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I have this urge to go into a long dissertation on
structured versus unstructured information and segue
into data versus document....

I think what we're faced with are decisions being made
in a vacuum which impose records upon us that are not
being captured by record-keeping systems. You can make
this case for voicemail to .wav, instant messaging,
and even the images being stored in digital copiers.

With instant messaging, we at least have some rules
for some industries (broker-dealers) that mandate the
retention of instant messages in certain
circumstances. You can get your arms around that to
some extent and apply (with some automation) metadata
tags that will allow you to get back to a particular
transaction between two parties. In addition, you're
dealing with text (for the most part) that can be
searched (although you may need a search engine
capable of deciphering a lot of the shortcuts and
"smileys" found in instant messages). But it is text
and that is ok to deal with.

Digital copiers are at the other extreme. You don't
intend to create a record, but the machine's
"undocumented feature" (every image that is scanned is
stored on a hard drive in the machine for a period of
time, then overwritten when the disk is full) does the
job anyway. The machine is not ever intended as a
records capture device, but it becomes one (in some
respects) by virtue of this functionality. I'll let
the lawyers debate whether or not the images are truly
records (I'm told intent is the deciding factor) but
what is there is discoverable and a potential security
risk.

In the middle might be voicemail. We really don't
intend for it to be a record, but I know that you can
always find someone in an organization who has
"archived" a bunch of voicemails, "just in case".
Usually, there is no real way to get them out of the
system (short of recording them onto a handheld tape
recorder) and retain them, so people generally deal
with them by ignoring them or giving the medium a "not
to exceed" retention period.

With VM to .wav technology, we get a different angle
on the "recordness" of the technology. By giving the
user the ability to retain a VM and "file" it, we
likely have to look at VM in a new light. As said
before, content, not medium, determines retention.
.wav files are unstructured and generally unsearchable
without a lot of metadata, due to the nature of the
file (sound). In theory, you could do voice
recognition and attempt to extract meaningful text,
but VM will likely seldom self-index. What's required
is a more robust system that automatically associates
metadata with the file (perhaps time/date stamps,
phone number called, caller ID of the call source,
etc.) and allows the input of additional metadata by
the user (billing code, record type, name of person,
etc.).

Until a system like that exists, we have to make do
with band-aids like retaining the attachment as part
of an email, which is then filed according to the file
plan. Now, if your file plan still has you printing
off email to be filed as paper, you'll have to go back
to that drawing board.

My point is that we have to design the requirements
for these systems if they are going to be treated as
records. We need to ensure that records requirements
are the part of such technology purchases and be more
proactive in these processes, rather than reactive.

Patrick Cunningham, CRM

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