At 01:46 PM 11/2/2004 -0500, you wrote:
>The paper I'm referring to has been sent to an Official Repository or
>should have been.
>The Working Files I'm referring to would be copies or drafts of those
>records.

Okay, that wasn't made clear earlier... "working files" is a pretty broad
description, and can mean a variety of things.

If they truly are drafts and/or (exact) copies, then there is no legitimate
reason for continuing to store them.  They aren't record material and there
should be a clear policy about what the process is for disposing of drafts
or non-record material.  And if there is, then retaining it for periods
longer than what's stated in the policy shouldn't be supported, by anyone.

>I don't know what native format you're referring to but just about
>everything created today in a normal office has come from an electronic
>source.  Exception being paper forms that are completed manually.  Lab
>Books would be another exception.

That's what I mentioned specifically, forms and if you are receiving things
in paper form from clients, such as purchase orders, contracts, etc.  While
I agree many things are produced using some electronic source, there are
still faxes, items received in the mail, forms, HR papers, training
materials, etc. that are handled in paper form and unless your policy is to
scan and delete the paper on these types of items, it will build up
periodically (he says as he looks around his office). =)

>Using established, legally researched retention schedules the retention
>periods would be applied to all media
>The exception here being Paper Conversion to an Archive media +2 years.
>  After I've place paper on film I would then dispose of the paper and
>keep the film for the full length of the retention.  It's that old Best
>Evidence Rule !

But keep in mind, you need to QC the images, and periodically convert and
migrate the images if they're in some proprietary format, or in the case of
the media, just to ensure it remains legible.  And you can avoid this with
film, provided it's properly processed and stored, and you have a viable
index to support the images on it.

>If the paper records being retained are available in an Electronic
>Repository, say for example Documentum, do you still believe you should
>keep the paper for retrievals or perhaps get training on how to access
>the electronic version.

No, there is no need to retain the paper if you have an EDMS used to retain
the record copies of documents and a policy that clearly states you retain
all official records in the system and delete drafts and any paper copies
once items are recorded into the system.  And yes, there should be training
for *any* individuals who are presently using the paper repository as their
source for information that will subsequently be required to rely on the
EDMS as their repository.

An example of where this doesn't work well is a County Public Defenders or
District Attorneys office, where a file on a client is handled by any
number of attorneys involved in the case, and it may periodically change
hands.  Most attorneys will want a "physical file" to review prior to going
to court, and the file will have items added to it, along with a wide range
of margin notes being taken, etc.  If they were forced to work off of an
electronic file, it would have to be printed every time they were preparing
to go to court and every time they returned from court, the file would have
to be researched to see what new materials or notes may have been
added.  In addition, if the case involved a minor, the file would need to
be sealed when they turned 18 and a new file started... and if the images
were stored on an optical platter (or backed up to a tape) that had mixed
records, there would be a big problem expunging the images/records from the
platter or the tape, because simply removing the "pointers" wouldn't
satisfy the legal requirements of sealing the record.

>I understand the concept of corporate culture and agree this plays into
>the what's, whereas and whys.  However I'm faced with the issue at hand
>which is the glut of unnecessary paper records being stored and will
>address additional RM theories and concepts at a later date.

As I said, if the issue had been initially presented as "these are copies
of official records kept elsewhere", lots of what was provided for
consideration wouldn't have been, in fact, I likely wouldn't have bothered
responding.

>I appreciate your response and perhaps if you have hard data that would
>help with a File Clean-up program you could share that as well.

If you have a written policy, then provide a copy of (or link to) the
policy to all employees reminding them of the Corporate RIM policy and
inform them that in accordance with the policy, the "working files"
presently being retained in the XYZ location will be discarded as of
XX/XX/XX date.  This should come on a letterhead from the Corporate
Counsel, reminding them of the need to be in compliance with policy and
explaining that the intention of this is to minimize costs associated with
the space required to store the extraneous materials and the potential for
exposure in the event of a discovery during a legal action.  Clearly state
that it isn't an effort to "clean out files", but an effort to comply with
existing policies.

Larry

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