A few thoughts on this

Are there Federal requirements related to the information/data being
managed?  Because if there are, 36CFR requires that data in systems not be
abandoned or orphaned if it still is required for retention under any known

Even if there aren't any records subject to Federal requirements, there are
obligations under Rule 26 and Rule 30 that during the data mapping process
all sources of ESI be identified and the processes, practices and procedures
related to the management of data within those systems be clearly identified
and documented.

On a different path, IT may recommend, implement, deploy, and support
systems and may even be granted the responsibility for the physical
management of the data that resides within the systems, but they do that as
a part of the function they perform... as part of their responsibilities.

The information assets belong to the organization, who pays for the
technology, the staff, and has the overall responsibility for the management
of the assets- it's their corporate obligation.  And IT is one of the
functions they are responsible for, so ultimately it is their responsibility
to ensure SOMEONE remains responsible for managing any active information
assets that reside within the systems, whether they are in active use,
transitional. or legacy... as long as the information still has a required

I don't know the extent of your role, but I don't know that it would be your
responsibility "to establish the IT Support person responsible", only to
identify the assets and systems they reside in and to then state that it
needs to be supported and protected.

The Records Manager serves a role in this team and in some cases, its to be
the Rule 30 expert, in others it's not.  I think in the example you've
provided here it's critical that the roles of all team members be
established and that every party performs their role, but that there not be
any 'holes' in the process.  It seems as if you've identified one or more


How do you solve this one:As I work on documenting company ESI I come up
> against this maddening roadblock right at the outset that derails my
> efforts: (snip)
> So what does a records manager do? Rocking the boat by trying to get some
> IT ownership is...ummm....unrewarding.

Larry Medina
Danville, CA
RIM Professional since 1972

List archives at
Contact [log in to unmask] for assistance
To unsubscribe from this list, click the below link. If not already present, place UNSUBSCRIBE RECMGMT-L or UNSUB RECMGMT-L in the body of the message.
mailto:[log in to unmask]