As more companies invest in efforts to reduce their paper footprint, we recommend taking into consideration a few key guidelines when moving forward with data conversion initiatives to scan or image paper records.
Initially, a determination must be made on whether the documents are suitable candidates for conversion. There are many reasons why a document should be maintained in paper copy, including:
- Highly confidential/sensitive material that should not be exposed through a digital migration
- Legal requirements to maintain in paper format (e.g., wet signature, dual copy requirements and so forth)
- Evidence of certain important legal obligations or rights (e.g., contracts of certain value, insurance contracts) or legal holds
These examples reflect some of the considerations attendant to digital conversion and demonstrate a mix of practical, legal and business reasons for retaining paper copies. The important takeaway is to confer with the interested stakeholders prior to the scanning effort and reach a consensus on what records should be digitized.
If the scanned document is intended to be the “official” copy, there may be additional requirements in terms of storage. These generally relate to ensuring both the integrity and veracity of the documents scanned. Work with the IT group to assure that once scanned, the digital versions are stored in systems that meet these minimum requirements.
Also, be aware of the fact that some documents may be of transitory nature or consist of content that is not useful and should not be subject to retention. In that instance, those types of documents should be weeded out prior to undertaking the effort of scanning.
Finally, once the scanning is completed continue to keep a pulse on the activity within the different departments for ongoing conversion initiatives. Monitor purchase requisitions and requests for additional storage, whether for additional filing cabinets or off-site storage capacity. This will provide forward notice of paper activity and an opportunity to discuss with stakeholders, in advance, the necessity of keeping the paper versions and alignment with the objectives of the initiative.
Disclaimer: The purpose of this post is to provide general education on Information Governance topics. The statements are informational only and do not constitute legal advice. If you have specific questions regarding the application of the law to your business activities, you should seek the advice of your legal counsel.