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Subject:
From:
Hugh Smith <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 5 Feb 2016 10:44:20 -0500
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> From: DEBI TADD <[log in to unmask] <mailto:[log in to unmask]>>
> Subject: Audit of Off-site Facility
> 
> I've been looking in the archives for information on a checklist for
> auditing an off-site records storage facility.  I googled it and found a
> checklist that covers the building, but not much about the processes of the
> staff or verifying retrieval standards.
> 
> Has anyone ever done an audit of their off-site storage?  What did you use
> to mark them as either passing or failing?  Did you have a standard
> checklist or did you just ask questions when you got there?



> Did you have a standard checklist or did you just ask questions when you got there?

I was surprised that no one mentioned NFPA 232 “Protection of Records” as this is the Standard for records centers and vaults.

A quick read through of the document will let you generate some questions, and note that this document specifically mandates that the Responsible Party is charged with defining the acceptable standards for records storage, inspecting the facility for deficiencies and mandating corrections or accepting the conditions as acceptable for you as the Responsible Party.

So the first step would be to ask management to acknowledge that “you are the Responsible Party” which delivers to you huge responsibility or to define who in the organization is the Responsible Party.  Here is exactly how NFPA 232 defines this position.
> 3.3.13 Responsible Party. The owner of the records or such organization, office, or individual charged by the owner with the classification, retention scheduling, and disposition of records if so designated in writing by the owner at the time of such designation. 
> 

This is important as “The Authority Having Jurisdiction” was replaced in the “Protection of Records Standard” with this phrase and this gives you an authority equivalent to a Fire Marshal or a Building Code Inspector when you inspect an offsite storage facility as well as your own internal storage facilities.

And as Jesse mentioned “Guideline for Evaluating Offsite Records Storage Facilities” is excellent.

If you seek to be effective in records management and information governance, here are my recommendations:

1) Approach management to determine if you are the Responsible Party for your organization?
	a) If you are move on to #2 and #3
	b) If you are not, then suggest that they designate such a position as this may be valuable in future litigation
2) Use the documents above to perform an inspection of your offsite and onsite storage facilities and create a list of corrections that must be satisfied prior to follow up inspection.  Alert your legal counsel of your findings in a written document.
3) Schedule a meeting with your IT department to request an inspection of their data center and also where they store their back-up media, disk drives, and even a discussion of their Cloud storage. Create a report to share with IT and your supervisor about your findings.

*Here is why NFPA 232 is so important to the records manager; it creates additional responsibility and authority if it is accepted as a guiding document in your organization.
** NFPA 232 now includes “Electronic Records” as a type of record that are governed under the Standard. This opens the door to the Server Room  and the offsite media storage function and potentially the Cloud space, as part of your scope of responsibility.

Hugh Smith
FIRELOCK Fireproof Modular Vaults
[log in to unmask]
(610)  756-4440    Fax (610)  756-4134
WWW.FIRELOCK.COM


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