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Subject:
From:
Tod Chernikoff <[log in to unmask]>
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Date:
Tue, 18 Sep 2007 22:11:22 -0400
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I'll open with the question of whether this is for a public (government) or
private organization.  

 

For a government organization there are likely to be set standards and forms
used that dictate what information is collected and used in the
destruction/disposal phase.  

 

My experience in the private sector was that the federal government body
that regulated our industry did not have particular rules for us in this
particular area.  That is not to say that there were not other general areas
we dealt with such as tax regulations, employment laws, and the like we had
to consider, but no where did we run into any guidance in the area you are
researching.

 

The information we kept generally was along the lines of the destruction
certifications and signed (by the departments, and myself as the corporate
records manager) copies of destruction inventories/approvals created by our
off-site vendor (for hard copy records).  They included information on
department, end of retention period (date), type of record/description of
the box contents, and the like.  

 

We even documented, in a similar fashion, records disposed of that were
never sent off-site.  We created internal forms and procedures for this
process.

 

There are a number of resources at the ARMA Book store including, Procedures
and Issues for Managing Electronic Messages as Records and Requirements for
Managing Electronic Messages as Records (ANSI/ARMA TR-02-2007 and ANSI/ARMA
9-2004) that include information on disposition or destruction of electronic
messages classified as records.  Hope this is a start.  Good Luck.

 

Tod Chernikoff, CRM

 

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Melissa Guenther
Sent: Tuesday, September 18, 2007 7:48 PM
To: [log in to unmask]
Subject: [RM] Documenting the Destruction or Disposal of Records

 

We are researching what others are doing in regards to tracking/documenting
disposal of records (electronic and non-electronic)

Does anyone know of any legal or regulatory requirements that dictates if
any documentation or audit trail is required that documents

(how/when/why) records were disposed?

 

Specific to E Discovery:  Let's say a record is disposed of because the
retention period on the schedule passes and there are no Litigation

holds at that time.  1 year later , you are subpoenaed and determine that
the record was destroyed.  What type of documentation is required

for due diligence re: the destroyed record?

 

Thank you in advance for any information you can provide 


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