Policy Memorandum on Optical Storage of Public Records PM 96-1 (Updated June 5, 2001)

Under the terms of KRS 171.660, the Department for Libraries and Archives is directed to establish rules and regulations governing use of optically recorded images and the circumstances under which original, manual, eye-readable copies of imaged documents may be destroyed. As mandated by KRS 171.420, the State Archives and Records Commission is directed to advise the department on matters relating to archives and records management. Because optical storage technologies are evolving so quickly and because the challenge of managing those recordkeeping technologies over time is substantial, the department is issuing the following policy statements. The commission has reviewed and evaluated this memorandum and fully supports its provisions and implementation.

1. Public records which are either, (1) scheduled* as permanent or, (2) whose vital retention status is greater than ten years, must have manual, eye-readable counterparts.
   

   State agencies desiring to maintain optically recorded public records in either of the above-named categories without manual, eye-readable backups may petition the Director, Public Records Division, for relief from this responsibility. The Director will ask the agency to demonstrate in writing the following elements in their imaging procedures:

1. Accuracy and Completeness of Records.
   A process of inspection must be in place to confirm that imaged documents are legible and that no corners of the original documents were folded or obscured during scanning. This process should include systematic quality control and audit procedures, as well as operational oversight by staff with detailed knowledge of the process or system used to produce the records.
   Resolution and use of gray scale should be appropriate to capture all needed detail within documents. Similarly, scanned images must capture all colors represented in the original documents which are needed to interpret or understand the meaning of the original. The accuracy of the indexing process must also be assured through procedures that visually verify indexes after they have been keyed or created through optical character recognition.
2. Maintenance and Retention of Documentation.
   Full and up-to-date process or system documentation should be maintained throughout the life of the records in question. Where processes or the system changes, documentation of processes must be retained until the retention periods have been met. Documentation should conform to standards established for documentation in the Kentucky Department of Information Systems' published Systems Life Cycle Manual.
3. Audit Trails and Security.
   Audit trails documenting who accessed or used the system, when they used it, and what the results of use were must be maintained. Security measures consistent with guidelines and standards provided in Kentucky's IT Enterprise Architecture and Standards should be adopted and applied.
4. Access to Records.
   Records maintained in imaging systems must meet all access requirements defined by Kentucky Revised Statutes or administrative regulations.
5. Backup.
   A backup copy of all image files and indexes must be created at intervals determined by the frequency of update and the criticality of the imaging system, as established by the creating agency. Kentucky's IT Enterprise Architecture and Standards and Department of Information Systems guidelines relating to backups and disaster recovery should be used to determine the frequency and means of backing up imaged records. Agencies should contact DIS directly for copies of these guidelines. Off-site backups of permanent and vital records must be maintained.
6. Equipment Maintenance.
   An effective maintenance program ensuring that scanners, optical disks, and magnetic storage devices are properly housed and regularly maintained must be in place. Equipment maintenance logs should be kept to document the occurrence of regular maintenance.
7. Training Programs.
   Staff employing imaging systems must receive formal training in system use to ensure that standard procedures are routinely followed and that the record or official status of system contents is broadly accepted.
8. Compression Algorithms.
   All images should be stored in or convertible to compression formats identified in the IT Enterprise Architecture and Standards. Currently, the standard requires use of, or an ability to convert to, CCITT Group IV.
9. Migration of Data.
   Migration paths for all records, including those stored off-line, must be identified and employed to ensure usability of public records throughout their retention period.
   If the above conditions are met, the Director, Public Records Division, will provide written authorization for the petitioning agency to maintain records solely in optical format(s). Periodic review of compliance with these standards will be performed by, or on behalf of, Department for Libraries and Archives staff.
2. Transfer of optically stored public records to the State Archives may only be made when agencies have strictly adhered to the IT Enterprise Architecture and Standards and in those cases where agency recordkeeping systems allow relatively simple transference or export of usable records.
   Both of these policies should make agencies consider the economies of maintaining records in manual formats for ultimate transfer to the archives or for creating microfilm copies of records early in their life-cycle.
3. Optically stored records whose retention period is less than permanent or without vital records retention status of greater than ten years may be maintained without hard copy, eye-readable originals.
   Agencies are strongly advised, however, that meeting the criteria described above under policy statement I is critical to the acceptance of the records as valid documentation of agency transactions and is required for the legal admissibility of public records. Agencies should be further advised that records subject to audit are auditable regardless of format and that these criteria will be used by the State Auditor in evaluating the content of imaged records.

"Schedule" refers to a records schedule formally approved by the State Archives and Records Commission. This schedule provides the agency its only authority to legally destroy public records, in any format. Vital retention status is a designation given certain critical records whose loss would preclude an agency's immediate return to operation or which protect the rights of individuals or groups or document the obligations and transactions of public agencies.