<we could just keep the entire film and just mark it as "perm">
So how would you justify not keeping other records of the same record type "permanently"?  A retention schedule establishes minimum retention by record type.  If you keep some of the record type for a specific retention time period and keep other of the same type as permanent, then you have invalidated the retention policy, unless you can justify why those particular records were considered of permanent value.  I don't think the justification of "they were on a roll of microfilm with other permanent record types" would be considered very valid.

<I could fill out my destruction form and sign-off to show all other cases (non-perm) were gone due to retention.>
Again - you are destroying some records of this retention type and not others.  Or is the state saying you should lie and say you destroyed records that are not, in fact, being destroyed (i.e. the microfilm images)?


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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