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Subject: Technological Obsolescence of Records
From: Patrick Cunningham <[log in to unmask]>
Reply-To:[log in to unmask]
Date:Mon, 2 Dec 2002 15:22:18 -0800
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I'll start a new thread taking off from Susan's posting. I think there
is some value in discussing this.

So the question is, "Should a records retention schedule take into
consideration the technological obsolescence of the medium of storage?"

My answer is: ABSOLUTELY, but with a very big astirisk.

I'm not going to advocate that we retain records for the life of the
software and hardware. Rather, the issue is that we need to make sure
that if we set a retention period for any record, that the record will
continue to be retrievable for the duration of the retention period.
What that means is that the records manager must partner with all
interested parties to ensure that they understand the implications of
the retention period.

If you set the retention period for the General Ledger to be "life of
the corporation", you must work with IS types to make sure that they
have a migration strategy in place for the information that is relevant
to the General Ledger.

To me, that approach is actively managing records.

You could, in theory, take the approach that technology will drive the
retention periods solely on obsolescence. If something is important, it
will be migrated and retained; if it is not, it will no longer be
available. But I'm not sure that such a passive approach works. Again,
the GL... If your company moves from SAP to PeopleSoft (for example),
will every bit of data be converted? I doubt it. The currently relevant
information will be converted, as will any information that is known to
be subject to audits. The other data will go away. And if that data is
relevant to the GL, but not relevant to current needs, you likely lose
information that needs to be retained.

The passive approach described above, then, has a couple flaws: 1)
Information that is not currently needed, but is required to be
retained, may be lost in migrations; 2) Information that is not needed
will be retained until media / system obsolescence, which is likely too
long.

If someone is advocating this passive approach to retention (which,
realistically, is very likely how many companies are dealing with
electronic records if no one is pushing the issue), I suspect they are
skating on thin ice legally. I know that I have been in seminars where
attorneys have indictaed that the courts don't care about your
technology issues. Just because you relevant documents are stored on
8-inch floppies and you have no reader, does not excuse you from
producing the relevant information.

Patrick Cunningham, CRM

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