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I disagree with Sam as well, but for a different reason: which version of the GUI is to be retained? Is it the MS Internet Explorer v6.0, or v5.0, or v2.0? Is it Netscape v7.0, or v4.5? Is it Mozilla, or Opera, or Lynx, or Mosaic 1.0, or AOL or WebTV?

What about web pages that use scripting to dynamically change the GUI for the particular browser client or for a particular user? There are dozens of different ways the GUI of a given web page will look depending on the OS, the version of the browser being used, and the elements that make up the web page. It is possible to identify and save the version of the GUI specific to the user and request, but the argument could be made that the only reliable way of doing so would be to convert to PDF, which would be a transformation little different from the one Tony describes.

All of these give strong impetus to safeguarding carefully the information contained in the web page, that information that would make it a record and thus worthy of managing, while relegating the actual visual representation of it to a lower priority - nice to have, but in the end, not a significant driver.

My .02,

Jesse Wilkins
LIT, CDIA+, EDP, ICP
Technical Support Manager
INFORMATION MANAGEMENT RESEARCH Inc.
6025 South Quebec Street
Suite 260
Englewood, CO 80111
+1 303 224-8548 office
+1 303 689 0055 fax
[log in to unmask] <mailto:[log in to unmask]>
www.imrgold.com <http://www.imrgold.com/>

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]]On
Behalf Of [log in to unmask]
Sent: Thursday, September 25, 2003 7:05 AM
To: [log in to unmask]
Subject: Re: Retention of Web Pages


I disagree with Sam McCollum's concluding sentence: "This means that you
must keep the GUI for the full retention period as well.", for the following
reason:

Section 37 of PIPEDA states:
37. A requirement under a provision of a federal law to retain a document
for a specified period is satisfied, with respect to an electronic document,
by the retention of the electronic document if (a) the electronic document
is retained for the specified period in the format in which it was made,
sent or received, or in a format that does not change the information
contained in the electronic document that was originally made, sent or
received; (b) the information in the electronic document will be readable or
perceivable by any person who is entitled to have access to the electronic
document or who is authorized to require the production of the electronic
document; and (c) if the electronic document was sent or received, any
information that identifies the origin and destination of the electronic
document and the date and time when it was sent or received is also retained

I interpret 37(a), which states, "or in a format that does not change the
information contained in the electronic document that was originally made,
sent or received", to mean that as long as the information cannot be changed
it doesn't matter which electronic format (e.g., GUI) contains the
information.  Hence, in my view, you don't have to keep the "GUI" for the
full retention period as long as the information that was displayed by the
GUI is kept for the required retention period.

Tony Laino, CRM, CDIA
Manager, Consulting Services
TAB Professional Services
1-800-243-6547 x.264
www.tab.com


-----Original Message-----
From: bobd [mailto:[log in to unmask]]
Sent: Wednesday, September 24, 2003 10:58 PM
To: [log in to unmask]
Subject: Re: Retention of Web Pages


Any Answers???

Bob Dalton, CRM
[log in to unmask]

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Maryanne Gedeon
Sent: Monday, September 22, 2003 10:20 AM
To: [log in to unmask]
Subject: Re: Retention of Web Pages

In his posting on this topic, Sam McCollum states:

"If a client or customer inputs personal information into a GUI, then under
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 format
(Graphical User Interface) that they used to input it.  This means that you
must keep the GUI for the full retention period as well."

I am currently very involved in Canadian privacy compliance at my company,
and I don't recall anything in the federal legislation (PIPEDA) that
requires production of information in its original format.

Can Sam or someone else please let me know where in PIPEDA this requirement
is defined?  Perhaps this is provincial, rather than a federal, requirement
(I hope!).

Thank you,

Maryanne Gedeon
Senior Records Management Specialist
GlaxoSmithKline Canada

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