Kelly,

Not treating copies of records as records may be fine depending on what you
mean by that.  With copies of records you DON'T need to:
- maintain/defend their authenticity
- protect them from alteration
- protect them from deterioration or unauthorized destruction
- manage them to support retrieval
- ensure they are retained for a specified time period

On the other hand you DO need to:
- protect them from unauthorized access/disclosure
- ensure they are properly disposed of before they become a liability (and
certainly by the time the "original" record is dispositioned)

Not addressing requirements for their disposition is not an option, so if
your retention schedule is your method for doing so, you should address
copies there.

Note that the above doesn't consider copies of records that may become new
records themselves if marginalia/notes/embedded metadata are added, or may
become incorporated as a part of another record.

Peter B. Lundell
Manager, Technical Support
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Millican & Associates, Inc.
2699 Stirling Road, Suite C106
Fort Lauderdale, Florida  33312-6579
(954) 963-1771
Fax: (954) 962-7956
www.millican-assoc.com

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