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Subject:
From:
"Link, Gary M." <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Thu, 1 Nov 2012 10:58:09 -0400
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<<
While there are variations in the USA from State to State, I would say
there is a consensus, supported by Federal and some States' legislation,
that you normally do NOT have to retain a hard copy of your records,
PROVIDING they have been converted to a generally-acceptable digital
format, using a process which you can document as reliable and accurate
(in the context, "document" may include testifying under oath), and are
stored in a fashion which ensures they are authentic. I'm sure others
(John Montana, are you OK?) can contribute chapter and verse.
>>

Well, we've established that I'm no John Montana, but here is the
citation from FAR Subpart 4.7, Contractor's Records Retention (which
applies ONLY to an organization providing, contractually, goods or
services to the federal government):

"(c) Nothing in this section shall be construed to preclude a contractor
from duplicating or storing original records in electronic form unless
they contain significant information not shown on the record copy.
Original records need not be maintained or produced in an audit if the
contractor or subcontractor provides photographic or electronic images
of the original records and meets the following requirements: 
(1) The contractor or subcontractor has established procedures to ensure
that the imaging process preserves accurate images of the original
records, including signatures and other written or graphic images, and
that the imaging process is reliable and secure so as to maintain the
integrity of the records. 
(2) The contractor or subcontractor maintains an effective indexing
system to permit timely and convenient access to the imaged records. 
(3) The contractor or subcontractor retains the original records for a
minimum of one year after imaging to permit periodic validation of the
imaging systems. 
(d) If the information described in paragraph (a) of this section is
maintained on a computer, contractors shall retain the computer data on
a reliable medium for the time periods prescribed. Contractors may
transfer computer data in machine readable form from one reliable
computer medium to another. Contractors' computer data retention and
transfer procedures shall maintain the integrity, reliability, and
security of the original computer data. Contractors shall also retain an
audit trail describing the data transfer. For the record retention time
periods prescribed, contractors shall not destroy, discard, delete, or
write over such computer data."

Gary Link
Pittsburgh, PA
[log in to unmask]
"Everyone remain calm, please. I'm a records manager."

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