Thanks to everyone for your comments on this question.  I'm sorry if I caused
anyone to have a sleepless night, but like Hercule Poirot, its helps to keep
the little grey cells working.  I need to clarify one thing.  I stated that I
am a newbie, but that is to this list and not to records management, which
profession I have been dedicated to for over 20 years.  Its just that times
change, as do regulations and technology.  Things that Tom Wilds taught about
listing diskettes on a "general" records retention schedule back in the 90's
just don't work today in our litigious and electronically challenged
environment.   As my old mentor Russ Gureasko use to say, RM is an art form
and not a science.  That's why no 2 programs are exactly alike and that's why
the dialog and sharing of ideas on this list is so important.  And I'm off
the soapbox ... 

Your comments are great and give me lots of "food for thought"  and I hope to
present them for to the Data Management team on which I sit and represent RM.
As the team finalizes our email retention process, we continue to work on
processes for identifying official records in applications, unstructured data
repositories, etc.  We have clearly documented the differences between
archival and back-up data, and this will be applied to our data stores when
we initiate an ILM solution beginning next year.  But we still need to deal
with the vagaries of old habits and that is why the discussion of the back-up
tapes came about.  Just because no one questioned the process before, doesn't
mean it should be continued when you know better today.  

I agree that if back-up tapes are being used to archive all records, without
regard to specific content and retention periods, a company may have no
recourse but to preserve the tapes for possible production in the event of an
investigation, litigation, or other regulatory matter.  But if the decision
is made to separate our the true DR back-ups from other archival or vital
record preservation requirements, does the company benefit by not having that
DR record on its retention schedule?  Would it be better to direct requests
to the IT department when information on the back-up process is requested,
rather than relying on the records manager to answer these questions?  While
back-up tapes may contain copies of official records, in the true sense of
these words, are the tapes themselves official records?

I do agree that written procedures need to be in place.  As a pharmaceutical
company we have a culture for SOPs (standard operation procedures), but
trying to get individuals to assume the roles and responsibilities is now the
challenge.  

To Hugh Smith's comments:  While I appreciate your analogies (been looking
for some of these), its not that I don't think the electronic copy of a
record isn't valid, I just object to applying formal records series status to
an object without regard to its content.  In our world today its not just
records management personnel who need to manage, control and protect company
information, its every employee and department.  That is what we are all
training on today.  So why should the IT department be any different.  If
they are in control of their back-up process, why shouldn't that it include
the full rotation and destruction (life cycle) of those tapes.  Why pass it
off to a records management group for sending it to an offsite vendor.  Seems
to me the process is better managed by them when they interface directly with
a tape storage vendor.


Carolyn A. Mariani
203-798-4424
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