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SOX is the Reason to Archive with Microfilm

Sarbanes-Oxley Act
Section 802

SEC. 802. CRIMINAL  PENALTIES FOR ALTERING DOCUMENTS.

(a) IN GENERAL- Chapter 73 of title 18, United States Code, is amended by adding at the end the following:`Sec. 1519. Destruction, alteration, or falsification of records in Federal investigations and bankruptcy. `Whoever knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States or any case filed under title 11, or in relation to or contemplation of any such matter or case, shall be fined under this title, imprisoned not more than 20 years, or both.`Sec. 1520. Destruction of corporate audit records.

Most IT managers would tell us that the only way to archive your records is to back-up on tape or disk drives. When you consider the implications of lost data how long you (firm, office) are responsible to keep much of your corporate records, you’re chosen long term archival media system needs to be thoroughly evaluated.

Destruction, Alteration and Falsification

If you store legacy records on paper in files, how easy is it to miss-place a single page, replace an existing page with a new page or eliminate (destruction of some method – i.e. shredding) a file from a record completely.

 Corruptibility and Backwards Compatibility

While the idea of a digital back-up of your records seems safe enough, have you recently tried to open a CD or USB type media device that is 10 years old or older?

CD/DVDs are still vulnerable to data loss due to disease and damage. USB type portable devices can be corrupted during the importing/exporting process.

Technology continues to march forward at an ever quickening pace. Platforms are changing every 2-4 years which makes backwards compatibility very “iffy”. It’s not good business practice to assume that you can easily and reliably access back-up data on a disk-drive from as recent as 6 years ago.

Reliability of Tape Backups– A survey of IT executives on tape backup solutions reported these findings:

Gartner Group estimated that 10 to 50 percent of all tape restores fail. Storage Magazine and Gartner reported that 34% of surveyed companies never test a restore from tape, and of those that do test, 77% experienced tape backup failures.

  • 75% of respondents indicated that their companies suffered unrecoverable loss of corporate data they thought was successfully backed up to tape due to unreadable, lost or stolen media.
  • 63% said they encountered unreadable tapes when they tried to retrieve data with 76% of those cases reporting a direct impact to their business from loss of productivity to punishments for regulatory compliance infractions.

Every digital media is vulnerable to some type of corrupting influence. Anyone who has participated in a large conversion process from an older digital format to a more contemporary version knows the pitfalls. It is very likely that some (if not all) of the data will be corrupted and lost during the conversion process.  And data conversion is very costly.

Trusted Long Term Archival Platform

Archiving your business critical data to microfilm is still the most dependable and trustworthy solution for long term records storage. Altering a roll of film is difficult and obvious. Anyone can see if a roll of film has been spliced. The cost to archive a single image to film costs about $0.03 each and storing a roll of film costs about $1.50 per year.

A single roll of 16mm, 215’ microfilm can store more than 2 full bankers’ boxes of records. Properly filmed, processed and stored microfilm has a life expectancy (LE) of 500 years. And ultimately, you need only a flashlight to view the documents.

How Redaction works for the Public Record (Recorders, Registers, Clerks, etc…)

At the state and local level, our elected officials are responsible to manage and make available Public Records. While doing this, they must be aware that some of these Public Records contain Private Information. Think about the volume of land related records your local county office deals with. Every transaction where a piece of land or property changes ownership, a voluminous collection of documentation follows. Title information, mortgage/loan information, historical information such as liens, court information and related documents all have some influence as to the disposition of any piece land or property.

Found within these numerous documents can be found varying types and amounts of Personal Identifying Information (PII) such as social security numbers, dates of birth, credit and bank card numbers, driver’s license numbers and etc. Now, add the additional complexity that web access to these documents is now de facto.  The voting public and private industry simply demand electronic information exchange.

More and more county and state offices are adopting electronic technology to manage their core business operations. Because of this, the inter/intra office, departmental and division communication is becoming more and more electronic based. Document sharing is no longer sending volumes of paper documents, but allowing access via an on-line computer application.

So how does a state/local official comply with current statutes and laws to provide open access to Public Records without exposing individual’s Personal Identifying Information (PII), especially via the web? And the question as to why they would not want to expose the PII should be rhetorical. Considering the current environment of identity theft we all exist within each day, information security is of paramount concern.

The answer is called Redaction:

Redaction is the process of covering over or blacking out specific information within a document. For hardcopy documents, this can be overwhelming task. Each time a person comes into a government office to research and gather information and makes copies of Public Information for personal or private use, the office has the risk that someone will walk out with someone else’s PII.

Or, when county offices receive record requests via snail mail, many offices today still deliver the information via hardcopy documents.

Example of legacy document hardcopy transaction:

  1. Original requested documents are located and photocopied;
  2. PII is redacted from photocopy using a marker of some type;
  3. The redacted copy is photocopied to eliminate the opportunity of bleed-through of original information;
  4. Original copy is re-filed, requested copy is mailed, and original photocopy is destroyed.

For day-forward electronic transactions:

Day-Forward Processing: Using an automated redaction software product

Documents can enter a local government office in a variety of ways;

  • Public Access software (E-Recording) (Simplifile, Ingeo, etc…)
  • Fax
  • Title Company
  • Gov-to-Gov interchange
  • Web Portal
  • Other

As each new document is received in an office:

  1. The document is scanned or received electronically;
  2. Workflow driven process pushes image through an automated redaction product;
  3. Image comes up for manual human review and verification;
  4. Redacted image is electronically copied, creating a “public, redacted” version;
  5. The image follows normal workflow process until final document is verified and made available for view;

The original, non-redacted image remains in-tact while the redacted version is made available for public access.

If you have legacy/historical documents that need to be redacted, you should check with your automated redaction software vendor to see what they suggest. If your legacy documents are still on paper or film, you will need to go through the exercise of digitizing these documents. See my posts on preparing for conversion projects for assistance.

If your documents are already digitized, then your vendor may be able to facilitate your office doing verification of the images they process through their automated redaction software. Your CAPEX would be minimized by doing the verification work in-house.

I would not suggest trying to process all of your legacy documents through an automated redaction software product in-house. Processing millions of images through redaction software is very processor heavy – your office would probably need to purchase expensive servers if you chose to do the entire project in-house.

Is Document Management Still a Viable Market?

Following the “glass half-empty” analogy, many have said that the document conversion and document management industry is nearing its end. “They” claim all the paper in the world has been scanned and every business has already purchased their fancy new EDMS (Electronic Document Management Software) and ECMS (Enterprise Content Management Software).

Well, not so fast. In a recent survey done by Eclipse Group, an international services firm providing document and content management solutions, they found that an alarming number of businesses and organizations today are still heavily reliant upon paper based business critical processes.

Key findings:

  • 75% of companies are still heavily reliant on paper based invoicing processes
  • 67% of respondents are currently sending the majority of their sales invoices by paper rather than electronically using a document management solution
  • 75% of respondents are currently sending the majority of their purchase invoices by paper rather than using a document management system
  • 83% currently have to re-type invoices received into their finance system

The survey, which includes the views of financial professionals from a variety of sectors including insurance, financial services, industrial and automotive, also found that 83% of respondents currently have to re-type invoices into their finance system upon receipt into the accounts departments rather than using a document management system, raising serious concerns over accuracy and efficiency.

Gary Waylett, CEO of Eclipse Group commented, “Given the efficient way most businesses are now able to share information, it is surprising to find so many finance departments are not using a document management solution and continue to re-key data between systems. In addition to duplicating effort, and hence adding cost, re-keying significantly adds the risk of errors which then complicates the reconciliation process.”

So take heart all of you software and services companies, business will be good for years to come.

Government Software Buyer Beware – Avoid Proprietary

This might be better stated as “beware of proprietary image file types”. 

It was during the 1980’s when document management software first impacted the day-to-day business of local government. The ability to convert paper and microfilm images into digital images and then access them on a computer was almost revolutionary. Maybe it was… Initially, document management software vendors created closed architecture applications that relied upon proprietary (non-standard) image file types. Today we would consider standard image file types (not including-Microsoft/Windows types) as, Group IV tif, PDF, JPEG, GIF and etc…

These early developers of document management products competed primarily against themselves for much of this government business. A vendor could produce a reliable product, distribute it heavily and charge just about whatever they wanted for annual support. Vendors locked government offices into long-term support contracts for what seemed like perpetuity.

However, many of these vendors could not or would not keep up with the rapid evolution of technology. The platforms they originally built upon and the development languages they used became obsolete. The document management world began to embrace more standard platforms and languages.

Government offices found themselves locked into early generation document management products that did not deliver as well as new technology. Support costs were high and performance, by comparison, was poor.

So here is where the really big problem came into view. As government offices were deciding to upgrade to new document management technology, they became aware that they could not use their legacy images. Why, because the legacy images were in proprietary formats. These images could only be viewed in the original, now obsolete, software. Converting the proprietary images to standard image formats could only be done by the original vendor, and you guessed it, vendors were charging outrageous fees for these services. The fees required to convert their legacy images many times made the move to new technology cost prohibitive. Eventually, all of these dinosaurs became extinct, right….

Wrong – Proprietary is back and in a big way. There are multiple vendors in the local government market today selling document conversion services bundled with proprietary software. Deals are disguised as exceptionally inexpensive conversion services bundled with the vendor’s proprietary document viewing software. We know that price is always the predominant factor in purchasing at the local government level. However, what has happened now, un-suspecting government offices find themselves in the same predicament as their predecessors 20 years ago. The upfront price to provide the document conversion services seems too good to be true – and it is. Just like in days past, when the government office needs to export their images out of this proprietary environment for other uses, the answer from their vendor is “NO, you cannot have your images”.  These un-suspecting government customers are required to view their scanned images in the vendor’s software or not at all. To have use of the images in another document management system, you will need to pay to have the original documents scanned again.

How to avoid this trap?               

Prior to signing any contract with a document conversion vendor, demand that you receive your images in a standard format that you can use in any system. This will deter most of the proprietary vagrants from trying to lock you and your department into an embarrassing mess.

Beware…

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