On Thu, Oct 2, 2008 at 3:39 PM, Larry Medina <[log in to unmask]> wrote:

> On Thu, 2 Oct 2008 12:54:50 -0500, Greene, Ben <[log in to unmask]>
> wrote:
>
> >What is the prevailing attitude towards placement of a corporate
> litigation
> >hold policy?  Is it best to be placed as a small section with a "link"
> >attached inside the corporate records retention policy or do you feel that
> >a litigation hold policy warrants enough attention that it should be
> >separated and on its own?  Thanks in advance.
>
>
> Just to make sure I understand the question, you're speaking about what to
> do with placement of the POLICY itself, guidance as to WHAT a Corporation
> does in the event of the need to place a hold on the destruction of
> information, correct?
>

I agree with LarryM's analysis. As I see it there are 3 pieces that we are
being discussed

1. Placement of the Policy - the policy is analogous to a law it tells the
world what the organization will do. It should be short and sweet. it should
be posted on the organization's internal websites where other policies are
posted.

2. Hold Procedures - this is how the hold will be done think of it like a
regulation. As Mimi mentioned it could be a very detailed Visio diagram or
some other graphical flowchart, it could be a detailed written procedure.
All those involved with a hold ie have a role in implementing a hold should
have a copy of it. It could be posted on the intranet for reference
purposes. The procedures should be regularly reviewed and on occasion
desktop exercises should be done to test the procedures

3. Holds in Effect - This would be a master listing of all current holds.
this too should be posted on the intranet and individuals/departments
affected by a hold should be receiving regular status updates and reminders
about the holds.

Now I said holds because in my mind there is more than just litigation holds
although that is the one type uppermost in our minds, there are also audit
holds and investigation holds.


-- 
Peter Kurilecz CRM CA
[log in to unmask]
Richmond, Va

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