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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 20 Jul 2007 11:53:02 -0700
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Great to hear so many thoughts on this topic and the offering itself.

I'm still of the mind that this isn't really the way to go about developing
a schedule for an organization other than considering it as a starting
point.

Here's a few reasons for consideration:

1) MANY of the people who have responded speak about the "wiki aspect", and
what's most interesting is what some cite as a benefit, others of us see as
a major detriment.  ANYONE can change it, and/or change it back, again and
again, with impunity.

If something is there that's correct (for a specific record series, but
applicable to only one State, Country, or Industry) and someone else changes
it because it isn't applicable to them (because they work in a different
State, Country, or Industry) it's still right, right?  But it's not right
for everyone.

2) If there is no citation of the regulation used to support guidance given
(Section, Chapter, Sub-Section, etc. AND the date of the citation), then
there's no way to validate that the proper or current guidance was used.

Here's an example... gas transmission pipelines.  The regulations for
inspection records for pipelines attached to bridges and appurtenances are
DRASTICALLY different if you operate an interstate versus an intrastate
pipeline.  Granted, that has a limited application... but the sources of
guidance come from completely different agencies, and in different states,
the guidance is different as well.

Here's another... loan and property related records.  There are some states
(sorry, Steve) that still require a lender to retain the wet-signed
documents, and others that could care less.  There are also some states that
disallow the storage of the documents in any state other than the one where
the transaction occurred.

In instances such as those above,m what would this on-line resource do?
List a record series description, then have a minimum of 51 citations to
cover each US state and the Federal guidance as well?

3) Because ANYONE can change this, how does anyone control who changed what
when, and what happens t the guidance that was there before?

What happens if an organization elects to use this to develop their
retention schedule, then says "they based their decisions on the GCR on-line
retention schedule guidance" (which is covered by a disclaimer, so GCR
appropriately accepts no liability) and then they go to court and are asked
to produce what they based their schedules on?

Unless you download and maintain a copy of the contents of the entire wiki
at the time you used it to develop your schedule, then you have nothing to
fall back on.  And this is similar to hiring a consultant, or using one of
the other "canned" resources mentioned to develop your schedule, but in
those cases, you HAVE a complete copy of the baseline information available.

I'm not suggesting this is the worst possible thing we've ever seen, but I
am suggesting that serious consideration should be given to any decision to
use someone elses homework, or to buy a term paper off the Internet, or to
get advice on a blind date for setting your retention periods.

Larry

-- 
Larry Medina
Danville, CA
RIM Professional since 1972

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