>There is thread on the list which touches on this topic, dated September
>6, 2008 (search the archives and use "word and pdf" as search
>parameters).

I get a real warm, fuzzy feeling when people take the time to cite chapter
and verse for locating content on topics discussed previously in the Archives =)

>I cannot point you in the direction of any regulatory requirements, but
>I can tell you the conclusion we came up with here.   When a document
>exists in both paper and digital format, we consider the paper the
>record copy, as  a) it is more difficult to alter, and  b) we cannot
>guarantee that we will be able to successfully retrieve the document at
>any future point, due to possible corruption during migration, obsolete
>software or hardware...

The only thing I'm aware of that addresses this in a published source you
can hold up is BIP008, "Legal Admissibility of Scanned Documents" which is
called a standard, but is more of a practice document from the BSI series.

And YES, this is a BIG 'it depends' issue... 

In the US Federal arena, guidance is in 36CFR, Part 1234 on the management
of records in electronic format and storage on electronic media. The
criteria for the creation and use of textual documents as official records
is in 1234.22; issues related to evidence are in 1234.26; selection and use
of media for storage in 1234.30; and retention and disposition in 1234.32,
which calls for "...regular recopying, reformatting, and other necessary
maintenance to ensure the retention and usability of electronic records
throughout their authorized life cycle." 

There are a number of issues organizations should consider when evaluating
the decision to image and eliminate paper files as their official records. 
Among these are:

- cost/benefit analysis of eliminating the storage of paper as opposed to
migration/conversion of electronic formats over a life cycle
- anticipated or perceived operational benefits
- risk of loss, due to the inherent unstable nature of media over the long term
- required retention period and frequency of access to the records
- ability to convert the paper in-house or the need to procure services
through a third party for prep, indexing, scanning
- ability to perform adequate QC on the converted materials on completion

There are instances where a hybrid option may also serve an organization's
needs.  In cases where there is a requirement for simultaneous access to
content by multiple parties in disparate locations for discrete business
purposes, there is value in imaging paper to create a 'reference copy", and
where these records have an extended retention period (10 or more years),
retaining the paper copy as the "official record".   As mentioned by Debbie,
is is difficult to alter (which in evidence terms means it can more easily
demonstrate that is is what it purports to be) and in the event the
electronic version becomes corrupted or lost, allows you to regenerate
another reference copy. 

Where records have a diminishing regular reference use, but an extremely
extended retention period (25 years or greater, up to Permanent) there is an
even greater benefit to retaining the paper as the official record, stored
in an appropriately protected environment. NFPA232 (Table 4.1.1) suggests
that Permanent and Vital records be stored in a vault, but allows for
decisions to be made of lower levels of protection, providing the
appropriate records protection equipment is used.

There are much greater maintenance costs associated with long term
management of records in electronic forms, but as mentioned, there are also
benefits for considering conversion for reference use in addition to
maintaining the paper copies as the official record.  

And yes...gulp... there are benefits to considering the output to
microfilm/microfiche of "born digital" (electronic only) records or even
printing them to paper if they are vital or permanent for satisfying
retention requirements. 

A word of caution though, IF your organization makes a conscious decision to
go away from maintaining paper as the official record, clearly document the
decision and ensure your procedures for conversion, validation, media
refreshing, storage and maintenance in the electronic system, backup,
disaster recovery and prevention, and other aspects of managing information
assets in this new paradigm are fully documented and signed off on by legal
counsel and/or a senior executive within your organization.  And follow
through at all levels of the organization to ensure the practices/processes
are consistently managed and applied to avoid legal issues in the future.
 
>My apologies to Steve, I know you hate paper.

Aww... no need to apologize to SteveW, his hatred for paper based records
will remain intact irrespective of anyone's decisions or actions. =)  That's
part of what makes him so dang adorable...

Larry
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