Wayne,
I know your company is not alone in dealing with this situation.  At this
point in time you must accept the fact that you have little to no control
over the data in your hosted system.  However, this situation should be a
red flag for your company.  Before you make a decision to use a hosted
system, your company policy should already be in place, and the vendor
contract should include your company's requirements.

When a company chooses to use the services of a hosted system they must
consider all the potential risks and costs associated with that choice.
Then the company must live with the consequences downstream if the
information/data is not deleted.  Some information/data may have few risks,
where other information/data may have very high risks (i.e.
personal/privacy data).

Risk Analysis should be a key element for these decisions, and always
weighs the benefits against the potential costs.  Information Policies
should not be written to establish the ideal situation, but rather to
ensure compliance with the company's decisions and choices.  Write your
policies now; not when you are ready to retire the system. Then you
systematically follow your policies and accept the results of your
choices.

Mary

Mary W. Haider, MBA, CRM
Records & Information Manager and Consultant
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865-983-1371

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