At 08:41 AM 1/21/2005 -0600, you wrote:
>We define general business records as "electronic
>non-record or working files, created or received for general business
>use but not required for record retention purposes".  The powers that be
>are currently discussing whether these documents require a stated policy
>for review and deletion.

I would think that based on some of the proposed rule changes to the
"Federal Rules of Civil Procedure" (FRCP) currently in the pipeline and
available for public comment until mid-February, along with the sanctions
and penalties handed down by any number of District Court Judges over the
past two years, the "powers that be" may want to reconsider this present
policy.

The present manner in which e-discovery is being handled would likely frown
upon these records being discarded, unless tit is done in the "normal
course of business", and the idea that the policy is based on the format of
the record (electronic) seems a bit ludicrous.  Retention policies are
established based on the CONTENT, not the FORMAT of information.  If these
TRULY are non-record material, then there's no issue, but "working files"
needs to be clearly identified and defined, because that terminology has
some specific meanings to the SEC and other regulators.

I noticed you're with a communications company... seeing as you are, your
retention schedule is likely impacted by SOME Federal Agency, and the
standard rule for the Feds related to records is "irrespective or media,
form or format".

Larry

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