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Electronic Information Records Management Questions and Answers - Section 112
Question 1 Electronic Notes?
How long may/must I keep the notes I receive by electronic mail?
You need not keep them at all. Retention is the responsibility of the originating department not the recipient However, if you do keep the message, you may not keep it longer than the established retention time. Most messages that are sent by electronic mail are "short-term'' records. Once they have served their purpose, they should be destroyed. Notes that are not "short-term" records must be transferred to an appropriate Tiling system (see question 5). Thus, it Is preferable to discard or file messages on a note-by-note basis. At a minimum we recommend quarterly cleanup.
Question 2 My Messages?
How often should I delete a copy of the messages I have sent to other people?
Messages that are "short-term" records should be deleted note-by-note when they have served their purpose. If this cannot be done, we recommend a quarterly cleanup as a minimum. Notes that are not "short-term" records should be transferred to other media (see question 5).
Question 3 "Short-
Term"?
How can I tell if a message is a "short-term" record or not?
Generally, a "short-term" record has three characteristics:
A. It does not fall into any of the categories of documents with specific retention times, in the Dow Records Management Manual.
B. It is intended to be acted upon, or otherwise serve its purpose, in a rather short period of time.
C. Once it have served its purpose, there is no business need to keep it, and no legal requirement to keep it
EXAMPLES: meeting notice, a note saying to return a telephone call, or a draft that will be revised.
Question 4 Ownership?
Do electronic messages belong to the individual employee?
No. Messages sent by Dow electronic mail systems are Dow property. This is the same policy as for other Dow Records.
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Electronic Information Records Management Questions and Answers - Section 112, Continued
Question 9 E-Mail deletes?
If I delete a document from electronic mail, is ft really gone?
After a time, yes. Many computer records, including electronic mail are "backed up" periodically and continue to exist for a time even if you delete the message from your electronic mailbox Backup copies are destroyed periodically, on a schedul that varies from one Dow computer system to another. If you need to know the backup policy for a specific system, contact your Information Systems representative.
Question 10 Audits?
How often will I be audited? Who will audit my electronic records?
Those decisions are made by your management. However, the Records Management Committee recommends the following as a minimum audit policy:
A. The Records Management Coordinator for the site or function has primary responsibility for auditing. As a minimum, each year audits should be conducted for a representative sample of employees, plus each employee who ceases employment in the function/site over which the coordinator has responsibility.
B. The Coordinator should have the specialized expertise to audit electronic records, or should obtain the assistance of a qualified expert.
C. The audit of electronic records may, but need not, coincide with an audit of paper records.
Question 11 Draft Documents?
If I create a draft document in electronic media and later I revise the draft, what is the "starting date" for records retention?
There are two documents to discuss: the draft copy and the final document.
The draft has its own retention as a "short-term" record. When you revise it, the draft normally should be destroyed because it has served its purpose. Some computer systems do this automatically; others keep one or more past revisions unless you specify otherwise.
As for the revised (final) document, the "starting date" for records retention is the date written in the document Many computer systems will also have a "directory" with a date. The directory date is Qoi the controlling date for records retention, but may be used if it is consistent with the date written in the document. As long as the year is the same, there is no problem for documents whose retention is one year or more.
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Confidential business information "Restricted for Use Within Dow"
Confidential business information "Dow Confidential Information"
This classification is for records whose disclosure outside Dow might not harm Dow, but the information has not been made public. You may use this classification under the following guidelines:
a. Marie the note 'Restricted for Use Within Dow".
b. Unless a secrecy agreement is in place that
covers these records, you must obtain the permission
of the department responsible for the information
before sending the message to anyone who is not a
Dow employee. This includes:
(i) a contractor employee, even
if
that person is working on Dow projects.
00 an employee of a Dow subsidiary or Dow-
associated company.
This classification is for records whose disclosure to
the public would harm Dow - - for business reasons,
legal reasons, or any other reason.
EXAMPLES: the specifications for process equipment, the formula for a product, or marketing plans.
These records may be sent by electronic mail, but onlv to Dow emolovee who need to know. Please
observe the following:
a. Unless a secrecy agreement is in place that
covers these records, you must obtain proper
clearance, including Legal Department or Patent
Department approval, before sending the note to
persons other than Dow employees. This includes:
(0 a contractor employee, even
if the
person is working on Dow projects.
00 employees of Dow subsidiaries or Dow-
associated companies.
b. If you use a standard 'mailing list", check first to
see if everyone on the list has a need to know this
information.
c. Double-check the distribution to assure that the
message is going to the proper persons. Is anyone
forwarding his/her electronic mail to a person
(including a supervisor, a co-worker, a subordinate or
an office professional) who has no need to know?
d. Mark everv Daae of the note "Dow Confidential
Information."
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Question 13 Records on Disk? (continued)
C. Undated disks. Each document stored on a disk must be dated. We recommend that d date also be put on the disk itself. That will help you know whether the documents on your disk are still within their retention time.
D. Disks with documents that do not all "expire* at the same time. Remember that when a document reaches the end of its retention time, it must be destroyed.
That can be difficult if the disk also contains other documents that have not expired. There are two options:
1. Don't "mix" records on your disk. Store only one type of record on your disk (so that all documents are kept the same number of years). Then start new disks every year. When a disk expires, destroy all the documents on it. This requires more time "up front', but save time during the annual review of records.
2. If you go store records with different expiration dates on a single disk, you must review that disk at least annually to see if any documents have expired. Destroy any expired documents in one of the three Dow-approved ways. If your computer system cannot overwrite specific files, you probably will have to copy off 'current* documents onto a new disk, then destroy or overwrite the old disk.
E. Disks that contain proprietary information, but are not properly secured. A documents is subject to the same security requirements, whether it is written on paper or stored on a disk. Thus, a disk must be protected according to Dow policies for the most confidential document it contains.
F. Disks that Travel" with an employee to a new job. Documents are 'owned* by the function or department where they were created - not by the individual employee. If a transferred employee's new duties do not include the subject matter of those documents, someone else must assume the responsibility for keeping them until they expire.
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