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RECMGMT-L  September 2011, Week 2

RECMGMT-L September 2011, Week 2

Subject:

WAS Re: Are scanned documents considered as records? NOW: SHOULD source materials be scanned and what does it entail?

From:

Larry Medina <[log in to unmask]>

Reply-To:

Records Management Program <[log in to unmask]>

Date:

Wed, 14 Sep 2011 11:51:07 -0400

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (109 lines)

In the Federal environment, which is where many of the regulations and
statutes come from regarding how records are managed, there are requirements
that must be taken into consideration.  

This applies to Agencies and Contractors generating records that ultimately
belong to Federal Agencies, as well as anyone who may have to respond to a
Federal records request *IF* their recordkeeping is regulated by a Federal
agency. There are a number of natural gas and other transmission pipeline
operators that are starting to gain appreciation of the changing
requirements to 49CFR that apply to them.  But I digress....

As stated by "the Johns" and others, if you develop a rigorous practice,
supported by policies ans procedures to verify and validate all images as
captured during a conversion process, AND you can comply with the
requirements below from 36CFR to ensure persistent accessibility for the
required retention period for images of the converted records, there
shouldn't be an issue.  

That said, this doesn't mean you chuck a handful of pages into an
auto-feeder, walk away, have lunch, come back and shred the source
materials. And as mentioned by Fred, Chris and others, there are instances
in which for historic or intrinsic purposes, the source materials SHOULD NOT
be discarded... BUT if you're going to keep both, make sure your indexing or
cataloging system indicates you have both and where to locate them.  The
"best evidence rule" may require you to present them *IF* you have them.

The other thing that has come up here in this discussion time and again is
to determine the cost benefits of converting source materials before doing
it.  Digitizing can cause more problems than it solves- and the cost/benefit
isn't always there. First, you need to consider the value of the information
contained in the source materials and the required retention.  If the value
is low and the retention period is short, why not simply maintain them in
the original form, supported by a clear index that tells you how to locate
them, then discard them when no longer required for legal and/or business use?

If the value is high and the retention period is long, digitizing is one
possible alternative. But so is making a second copy that is stored in a
secondary location to avoid potential damage in a catastrophe and again,
support them with a clear index that tells you how to locate them.

Where there is a benefit to digitizing is if the value is high, multiple
people in multiple disparate locations need simultaneous access, and the
retention period is long or even relatively short (up to 7 years). You will
STILL need to develop a detailed index to gain access and there may STILL be
a value in retaining the source materials as a backup in the event of a
failure of your electronic repository... but the images become your primary
reference source.

There are extensive costs related to imaging, far beyond the labor to
prepare and capture the images, build the index, verify the accuracy of the
data, purchase storage equipment, generate backups, periodically
replace/refresh the media, convert and migrate the content to new formats as
required over its retention period, etc.

Larry
[log in to unmask]

Excerpt from 36CFR, Part 1236 "Electronic Records Management"

§ 1236.12 What other records management and preservation considerations must
be incorporated into the design, development, and implementation of electronic
information systems?
As part of the capital planning and systems development life cycle
processes, agencies must ensure:
(a) That records management controls (see § 1236.10) are planned and
implemented in the system;
(b) That all records in the system will be retrievable and usable for as
long as needed to conduct agency business (i.e., for their NARA- approved
retention period). Where the records will need to be retained beyond the
planned life of the system, agencies must plan and budget for the migration
of records and their associated metadata to new storage media or formats in
order to avoid loss due to media decay or technology obsolescence. (See §
1236.14.)
(c) The transfer of permanent records to NARA in accordance with part 1235
of this subchapter.
(d) Provision of a standard interchange format (e.g., ASCII or XML) when
needed to permit the exchange of electronic documents between offices using
different software or operating systems.

§ 1236.14 What must agencies do to protect records against technological
obsolescence?
Agencies must design and implement migration strategies to counteract
hardware and software dependencies of electronic records whenever the
records must be maintained and used beyond the life of the information
system in which the records are originally created or captured. To
successfully protect records against technological obsolescence, agencies must:
(a) Determine if the NARA-approved retention period for the records will be
longer than the life of the system where they are currently stored. If so,
plan for the migration of the records to a new system before the current
system is retired.
(b) Carry out upgrades of hardware and software in such a way as to retain
the functionality and integrity of the electronic records created in them.
Retention of record functionality and integrity requires:
(1) Retaining the records in a usable format until their authorized
disposition date. Where migration includes conversion of records, ensure
that the authorized disposition of the records can be implemented after
conversion;
(2) Any necessary conversion of storage media to provide compatibility with
current hardware and software; and
(3) Maintaining a link between records and their metadata through conversion
or migration, including capture of all relevant associated metadata at the
point of migration (for both the records and the migration process).
Ensure that migration strategies address non-active electronic records that
are stored off-line.

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