Kathryn:
They are definitely to be treated the same as any records with PII. If you think they provide some value to the actual licenses then I suggest that they be part of the license file, although I don't know what value they would have after a period of time. You said the licenses have a permanent value, but I would question the need for the individual records of "employees getting approval to serve alcohol at licensed establishments" when the employee is no longer working at the establishment or if the establishment no longer serves alcohol (i.e. gives up or sells the license).
Ginny Jones
(Virginia A. Jones, CRM, FAI)
Records Manager
Information Technology Division
Newport News Dept. of Public Utilities
Newport News, VA
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