This is what and how we do it also, as I tried to explain in my earlier
e-mail to you.

Respectfully submitted,

Tracey Ann Black
Records Administrator, MMWEC
mailto:[log in to unmask]
1-413-589-0141 x272

-----Original Message-----
From: Patrick Cunningham, CRM [mailto:[log in to unmask]]
Sent: Tuesday, July 09, 2002 4:44 PM
To: [log in to unmask]
Subject: Re: IT and Records Management

I'm going to take a slightly contrary viewpoint. A couple companies ago, I
worked in an environment where RM managed the flow of offsite backup storage
due to the FIRELOCK (tm) vault that we had back there. Note well, that we
did not do the backing up or restoring. As others have noted, that is best
left to the experts in that arena. But if you have the right offsite
facility (i.e. climate controlled, away from other critical systems, etc.),
there is nothing wrong, IMHO, with RM managing the "vaulting" of backup
media. It is possible that you can provide this service for less expense
than might be incurred with a third party vendor. But do your homework.

At that company, we did picks and pulls for the offsite tape storage silos.
IS controlled the Tape Management System and sent us the manual picklists
and inventories for the nightly tape rotations. In addition, we maintained
the various daily, weekly, and monthly backup tapes for the server
infrastructure. All we did was ensure that the media were coming offsite on
schedule and send back the expired media.

I'm aware of at least one other company that had RM doing the offsite tape
silo picks and pulls, but that company is consolidating its records
operations and the tape silo management will revert to IS because the RM
folks are not proximate to the equipment.

You do want to make sure that you are provided with the correct resources to
do this, both in terms of people and equipment. Keep in mind, a lot of
mainframe-scale tape vaulting is a second or even third shift operation.

Some of the benefits of partnering in this way are:

1) Forging a true partnership with IS. This partnership may open the door to
getting better retention control over computer storage media, if such a
partnership has been hard to achieve.

2) Ability to implement hold orders during litigation more quickly. If you
manage the tapes, you will likely be able to implement litigation holds more
effectively and more quickly. You will also have a better communication
channel to the right people in IS to ensure that relevant tape rotations

3) Ability to leverage RM investments across additional types of media and
business units. Ability to leverage people resources.

Risks include:

1) Inability to do much more than respond to a request for a particular tape
(i.e. no real way to verify tapes, exercise them, or otherwise ensure that
the integrity of the data exists). If you have concerns about complying with
IRS Rev. Proc. 97-22, you may not be able to effect compliance.

2) Becoming the scapegoat for system failures. Many backup systems do not
always work as advertised and the technologists often do not verify that the
systems operate as they should. Be cautious that RM doesn't become blamed
for every bad tape cartridge. A solid partnership will mitigate this.

3) Unrealistic service level expectations with no additional resources. Be
clear in your expectations. Get requirements documents and service level
agreements from IS. Understand that tapes can be needed 24 by 7 and that
someone (possibly you) may have to roll out of bed at 3am on a snowy, frigid
Sunday morning to pull an urgently needed tape. Be sure that your agreements
are clear on the "normal" frequencies of activities and what happens when
the levels exceed agreed upon limits. You do not want to lose your primary
work focus (RM) because the tape operations are draining away resources.
There is a reason that IS wants to shift responsibility to you. Make sure
you get all the facts... in writing.

Hope this helps...

Patrick Cunningham, CRM

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