In response Sam McCollum's points:

"If a client or customer inputs personal information into a GUI, then
current Privacy legislation in Canada, they have the right to ask your
organization for a copy of that personal information at any time, for
verification reasons. If you still have the information in your system (in
accordance with proper retention schedules) then you must produce it. The
catch is that they have the right to see the information in the same
(Graphical User Interface) that they used to input it.  This means that
must keep the GUI for the full retention period as well.
        This Privacy requirement creates all kinds of complicated
retention issues
since webpages are regularly changes or updated."

That certainly puts a spanner in the works. My question would be: Do you
need to keep the layout with their input (ie. what the page shows when
they hit the "submit" button)? Or just the layout they were viewing as
they entered their information?

If the former, you'd probably need to program the webpage to print the web
page (with info input) to PDF and save it as an attachment in the
database. Again here you have the exact view in the database. The Web
pages could be changed and the customer views kept exactly as they were
when used.

If the latter, then the web page "form" would be a copy of a standard form
which can be kept in the company's ISO 9000 series manual (or if not ISO
accredited, then in the company's procedure manual in the "forms"
section). The manual would then be subject to retention (ISO manuals are
subject to change history so it wouldn't be any extra effort for ISO (9000
series) certified companies).

Would either of those methods satisfy the Canadian privacy legislation?

And finally: "Are we all having fun yet?"

To quote Steve Lewis's title of his regular column in RMTechnology
magazine: "Records Management is Fun" :-)

Martin Cole
Manager - Hawaii
Crown Records Management

Email: [log in to unmask]

This post reflects my personal opinions and is not indicative of the
of Crown Records Management.

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