Larry,

I agree with you on the guidance - we have both a standard and a policy
that spells out what the tapes/CDs are for (backup/disaster recovery
purposes) as well as the rotation schedule.  But I am not sure the need for
including on a retention schedule if the sole purpose is for disaster
recovery purposes.  Since the records are most likely maintained in a
repository of some type (SharePoint, shared drives, ERP, etc) the back-ups
could be considered the storage media for convenience copies.  If a record
of the destruction is to be retained, I would say the responsibility for
retaining these is with your IS group, not you.  That has been the policy
for other organizations I have worked for, both public and private.

Bruce White, CRM, PMP
Virginia Beach, VA
e-mail: [log in to unmask]
LinkedIn:  http://www.linkedin.com/in/bblanco

Sometimes the questions are complicated
and the answers are simple.
                       Dr. Seuss


On Wed, Mar 5, 2014 at 12:40 PM, Larry Medina <[log in to unmask]>wrote:

>
> The guidance that should exist for rotation and deletion/overwriting of
> content on backup tapes should revolve around the shortest time possible
> that the content remains viable for reconstituting the system.  If full
> backups are made, as soon as a new one is generated, the content of the
> prior one becomes less valuable.  If incremental backups are made, then
> decisions have to be made to determine when the last full backup becomes so
> stale that it would take too much effort to reconstitute from the full
> backup and have to add in all of the incremental data.
>
> As to the question about retaining the destruction notices?  My opinion is
> YES, they should be retained, in part because the demonstrate that you were
> following the policy related to the backup rotation/cycling. Secondly,
> because although as you stated they are not "a records storage medium",
> they DO contain records and because you maintain records of the disposition
> of records in other forms, this would be no different. In our case, we
> follow the guidance in NARA GRS 16, item 2 (a) 2 which is to retain for 6
> years.
>

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