In response to Blake's inquiry about Records of Destruction/Certificates 
of destruction:

We keep Records of destruction long term (Permanent) but are changing our 
thoughts on a formal Certificate of destruction.  This is because of the 
way we use our current RM software to batch destructions and the need for 
a formal certificate.  Since we batch the destructions we keep the batch 
open formally in our software until such time the vendor emails us with a 
message that the particular batch is physically destroyed.  We then 
destroy the batch , have that entry in the audit trail and archive the 
email message under our current process.

A good example of why we keep Records of destruction long term is a 
litigation situation we found ourselves in many years ago.  It involved a 
time charging action and over time we had changed our retention period 
multiple times due to changes in Federal law.  The time frame of the 
investigation spanned these changes and while sitting in front of a grand 
jury we were asked to show that we destroyed timecards in a timely and 
consistent manner over the entire period  Without the records of 
destruction we would not be able to show actual compliance to our policy. 
Simply stating that we followed our policy without proper documentation 
supporting it would have been insufficient according to counsel. 

Applying the same type of process to electronic media/records will/is more 
problematic and is something we struggle with currently. 

Steven H Petersen CRM / Records Manager 
MS 109-124
Phone: 319-295-5244 / VPN: 295-5244 
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www.rockwellcollins.com 


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