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Subject: Re: Best Practices in destruction of off-site
From: Peter Kurilecz <[log in to unmask]>
Reply-To:Peter Kurilecz <[log in to unmask]>
Date:Wed, 15 Jun 2005 22:28:42 -0400
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On 6/15/05, Patrick Cunningham <[log in to unmask]> wrote:
> I've been publicly taken to the Listserve woodshed in the past for
> advocating the approaches I outline below, but they are other options,
> provided that you have good controls and procedures in place.

"good controls and procedures in place" that is the key to the whole
destruction process. Just as retention schedules are unique to each
organization so to is the destruction process. The Patrick's process
works for his organization it may not work for others. Note especially
that the General Counsel's office is to receive ALL subpoenas upon
pain of ...

I agree with Patrick that the retention schedule when approved
provides the authorization to destroy the records when they are
eligible. BUT it takes time to EDUCATE the user community that that
destruction will take place. All processes must be examined, analyzed
and improved upon. They are not static, but are dynamic. Technology,
regulations and people all impact a process.

But remember in this day of Sarbanes-Oxley and internal controls your
destruction process must be documented, consistent and auditable.
Deviation from the process runs the risk of putting your program into
non-compliance.


--
Peter Kurilecz
Richmond, Va

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