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Date: | Fri, 4 Sep 2015 07:33:57 -0400 |
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<<
I'm not thinking about simple deletion by hitting the Delete key, but a
thorough and complete removal of documents and their sub-versions from
within a document management system. Is there a need or requirement to
retain any document specific metadata as proof of deletion?
>>
A requirement? Regulations that address actual records destruction are
typically privacy laws. 30 states have regs that address destruction of
personal data. I'm not sure any of them specify what metadata should be
retained. There's GLBA on the federal level, but the law itself is while
it does address protection does not go into that level of detail on
document destruction. European privacy laws are typically a bit more
specific, but even they dont't prescribe metadata retention requirements
that I've seen. If you have records that apply to those laws, think of the
metadata you might reasonably need to produce to prove you complied with
the law.
A need? Aside from regulatory requirements, you may need to show in an
audit that you no longer have the records being asked for, as they were
legally destroyed IAW your normal business procedure based on your records
retention schedule and destruction procedure. Again, think of the metadata
you my reasonably need to show this...
Destruction documentation is typically done on the batch or group or
record series level depending on the nature of what was destroyed. Many
people on this list are much more versed in DMS's and would know their
capabilities for retaining metadata from individual documents that were
deleted, but again, you would have to determine if you have the need to do
that IAW your industry, and what metadata you would reasonably need to
retain.
Gary Link
Pittsburgh, PA
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