On Feb 3, 2005, at 8:39 AM, Fresko, Marc wrote:
> Anthony
>
> In reply to your "Surely the hard copy of these should be stored" the
> answer is quite simple: No, you do not have to store the paper after
> scanning, SO LONG AS you create and keep the scanned images in a way
> which results in you being able to have sufficient confidence in them.
> There is one "obvious" proviso:
Make that TWO, but the second may be less obvious =)
You need to revise your RM policies and procedures to clearly state
this change in business practice and when it took place, so that if
anyone challenges any of your recordkeeping systems you can clearly
show that this change is expressed in your policy and procedures as the
routine manner in which you do business, including the disposing of
paper once it's been imaged and the quality of the images have been
verified.
For example, if the policy currently states "generate documents and
file; retain for X years and then dispose" you should change it to
state "generate documents and image, verify contents of image and
dispose of originals; retain images for X years and then delete". You
may want to document the QC practice as well, in the event images are
illegible or unable to be retrieved for some reason.
It seems like a minor issue, but there are cases where the RM policies
of an organization were called into court and organizations who had
changed their business practices and failed to document them were
required to generate paper copies of all records in response to a
discovery request for the opposing party, because their policies and
procedures said their process was paper based.
Larry Medina
|