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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 19 Aug 2008 12:51:50 -0400
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>The point I was making was that as a RIM professional I am responsible for
>more than just records. How we go about finding our data is not material to
>my response.

I don't think the question posed was suggesting that your methods were
material to the response, but it was asking a legitimate question as to
whether it is possible to support the claim.

Unless you have a complete "data map" of all information sources in the
organization at what was once known in the Federal Arena as a "RIDS" level-
what exists by series and volume, where it exists physically, who has
control over it, and what practices are followed regarding its disposition,
then can you as the RIM TRULY control it?  

If responsibility for decisions on what information to retain, whether it is
a record or not, are delegated to all individuals in the organization, then
are you ad the RIM responsible for it, or simply aware that it exists, but
not able to exercise any control over it?   And please understand I don't
think anyone is calling into question your ability to discharge your duties,
but would you be able to sit as a Rule 30(b)(6) witness for your
organization to provide a data map not only of the ESI, but then non-ESI
once it comes to light that other information exists in non-electronic
formats?   

If it were an SEC related hearing, would you be able to cite all of the
sources of information required to be retained to satisfy SEC Rule 17a-4
requirements within the organization?

These are they types of questions that would be asked if you state that you
are responsible for ALL information, record and non-record, within your
organization and I think it was a legitimate question that was asked.  

Many others are facing similar situations and when someone says they are
doing it, it would be wonderful to know how someone is going about it.  

Larry Medina  

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