"For permanent records I've always advocated a hybrid solution; the
> microfilm becomes the official/vital version and the image a working
> copy."
>
>  I know that there are a couple of schools of thought on this subject but
> I'll ask the question anyway- Do you consider both copies a record?  If
> yes how is it worded in your records definition ?  If no, how are they
> defined ?


Every organization has to make a decision and state in their policy how they
define a "record", or a "record copy".  For the most part, what I've seen is
the physical record, be it paper, microfilm, or another form, is defined as
the official record (record) for the organization and any images or digital
representations that exist elsewhere are copies used for routine reference.

There are some organizations that take this a step further, and establish
formal systems to covert physical formats to digital images and store them
electronically, and then discard all physical source documents.  In these
cases, obviously, what is stored electronically becomes the record.

And as mentioned, there are plenty of hybrid systems, where organizations
with records that have extremely long retention periods (25 years or
longer), scan and/or image for use and reference, and film for vital or
permanent storage, and STILL retain the source documents.

And naturally, there are many organizations that have a majority of their
"records" born digital that never exist in a physical form, and these are
handled in a number of ways.  Whether you are a public or private
organization impacts some of this, the retention period for the information
also figures into the strategy you use.

Federal agencies (and their Contractors) must comply with the requirements
in 36CFR for any information  created, managed, and stored in digital or
electronic forms... and in some instances, although the regulations seem
less than logical, they are extremely straight forward. Others in the
private sector include risk factors in their assessment about how to manage
their information assets, and in some cases costs outweigh other issues when
the final decision is made.

I guess it isn't really as important if the records are permanent but what
> about those with say a 20 year retention period.
>

First, I think the line is really drawn at about 10 years for making more
critical decisions about media and other options for storage.  There is
sufficient data to support that much removable media begins to degrade or
become obsolete within a 10 year window, and some in even a shorter period,
if not stored appropriately.  Use patterns, environment, handling and a
number of other factors come into play.



> My concern comes from
> the thought that if they're not considered a record how do we be sure that
> the people keeping them don't just say - let them throw the official
> record away - I've got my non-record copy that isn't controlled.  This
> defeats the purpose of a retention schedule- in my opinion- and creates
> many compliance problems.


This kind of thinking is common, and unfortunately, it's much more risky
than many business people realize. If a legal issue comes into play and
discovery actions are taken, it doesn't matter what form it's in, or if it's
a record or a copy, if it exists, it must be produced.  The guidance that
should be given in policy is that copies can be made for use, reference, and
convenience, but in NO INSTANCES should copies be retained longer than the
approved retention period for the official record.

It's tough to enforce, and compliance needs to be audited... and that
requires a lot of support from senior management.  In some cases, this
happens after a major lawsuit or a judgment is issued based on a case where
these copies resulted in "problems" for an organization.  Everyone hopes
it's someone else this happens to, but if it is, then maybe it's enough to
get others to think twice about not enforcing their policies.

Larry

-- 
Larry Medina
Danville, CA
RIM Professional since 1972

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