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Subject:
From:
Christian Meinke <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 20 Jul 2007 12:18:36 -0700
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> 1) MANY of the people who have responded speak about the "wiki aspect",
and
> what's most interesting is what some cite as a benefit, others of us see
as
> a major detriment.  ANYONE can change it, and/or change it back, again
and
> again, with impunity.
>

I think the way that is managed in the wiki is the fact that wikis also
contain the history of changes made, so that a well attended wiki quickly
corrects bad information. Additionally, the "anyone" aspect isn't really a
problem where they are providing references/citations/examples of use, etc.
(Besides, do you really want to go into the whole "value of credentials"
sort of argument that we might get in if we do something like limit input
from CRMs)

> 2) If there is no citation of the regulation used to support guidance
given
> (Section, Chapter, Sub-Section, etc. AND the date of the citation), then
> there's no way to validate that the proper or current guidance was used.
>

I agree about the need for citations - I imagine retentions listed without
citation would be ignored and perhaps either eliminated or appended as more
People participate.

As for different rules and regulations applying to different jurisdictions,
I also don't see that as a problem (that's always been the case with or
without a wiki and plenty people still make the mistake in thinking the
following the federal guidelines absolves them from checking out other
state or local requirements.) If anything I think this might be the
strength of the wiki - to document the rules on a topic for various
jurisdictions (My personal example involves researching an application of
applying digital signature that forced me to do ridiculous amounts of
research on different States, Nations, disciplines, and professional
organizations - how nice if these citations were already collected in one
place.

Wiki or not, I think we records managers are constantly facing the dilemma
that while our research is extensive, we never know if it's exhaustive -
who can honestly claim to have read all the CFRs, State Laws, Guideline
documents, that exist out there - I know I haven't. In my mind the wiki is
a great tool to close that gap (over time of course - right now it's like
started off on a brand new RM implementation).







                           Christian Meinke, CRM
                        Southern California Edison
                       Enterprise Resource Planning
                            Operations Support
                       Document & Records Management
                         (626) 543-7260/PAX 37260
                           Mobile (818) 414-9515
                         [log in to unmask]


Records Management Program <[log in to unmask]> wrote on 07/20/2007
11:53:02 AM:

> Great to hear so many thoughts on this topic and the offering itself.
>
> I'm still of the mind that this isn't really the way to go about
developing
> a schedule for an organization other than considering it as a starting
> point.
>
> Here's a few reasons for consideration:
>
> If something is there that's correct (for a specific record series, but
> applicable to only one State, Country, or Industry) and someone else
changes
> it because it isn't applicable to them (because they work in a different
> State, Country, or Industry) it's still right, right?  But it's not right
> for everyone.
>
> 2) If there is no citation of the regulation used to support guidance
given
> (Section, Chapter, Sub-Section, etc. AND the date of the citation), then
> there's no way to validate that the proper or current guidance was used.
>
> Here's an example... gas transmission pipelines.  The regulations for
> inspection records for pipelines attached to bridges and appurtenances
are
> DRASTICALLY different if you operate an interstate versus an intrastate
> pipeline.  Granted, that has a limited application... but the sources of
> guidance come from completely different agencies, and in different
states,
> the guidance is different as well.
>
> Here's another... loan and property related records.  There are some
states
> (sorry, Steve) that still require a lender to retain the wet-signed
> documents, and others that could care less.  There are also some states
that
> disallow the storage of the documents in any state other than the one
where
> the transaction occurred.
>
> In instances such as those above,m what would this on-line resource do?
> List a record series description, then have a minimum of 51 citations to
> cover each US state and the Federal guidance as well?
>
> 3) Because ANYONE can change this, how does anyone control who changed
what
> when, and what happens t the guidance that was there before?
>
> What happens if an organization elects to use this to develop their
> retention schedule, then says "they based their decisions on the GCR
on-line
> retention schedule guidance" (which is covered by a disclaimer, so GCR
> appropriately accepts no liability) and then they go to court and are
asked
> to produce what they based their schedules on?
>
> Unless you download and maintain a copy of the contents of the entire
wiki
> at the time you used it to develop your schedule, then you have nothing
to
> fall back on.  And this is similar to hiring a consultant, or using one
of
> the other "canned" resources mentioned to develop your schedule, but in
> those cases, you HAVE a complete copy of the baseline information
available.
>
> I'm not suggesting this is the worst possible thing we've ever seen, but
I
> am suggesting that serious consideration should be given to any decision
to
> use someone elses homework, or to buy a term paper off the Internet, or
to
> get advice on a blind date for setting your retention periods.
>
> Larry
>
> --
> Larry Medina
> Danville, CA
> RIM Professional since 1972
>
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