It may be of great importance to have these reports or snapshots of a
particular time retained as records, especially if the database or system is
dynamic and can not recreate a view at a particular point in time with
appropriate integrity and reliability.

I have worked with organizations, both private and governmental, that create
such reports from systems and declare them records for one reason or
another.

Dependent on the purpose the retention may vary as Larry mentions.  In some
cases the snapshots or reports may become part of another report or
products, such as an "Annual Report"

Many records contain information that resides in other records or
information systems.  It all depends on the functions served. 

Tod Chernikoff, CRM

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

I was asked this morning about extract files constituting original records,
e.g. a file extracted from a system (PeopleSoft) based on specified
parameters (date range etc.) that is sent to a third party
vendor such as a payroll or benefit processor.  The thought that was
presented to me was that the extract file is a duplicate record because
the data resides in the system.  My thought is that the extract file
does constitute an original record although this information resides in
our system.  I am basing this on several factors; one of which being if
my company disputes what was processed by the vendor, the extract file
serves as proof of what was submitted to the vendor.  I would like any
thoughts/feedback that the members may have.

_______

My initial reaction is that the content of the extract file represents a
record of what you are asking the third party to act on, so in that respect,
it is a record of that transaction.  Most third party work is done on some
form of a contractual basis, and for that reason, it would be important to
document what you provided them as work product to develop whatever it is
they are subsequently developing for, and delivering to, your organization.

I would see these as transitory records, with a short retention
requirement.  The retention time may be relatively short, say 30-90 days
beyond the time you receive the final product back from them... or the same
period after you have paid them for the service provided. Then again, if the
organization is regulated under SEC rules, and these may be considered "work
papers" that are subsequently used in support of a financial audit, the
retention could be much longer.

I don't think the person who proposed the idea that they were a "duplicate
record" is completely wrong in their thinking.  It's similar to a database,
in that in most cases, the information reflected in a database is simply a
compendium of information that exists elsewhere (source documents) and has
its own required retention, so how do you "schedule" a database?

Where this differs is it supports a transaction and may be required as proof
of what it was you asked someone to do, and because it's a "snapshot taken
in time", you may not be able to recreate it.


Larry

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