Dana, the first purpose of scrubbing metadata to repurpose information,
which, I am assuming will then have new metadata applied, strikes me as
being a legitimate business practice - somewhat along the lines of a
form letter. However, using that process to further provide
justification of a metadata scrub for "posterity" raises concerns, as
this violates fundamental principles of records integrity and
authenticity. It would be similar to erasing signatures from contracts
for posterity. 

I can think of a number of instances where a practice like this might be
justified - for example, in a public health setting where information is
being exchanged regarding confidential HIV testing, or perhaps even in
an email box set up to receive confidential whistleblower information.
These are fairly limited and specific situations. If you have a similar
need, then that needs to be specifically cited as the business purpose
for the scrubbing related to "posterity". 

Case law is not necessarily the issue I would be concerned with.
Generally speaking, if a records keeping practice violates fundamental
records keeping principles without justification for the specific
practice, risks associated with that practice increase. In my opinion,
the fact that you are engaging in a records keeping practice to achieve
purpose A in no way justifies extending that practice to purpose B based
on a "normal course of business" argument, which appears to be what you
are describing. There has to be a clear justification for applying the
practice to purpose B specific to that purpose. 

I'll be blunt: if the purpose is related to potential future litigation,
the red flags I would be raising would shame the Soviets. However, in
all fairness, I am in a public records environment with its own demands,
and would be interested to hear of other instances where such a practice
has been used and justified, as this is a practice/technology that I
could learn more about.

Dwight Wallis, CRM
Records Administrator
Multnomah County Fleet, Records, Electronics, Distribution and Stores
(FREDS)
1620 S.E. 190th Avenue
Portland, OR 97233
Phone: (503)988-3741
Fax: (503)988-3754
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