Okay... this is a subject that is near and dear to me in many ways, not only
the scenario mentioned here, but on a MUCH GRANDER SCALE, which I will
address below.
On 11/1/06, Gerry McFatridge <[log in to unmask]> wrote:
>
> I will soon be addressing the issue of having some of our VHS and 16mm
> construction project videos converted to a digital format.
>
> The feeling of some of the project engineers is that that expense should
> be borne by the records management bureau and not come from the
> construction bureau budget.
WHAT a surprise! (not!) So, videos were made as part of a construction
project when the project was ongoing, and someone must have thought hat they
would be accessible in perpetuity in whatever form they were generated? And
these are ENGINEERS?!?!?! Ask one of them to pull out their slide rule and
calculate the estimated cost for you... WHAT? They don't use those any more?
=)
This is an ongoing problem we have and will continue to face when it comes
to the long term management of information, in ANY form or format that is
captured digitally, or is otherwise dependent upon technology that exists at
the time of capture/generation for viewing/access.
Not only will there be an ongoing cost to convert the information onto new
media to avoid degradation, there will be a need to convert and migrate the
information to avoid hardware and software (application) obsolescence for
the required retention period of the information. And it includes the need
to support the labor to convert and migrate, as well as verify and validate
the success of the transfer every time it occurs.
The cost should be borne by the "owning organization", or whoever it is that
generated the information and needs to have continued access to it, or needs
to have it available to support future work or to meet legal, regulatory, or
statutory requirements to retain the information. Sure, it can be thought
of as an institutional cost, IF THE INSTITUTION is made aware at the time
its generated that:
1) information exists that must be retained for X years and it will need to
be migrated/converted every N years,
b) the cost of conversion or migration at each juncture, and how many times
that will happen, and
Thirdly) they need to budget for the media and labor to accomplish this task
There is a trend in the Federal Government to address these potential costs
as a part of budgeting projects as they are planned currently, but I haven't
seen how successfully this is being managed. The main problem I see in the
Federal Arena is at the end of each fiscal year, the budget goes back to
zero... so where is the money maintained to accomplish this, and WHO
physically is going to do it? Unless every Agency has an annual project
planned to "migrate and convert information to avoid degradation and
obsolescence"????
But the same is true in all privately held companies... if information is
stored digitally and it needs to be retained beyond 5-6 years, there are
going to be problems accessing it. You might be able to stretch it to 10
years, but I think that is really wishful thinking.
This is not something we have dealt with before and I am curious how
> other organizations deal with the issue of funding that sort of
> exercise. Do most folks find that that is normally an expense a records
> management bureau deals with? Or, do some organizations fund media
> conversion efforts thru some other bureau?
Gerry, this is undoubtedly the $64M question. And I have a feeling that
there will be different answers from Public and Private sector participants,
and even different answers within industry segments for both of those.
A lot will depend on how heavily regulated you are... as an example, I know
Utilities who operate Interstate Transmission Systems are under either FERC
and/or DOT regulations and must maintain their data for the life of the
system, plus X years. I also know any organizations subject to Sarbanes
Oxley and SEC regulations have requirements for maintaining some information
for current year plus 6, and others have even longer retention
requirements. The IRS requires access to tax filings for certain
Corporations for 25 years.
And if you are under the management of the DOE or NNSA, you must retain ALL
personnel records for 75 years beyond separation from employment, even if
you are a Contractor or Subcontractor. And I'm sure other Feds can weigh in
on some of their requirements as well...
NOW... MY BIG CONCERN HERE????
Federal regulations related to EMR/EHR. The Govt is wildly forcing the
issue of the development of a national database for managing health
information, they're starting with military personnel, pushing on to Federal
employees, and also making it a requirement for everyone in the medical
arena treating patients on Medicare or other Federally funded programs.
http://www.computerworld.com/blogs/node/994
They are addressing concerns related to privacy, but they are COMPLETELY
BLIND to the concerns of persistent access to information and the need/cost
to periodically migrate and convert information to achieve this access over
the life span of patients, which is now approaching 75 years.
http://www.computerworld.com/blogs/node/1185
WHO bears the cost, when a patient changes physicians, or a physician
changes medical groups, or a heath insurance company goes bankrupt, merges,
or otherwise disappears? What about pharmacies, hospitals, clinics, labs,
and other providers? What about when the manufacturers of the equipment
used to generate test data or images ceases to exist, or gets bought out, or
their technology changes so drastically that what existed when the original
data was collected simply isn't available anymore? And the cost here isn't
limited to conversion and media, but there is also the cost of changing
access codes, access privileges, etc.
http://www.computerworld.com/blogs/node/2017
Or what happens when we have a blackout like the one in the Northeast a few
years back, or any other catastrophic incident where power and
communications are lost for hours, days, weeks?
Great Question Gerry... let's see the answers.
Larry
--
Larry Medina
Danville, CA
RIM Professional since 1972
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