< that is the key comment. As I see it companies will have to provide
better information on how their records management programs operate and
how they implement holds. Once again it comes down to your business
processes.>

I hate to sound like an old f*rt (even if I am one), but the foundations
of sound records management still apply to electronic records.  You set
a retention and disposition policy and you DOCUMENT that policy and you
do everything possible to make sure the policy is followed consistently
throughout the organization.  According to the link in Peter's original
post, the courts in question were sanctioning firms with "seat of the
pants" retention policy - undocumented and not monitored/controlled
through a designated responsible person (preferably the records manager
8-) ).

Ginny Jones 
(Virginia A. Jones, CRM, FAI) 
Records Manager 
Information Technology Division 
Newport News Dept. of Public Utilities 
Newport News, VA 
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