Larry, I believe, in general, it is permissible, under federal and state laws, to maintain all types of records (converting physical to electronic) in an electronic format. However, several federal agencies and state laws impose certain requirements with which companies must comply in so doing. Among them, as I am sure you are aware, the e-record must/should (i)accurately reflect the information set forth in physical record;(ii) remain accessible to all persons who are entitled to
access in a form that is capable of being accurately reproduced for later reference, whether by transmission, printing, etc.  IRS, ESIGN, EEOC, FMLA, and the list goes on, permit it with various caveats.  The main point here is that one must have a very robust and documented process and procedures for the conversion of physical records to e-records and governing the maintenance of the e-records through its lifecycle.  If you have this covered, I believe you can even destroy the physical record within a reasonable amount of time to the business (not retention time), since retention should be applied to the e-records...


-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Larry Medina
Sent: Thursday, November 08, 2012 11:41 AM
To: [log in to unmask]
Subject: Re: [RM] Retaining Hard Copy After Scanning

the problem with paraphrasing language form regulations is sometimes one fails to include some critical aspects of what the clause is applicable to:

(a) Except as stated in 4.703(b), contractors shall make available records, which includes books, documents, accounting procedures and practices, and other data, regardless of type and regardless of whether such items are in written form, in the form of computer data, or in any other form, and other supporting evidence TO SATISFY CONTRACT NEGOTIATION, ADMINISTRATION, AND AUDIT REQUIREMENTS OF THE CONTRACTING AGENCIES AND THE COMPTROLLER GENERAL for (1) 3 years after final payment or, for certain records, (2) the period specified in 4.705 through 4.705-3, whichever of these periods expires first.

So what this language applies to is CONTRACTUAL records... not necessarily other records.

 Larry
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