I have been up to my eyeballs working with a consultant conducting  
data gathering interviews for our enterprise-wide retention schedule  
-- a totally from scratch endeavor. I have found that many of our  
functions/offices are scanning paper documents, and in some cases  
destroying the paper -- not a bad thing in and of itself. However,  
when asked if they have written scanning procedures and QC, they, to a  
one, have said that no such thing exists. When asked what type of QC  
they do, I just get a blank stare.

We have never had the authenticity of any scanned documents called  
into question in court, so our attorneys aren't too alarmed by the  
lack of procedures. However, in my mind, that is a huge red-flag, so I  
am planning on issuing a scanning policy. It will be either a stand- 
alone policy or included in the overall records management policy. The  
consultant suggested that I not create an actual procedure, but  
instead just say scanning procedures must be documented and publish  
minimum scanning standards (DPI, etc). I am concerned that, since  
virtually all users seemed totally clueless about the need for such a  
procedure, that they wouldn't know where to begin. So I am  
contemplating a policy that states that, in order to be able to  
destroy the originals after scanning, a documented procedure must be  
in place which covers document preparation steps, scanning steps, QC  
steps and percentage of documents selected for QC and how that  
selection is made (i.e. every 20th document, first and last 20  
documents, or whatever). Should their procedures state how long they  
keep the originals after scanning -- I'd expect to see around 90 days  
to 6 months. I'm thinking that each unit may have different internal  
issues that may affect how long is prudent to keep originals before  
destroying. Or should that be a blanket timeframe in the retention  
schedule?

Of course, once that is done, I'll have to work with compliance to add  
that to some audit cycle, but I'm thinking it should be a pretty  
simple watch them scan a batch and see if what they are doing matches  
what they say they are doing. I am thinking the standards themselves  
will be separate since technology will change faster than the need to  
change general procedures.

I often have to check myself to make sure I don't get too detailed. If  
the attorneys aren't concerned, should I be? Do I not give people  
enough credit to be able to figure out how to document their procedure  
on their own? Or, on the other hand, do I not go far enough?

So, is my porridge too hot, too cold, or juuuust right?


Nolene Sherman
[log in to unmask]
Orange County, CA

Tracking where records are kept is what Tiggers and Records Managers  
do best!

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