Nolene,
I publish scanning tips, guidelines and FAQs on the intranet for staff. IT
publishes the instructions for using a particular networked (free) scanner.
My concerns as an RM and my scanning requirements are more focused on
the documenting of procedures than on the scanning activities and
technologies themselves. I'm not a project manager for scanning projects;
business units pay for their own projects and technologies. The technology
they adopt may be a 'controlling' kind of information system (causing people
to say 'it is what it is') whether integrated with current systems or not,
or it could be flexible, which often means low-tech and requiring lots of
human processes and rules to be developed.
I require the same concepts as you mentioned to be in scanning procedures
documentation. But I tell my users they must write it. Only users can keep
track of, and document, their changing processes and technologies. I tell
users to store the procedures document electronically in a communal place,
and I spell out the retention period of the procedures document ('IND keep
forever, same as policies) and how to update the document and why procedures
documentation is so important (litigation, regulatory audits). I tell users
to keep records of QC activity that include scan dates and QC dates.
I suggest to users to do lots of QC audits at the start of the program, i.e.
30%, then reduce as they become comfortable with their procedures and the
quality of the scans. I tell them QC audit rates can go down as little as
2-5%, depending on how high-risk their stuff is. I think a list serv member
said a while back that some government agencies require 100% QC e.g. nuclear
and/or aerospace industry records.
Where I work there are many controls around resources: project processes,
procurement, clerical workflows and clerical productivity statistics. Users
of new processes and technology are interested in doing the new thing, just
not documenting it. And the QC part of the workflow is indeed left out of
their project and process development busywork.
My users instinct was to send paper originals to storage. I explain that
the point of scanning is to throw out the original paper unless it's a vital
record because the scan becomes the 'official' record and the paper becomes
merely a copy. I remind them of the overall copy rule - copies may not be
sent to storage nor kept longer than the retention period says, and, in
fact, copies should be destroyed as soon as no longer needed. Luckily for
me I control destruction of paper records in storage so paper originals that
are vital become an easy-to-control part of the RM DR program. Users control
the destruction of their pdf scans because they're on shared drives. I
remind users that they need to follow the retention schedule and legal
holds. I point out that the retention schedule is media neutral and doesn't
tell people where or in what media to store throughout the lifecycle.
- Some users do QC on the day of scanning or 2-4 weeks after.
- It seems to me that QC should involve destroying the paper original as
the final step (unless it's a vital record).
- Some users seem to want to keep the paper onsite for 6 months,
regardless. To me this requires users keep track of what has been QC'd,
which means creating indexes of records stored on-site in file cabinets, in
boxes, in storage closets.
- What do you think of the above?
Courts and auditors request procedures documents for recordhandling just
like they request retention schedules. Therefore attorneys should care about
the documentation of scanning activities, (if the company gets sued
or regulated a lot or heavily), but they often don't care about it, so RMs
need to.
--
Maureen Cusack
San Francisco, CA
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