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Subject:
From:
"Harrelson, Amy" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 18 Nov 2014 16:48:42 +0000
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Hi List,
  To piggy back on the question I posed a couple days ago, I am wondering if anyone has ever submitted evidence to NERC or FERC stating that a record had met retention requirements and was destroyed in accordance with an established records management plan as audit evidence?  My concern is this:  we are being told that we need to keep most items 7 years even if they don't have a 7 year retention based on state or federal rules because they may come up in the scope of NERC/ FERC audits.  I don't understand how we would be out of compliance if state or federal statue dictated one retention and NERC did not specify a longer one for those records.  I really thought it would be similar to litigation in that if we followed procedure and disposed we prove that and we are in compliance.  I am hearing that is not the case with NERC/ FERC audits.  Any guidance on this point is appreciated.  I am just now reading up on NERC/ FERC requirements.  Also, if there is a good class or site for information on record handling for NERC/FERC items other than those respective sites, I would be interested.  I want to ensure we are doing the correct thing but I also want to ensure we are not keeping items longer than may expose us to undue risk.

Thanks,
adh

Amy Harrelson
Records Analyst
Austin Energy
721 Barton Springs Rd. Austin, TX 78704
512.322.6283


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