Scanning and Tossing Requirements for Scanning and the Destruction of Paper Based Records
Overview I want to go paperless! Can I scan and toss? What are the rules and requirements about imaging? What are the rules and requirements about getting rid of the paper?
Going paperless Does NOT mean simply tossing the paper based copies after scanning If you are still creating paper based records as part of your business process, you are not going paperless
How do I go paperless? Going paperless is developing completely electronic processes from start to finish No paper copy is generated, no hard copy signatures required for authority or execution. The transactions and execution of business is all done in a digital format (For example: using e-forms, electronic web-based applications, databases, electronic approvals/signatures)
Do some planning when you do go paperless You can absolutely do business completely electronically (born digital) as long as you follow retention and disposition requirements And Meet any other requirements (legal, audit, access, other regulatory) as necessary for your agency business It s a good idea to document the decisions and implementation of going paperless
Digitization vs born digital Imaging or scanning is converting a paper based document, photograph or even film to a digital picture or image Scanning and tossing is imaging and then wanting to destroy or get rid of the paper based records The resulting image is then your substitute public record
What is Born Digital? #1 Board minutes are drafted using Microsoft Word and then printed in hard copy Chair signs the printed hard copy minutes at the next meeting Transaction of public business occurs in paper so the signed paper minutes need to be retained, the unsigned word document is considered a draft
What is Born Digital? #2 Agendas are drafted using Microsoft Word Agendas are distributed to Committee members via email with the Word attachment, nothing is printed Transaction of public business occurs electronically so the email and attachments need to be retained
What is Born Digital? #3 A request to change a student s address is submitted in hard copy to the school. Information entered into database. Transaction of public business occurs in paper so the submitted hardcopy record need to be retained that form is the evidence and the authority to make the change requested
An example A local school board goes paperless Meeting arrangements, agendas, drafts of minutes, approval of minutes, resolutions are all drafted, circulated, accessed, approved and executed without printing out of any paper and no hard copy signatures required Official business is all conducted via email, online, or use of a software applications specific to supporting boards and meetings All business captured and supported electronically Board passed resolution to do so
There is still a lot of paper! Requirements for Scanning
You can t just do it Conversion to an imaging system does not automatically authorize the destruction of the source documents for which images have been created. WAC 434-663-600
Preservation of Electronic Records And images are maintained in accordance to WAC 434-662-040 Electronic records must be retained in electronic format and remain usable, searchable, retrievable and authentic for the length of the designated retention period. You must maintain that image for the entire minimum required retention period Be it for 10, 25, 60, or 100 years Technology and longevity have yet to meet!
Much ado about metadata Commonly described as data about the data Establishes and preserves the authenticity of an electronic record Is the evidence of the transaction it documents
Metadata and indexing WAC 434-663-710 Imaging requires consistent indexing and metadata for identification, access and retrieval of public records Indexing is a way to attach metadata that facilitates access, retrieval and management of information
What you need to know first Paper-based source records must be eligible for destruction There must be an appropriate records series approved for agency use The records must be designated NON-ARCHIVAL
Archival Records are NOT to be destroyed! An agency may scan any archival record and then transfer the paper to the Archives for appraisal and selective retention AND arrange for transfer to the digital archives for preservation of the images
Scan and Toss Archival Board Meeting Minutes Board minutes are still approved and signed in hard copy After approval, scan in according to requirements call the Archives for an appraisal decision regarding the paper based records Package up all the related digital records along with images Prepare for transfer Transfer to the Digital Archives for archival preservation
Let the imaging begin The imaging process should be guided by requirements in WAC 434-663-325 : Capture a complete and accurate image of each source document It is critical that an agency develop and document written standards and consistent processes for imaging so that everyone is doing it the same way
Vendors need to know WAC 434-663 requirements apply to images produced by vendors, too! Make sure any vendor you are using knows they need to also abide by the same rules and requirements Make sure obligations to do so are included in contract negotiations, including legal custody
Just in case If the contract terminates, all imaged records and metadata must be returned to the agency in an accessible format Agencies should apply appropriate mitigation strategies to ensure they can fully recover records and metadata that have not met required retention periods
At the beginning - QC Quality Control needs to start at the beginning to ensure complete and accurate capture: Both sides are captured if double sided No lines, bent pages or bent corners Scanning all textual documents at 300 dpi ensures you are meeting minimums Comparisons (individual visual check of each document or batch checks?
More QC Specific quality control procedures may include, but are not limited to: Enhancements or other manipulations of the images (such as de-skew, de-speckle, etc.) which may be employed to improve the quality of the resultant image Routine use of scanning targets to verify configuration settings
Check and check again Periodic checks that the indexing/metadata is appropriate and accurate. You do not want to have to re-do thousands of images! IF a complete, accurate and legible capture of the source document s content cannot be obtained, the image should be labeled or tagged as best scan possible AND the original paper based record is to be kept for the length of the retention requirement
Format can matter Records with retention requirements less than 6 years can be imaged with an acceptable lossy or lossless format such as PDF, PDF/A, JPEG, or TIFF
Good candidates for scanning and tossing 6 years or less Any Non-Archival records series are eligible, here are some good candidates 6 years or under: Financial records general General administration/working files Maintenance/routine operations/food service Some student records** Some HR/Payroll files** **Some records are long term and have to be handled differently
Long term records Due to the rapid changes in technology both hardware and software, agencies must plan their processes to ensure long-term access and retrieval of images for the entire length of the retention requirement
Predicting the future Planning for future access requires making choices based on stability and longevity (hard to do with technology) Remember when? Cassette tapes 8 track tapes CD s
Long term records and imaging Records with retention requirements more than 6 years must be scanned using a lossless data compression format (e.g. TIFF Group 4, PNG, or GIF)
Insurance policy AND for certain long term records not a bad idea to consider MICROFILM (yes, microfilm) Microfilm is very stable (think hundreds of years) and technology independent
Images and film It is an economic and stable choice for long term preservation (think insurance policy) Microfilm can be generated easily from images In the event of a disaster, images can be written from film for restoration and access
Consider the future Any imaging project should be planned and future needs taken into consideration Look at the type of record Look at how long you need to access and retrieve images
More planning for the future Do a business process analysis and create conventions and file/directory structures to facilitate organization and access now and in the future
Possible candidates Long term records These records are also eligible for scanning and tossing as long as you plan and prepare for worse case scenarios: Official student records Personnel records (long term) Retirement verification records And consider microfilm security back-ups as disaster insurance for these records!
Access and Retrieval Agencies should develop appropriate business and recordkeeping metadata in order to identify, access and manage in the future Which agency/business unit Common identifiers (i.e. Minutes, resolutions, ordinances) Disposition Authority Number (DAN) Retention and disposition requirements
An ounce of prevention Establish security protocols Designate approved users Do regular system checks Perform check sums and error checking Develop disaster plans Generate regular backups which are securely stored at least 50 miles away offsite to enable access to and recovery of the images in the event of a disaster
More planning and prevention Incorporate record images into the records management system Ensure that images are authentic and accessible for their entire required retention period Plan for migration to future systems and formats, plan for obsolescence and failure
Disposition and Destruction Images are subject to the same rules for records management, public records requests or litigation holds Do not destroy images if open records request or litigation hold in place Make sure images are destroyed at the end of their required retention periods in accordance to approved records retention schedules (WAC 434-663-615)
Disposition is a verb Be proactive Practice defensible disposition! Document destruction of the paper based records after verifying image capture AND Document destruction of images once retention has been met
Available online Requirements for the Destruction of Non-Archival Paper Records After Imaging http://www.sos.wa.gov/archives/recordsmanagement/ DestructionofPaperRecordsAfterImagingScanning.aspx
You are not alone Questions? recordsmanagement@sos.wa.gov Thank you! Washington State Archives Partners in preservation and accesss