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From:
"Cohen, Stephen E." <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 4 Sep 2015 11:43:06 +0000
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Thanks!

Stephen Cohen, CRM
MetLife | Legal Affairs | 212-578-2373

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Gary Link
Sent: Friday, September 04, 2015 7:34 AM
To: [log in to unmask]
Subject: Re: Document deletion query

<<
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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