thing with the protection of an optical
disk.

And for us records managers, WORM technology has always been a
two-edged sword. We love the integrity of the data, but we hate the
inability to readily (and properly) implement retention schedules
against anything but the whole of the recording media (the entire disk
or tape). WORM works great for record series where the retention is
based upon the creation date of the record, but for records where a
non-fixed date per record will determine when the clock starts ticking
(mortgages, loans, personnel files, etc.), WORM is almost unusable
unless the organization intends to keep everything "forever". And that
gets to be a huge data migration problem because this technology is in
continual flux.

For folks who worry about Rule 17a, don't forget that the SEC has
modified its position on WORM somewhat. 17a still requires that
information is retained in a non-eraseable and non-rewritable format,
but clearly indicates that it recognizes the need for companies to
apply records retention schedules.
http://www.sec.gov/rules/interp/34-47806.htm

The discussion in the referenced document states:

A broker-dealer would not violate the requirement in paragraph
(f)(2)(ii)(A) of the rule if it used an electronic storage system that
prevents the overwriting, erasing or otherwise altering of a record
during its required retention period through the use of integrated
hardware and software control codes. Rule 17a-4 requires broker-dealers
to retain records for specified lengths of time. Therefore, it follows
that the non-erasable and non-rewriteable aspect of their storage need
not continue beyond that period.


So it follows that WORM technology, as such, is not required, although
the system better be bulletproof when it comes to ensuring that nothing
can go missing prior to the required retention expiration.

Patrick Cunningham, CRM

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