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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 12 Apr 2013 10:19:50 -0700
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On Fri, Apr 12, 2013 at 9:39 AM, Dwight WALLIS <[log in to unmask]>wrote:

> Larry posted an article yesterday which epitomized the bad side of cloud
> storage and a "cheap storage with minimal data controls will solve
> everything!" mentality. As I read that, I thought of this article out of
> Government Technology - note the comments of the CIO of the Virginia
> Department of Corrections. He's not necessarily discussing cloud computing,
> but the awareness of the reality of retention requirements, and the
> challenges of applying them in a "big data" world is notable.
>
> http://www.govtech.com/policy-management/Big-Data-Raises-Big-Questions.html
> --
>

The ubiquitous "cloud" is only trumped in today speak by the even MORE
ubiquitous "big data" and that "other" term being held on banners high by
some that feel they have the silver bullet to resolving issues regarding
the management of information.

From the article:

Agencies will need to make hard decisions about which data to keep, and for
how long, to support useful analytics, Davis said. “There’s no reason that
we have data from somebody who may not even be in this world now, from 40
years ago.”

This comment alone shows a total disregard for records management practices
and retention policies.  DOC employees records are likely subject to the
same standards as those for Federal Employees, who may have been exposed to
potentially hazardous materials, substances, or in the case of Corrections
officers, exposed to inmates that may have been carrying infectious
diseases.  Those records are required to be held for 75 years following
separation form employment.

There are probably other series of information generated that are subject
to extended retention periods.  Care should be given not to use a broad
brush when evaluating data and making determinations on dispositioning data
simply based on age or volume criteria.

"Big Data" didn't get that way on its own- it happened because
organizations failed to implement proper policies and practices as they
were collecting the data.

The more logical manner to deal with this is to draw a line in the sand and
set policies based on requirements for retention on a day-forward basis,
then to begin more carefully evaluating the legacy data, deleting that
which truly is a simple copy or duplicate set first, and then retaining
based on consideration of the content, that data which has yet to meet its
required retention.

Does it take time and is it expensive? Sure... but until you know what
these records represent, you can't apply a slash and burn mentality to
their disposal... it isn't 'defensible' if you discard medical, treatment
or exposure records of Corrections workers or prisoners working in or held
in publicly owned facilities.OSHA has very specific regulations regarding
employee exposure records http://www.osha.gov/Publications/pub3110text.html
and NIOSH weighs in on this as well
http://www.law.cornell.edu/cfr/text/29/1910.1020/appendix-B

Some states even have rules regarding this (pg 21)
http://www.cbs.state.or.us/osha/pdf/pubs/2261.pdf


Larry
[log in to unmask]
-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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