For what it's worth, I am currently drafting a new Retention Policy for my organization.  I do address this issue briefly in the Policy by stating (paraphrased) that DR/BC back-ups and storage cannot be used for the purposes of a records retention/archival system.  That said, I have not had Legal Counsel review the draft yet.  In addition, as with any organizational policy, my organization will need to "practice what the policy preaches."

Thanks to everyone for the great discussion on this topic!


Brett Wise CRM, CIPP/US, IGP, CIP | American Board of Pediatrics
Director of Records & Information Management
111 Silver Cedar Court
Chapel Hill, NC 27514
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