Lisa, I ran into this issue some time ago. Another agency was hammering
us and basically calling for my head because we did not document the
destruction of every record in the county (as it later turned out,
neither did they). At the time, I discovered that Oregon rules did not
require that documentation (of course, that probably doesn't apply in
your case - I wouldn't argue law with lawyers).

We document every destruction done through the Records Center. That is
part of our service, and it has proven valuable when it becomes an issue
with our customers, but, to be honest, it is very rare that that
happens. I believe I've had to produce documentation twice in the past
20 years, although questions on whether records were destroyed or not is
a regular occurrence - primarily for operational, not legal, purposes.
In spite of this, I consider it a critical component to our claim to be
a trusted repository. Maintaining our market penetration in the county
relies to a large extent on that trust. IMHO, the concept of trusted
records keeping systems is going to become increasingly important in the
maintenance of electronic records. However, there are multitudes of ways
that a system can claim to be "trusted".

One needs to be careful with requirements. You have to balance need with
effort. How realistic will it be to document such destructions in the
absence of a record keeping system that will provide that capability?
Creating the requirement without the capability increases risk. You need
to balance risk with cost and operational need. 

If you are not documenting destruction, what is the plan in place to
show that e-mails are being maintained in compliance with retention
policy, and being destroyed in the normal course of business? Written
policies, regular training, and occasional audits all may meet this need
in lieu of the type of documentation you are looking into, and create
the trust needed.

Dwight Wallis, CRM
Records Administrator
Multnomah County Fleet, Records, Electronics, Distribution and Stores
1620 S.E. 190th Avenue
Portland, OR 97233
Phone: (503)988-3741
Fax: (503)988-3754
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