I think this is a good discussion.  I've worked the RIM end of the
profession (as opposed to the technical end) almost exclusively in
government - state and local.  I was taught by an alumni of NARA.  My
comments were not on legal holds or temporary holds, but on applying
approved retention periods.  There may be policy issue differences
involved in the discussion.  Perhaps NARA's interpretation of the
process differs from others.

When with state government (I left in 1983), we frequently applied
revised retentions to records in storage. I have not so fond memories of
going into the unheated, unair-conditioned stacks of 30,000+ boxes with
clipboard and revised tickets in hand to mark boxes for destruction that
previously had longer retention periods.  Had we not applied the new
approved retentions to ALL existing records, we would have created a
validity question in court or during hearings when asked why we
destroyed the "xxx records from 1966 in 1980, but destroyed the 1970
records from that series in 1976."

<I'm just unaccustomed to seeing assigned periods "fooled with" based on
changes to regulations, once they've been established.  And you can
imagine
the nightmare in doing this in an electronic records environment, which
is
what my original comments were about.>

In fact, we HAVE applied this procedure to electronic records.  When I
first established our RIM program here, the retention for customer
records was 5 years after final bill.  In the late 1990's, the retention
changed to 3 years after final bill.  It was very simple to change the
scheduled purge process to query for 3 years after final bill rather
than 5 years.  If we had had to write our purge program to apply the 3
years to final billed customers from "here forward" and keep the old 5
year purge process for customers final billed up to this date, the
programming would have been complicated and confusing, and probably very
error prone. 

Since our backup tapes are for recovery purposes, and not retention
purposes, changing the time period for purges do not affect them.

Ginny Jones
(Virginia A. Jones, CRM, FAI)
Records Manager
Information Technology Division
Newport News Dept. of Public Utilities
Newport News, VA
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