Dear Luciana,

Your implicit assumption that all exemplars of a record in a possession of an organization should be kept for the same time period is IMHO incorrect. Retention doesn’t work that way! Usually I must preserve at least one exemplar (sometimes called official record copy) as long as required, and the fate of additional exemplars is entirely at organization’s discretion.

If backups (as containers) are deemed records of whatever kind (and if the law or even internal by-laws says so, they will be - irrespective of the academia’s opinion :) ), that doesn’t automatically mean their retention “for as long as the records system that is backed-up is supposed to exist”. Where did you get such a strange idea? :)  The law may require nothing at all, or much less, or much more. Business need for back-ups in normal circumstances is limited. Real practice of back-up retention is quite complex – selected few back-ups may be kept for a long time while most of back-ups are disposed of as soon as new back-ups are created.

Law, by the way, doesn’t explicitly distinguish back-ups from any other digital storage. It doesn’t prohibit using back-up system for records management purposes. Regulators in most cases don’t care where you keep your records, you either produce them on demand or get punished. And the back-ups are not necessarily difficult-to-access magnetic tapes! :)

I accept your point about back-ups as containers; I agree that themselves they are not records of line-of-business activity. However these containers do contain spare exemplars of various records (that’s one of the points of making them). Digitally signed records in back-ups are special because, by law, they are more or less self-sufficient: if the signature can be validated and limitations set in digital certificate are observed, the record will be effective for its purpose – so it won’t be just evidence.

And yes, that’s true that I am looking for relatively simple rules (maybe with a degree of flexibility) suitable for rank-and-file practitioners :)

With my best regards and warmest feelings,
Natasha

-----Original Message-----

Dear Natasha: 

To a farmer may not be important whether a tomato is a fruit or a vegetable, but to a records manager it is very important whether a backup is one record, contains records, or is a security function product whose content may become records when treated as such. If one backup is one record, we need to preserve every backup produced (perhaps several per day) for as long as the records system that is backed-up is supposed to exist. If a backup contains records, those "records" need to be kept in each and every backup made of the same records for as long as the "original" records are scheduled to exist and only for as long (thousands of backups). If the backup is a product of another function (e.g. security), it can be destroyed on a rotational basis every two or three backups. 

Yes, you should not care for backups as a records manager as they are not records. Your IT department must take care of them.

It seems to me that you are looking for rules, like those espoused by standards, rather than for principles. Rules are rigid. Principles are flexible, and in different contexts their application gives different outcomes. So, if your Russian law says that backups are records, they become your business and you have to care for them in the way I explained above. I certainly hope that you do not have such a law.

Luciana

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