While the State requires us to use a particular form to document the
destruction of records, we also use internal tracking.  We have a master
log that is supported by destruction documentation (destruction
notifications, hold requests, certificates of destruction, etc.).  This
log has a permanent retention.  We do not list every individual record
that is destroyed, but list in records series groups with inclusive
dates.  With an EDMS, you can produce copies of audit trail logs or
reports that show the same thing.

When we are asked to produce records that have been destroyed, I use the
log to obtain date and method of destruction (recycling, shredding, or
electronic deletion) and I issue a certified statement that the records
were destroyed/deleted in accordance with established policy and
procedures.  The key is to have demonstrable established policy and
procedures and to have supporting documentation that show we followed
those policies and procedures.

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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