Hi Barbara,

Like Dean, I don't know of any specific citation that would apply in this
case, however here's my take:

If the employees who will have access to the imaged correspondence and
checks would have normally had equal access to the physical correspondence
and checks, then the effort required for redaction is probably unnecessary.
However, if you are broadening the distribution of the information to
individuals who do not have a need to know/who have not already been
approved for access to that information (account numbers, etc.), then
redaction is certainly called for.

My point is, just be sure you need to spend the effort ($$) before you do
it.

I assume you've already tried, but maybe see if you can track down the
"someone" who told them they needed to redact ... perhaps that someone can
point you to the authority they were thinking about?  Best guess is they
were referring to laws to protect PII, however if the individuals who will
have access to the PII *need* access to the PII to fulfill their job
requirements, then redaction would necessarily bring your process to a
screeching halt!

Also, be sure that you know what your plan is for maintaining the physical
records and the images going forward (will you keep the physical records as
the "record" copy, or will the image serve as the "record" and you plan to
destroy the physical copies after imaging?).  Your retention schedule will
need to address retention and disposition requirements for all media if you
keep copies in multiple formats.

Good luck!

Julie

-- 
Julie J. Colgan, CRM

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