"Ha! Jeff! You are always so kind!
A great point you make about keeping the "inked" copy of ELs (and Waivers, for that matter). For contractual documents such as that, particularly when they cover fiduciary issues, the imaged copy is more…"
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Patricia S. Brackin
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PCI DSS COMPLIANCE
2 Replies
17 CFR 257.2 9(b) requires 3 year retention of credit card authorizations. Under the new PCI Data Security Standards, we are under pressure to destroy these records as soon as they are no longer…Continue
Started this discussion. Last reply by Patricia S. Brackin Aug 18, 2010.
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Julie J. Colgan, CRM replied to Patricia S. Brackin's discussion RETENTION OF CERTIFICATES OF DESTRUCTION in the group Legal
Jeff Lewis replied to Patricia S. Brackin's discussion RETENTION OF CERTIFICATES OF DESTRUCTION in the group Legal"Julie -- You always answer before I can and in a better way than I could. The only caveat I would add to scanning engagment letters is you may want to keep the originals as sometimes a judge will require the original signature. I have heard this in…"
Patricia S. Brackin replied to Patricia S. Brackin's discussion RETENTION OF CERTIFICATES OF DESTRUCTION in the group Legal"Yes, Julie. I agree that, when feasible, anything to be retained permanently should be scanned to the firm's document management system. Like you, I'm uncomfortable with the long-term viability of removable media."
Julie J. Colgan, CRM replied to Patricia S. Brackin's discussion RETENTION OF CERTIFICATES OF DESTRUCTION in the group Legal"No problem Patricia. Your response made me giggle a little ... so what do you do with the Certificate of Destruction for the Certificates of Destruction that your colleagues were proposing be destroyed ...? :)
And to Christie's comment about…"
Christie Narver, CRM replied to Patricia S. Brackin's discussion RETENTION OF CERTIFICATES OF DESTRUCTION in the group Legal"I agree with Julie, life of the 'firm'. Scanning them onto a CD is an alternative to keeping the paper copies. We seem to be doing more and more scanning of our 'permanent' documents.
Christie Narver, CRM
Rutan & Tucker, LLP"
Patricia S. Brackin replied to Patricia S. Brackin's discussion RETENTION OF CERTIFICATES OF DESTRUCTION in the group Legal"Thanks, Julie; that is what I thought as well. The question had come up in our department, and there were some who felt they could be disposed of 3 to 7 years after the records were destroyed."
Julie J. Colgan, CRM replied to Patricia S. Brackin's discussion RETENTION OF CERTIFICATES OF DESTRUCTION in the group Legal"Hi Patricia, in my experience, CoDs are kept as "permanent" records. In the event you are ever asked to produce a record that has been destroyed (by a client, in response to a subpoena, etc.), you need proper documentation proving it was…"
Patricia S. Brackin added a discussion to the group Legal
RETENTION OF CERTIFICATES OF DESTRUCTION
How long should Certificates of Destruction be retained after the related records are destroyed?See More
Patricia S. Brackin replied to Patricia S. Brackin's discussion PCI DSS COMPLIANCE"Thanks, Jennifer; that is essentially what we have decided to do. What company do you work for?"
Jennifer Walker-Ostertag, CRM replied to Patricia S. Brackin's discussion PCI DSS COMPLIANCE"I consider retaining records for the time recommended by the CFRs that a company is regulated by a valid "business purpose", and I will recommend that my company retains these for three years (after which they are "no longer needed…"
Patricia S. Brackin posted a discussionPCI DSS COMPLIANCE
17 CFR 257.2 9(b) requires 3 year retention of credit card authorizations. Under the new PCI Data Security Standards, we are under pressure to destroy these records as soon as they are no longer needed for business purposes. I'm curious to see what retention policy is being used by other large enterprises.
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