Insurance Networking News - September 2011

VANTAGE POINT
Document Management:
When to Shred
How long after
implementing
an electronic
document
management
system can an
insurer get
rid of original
paper docu-
ments? The
answer:
It depends.

Historical and current paper-based business documents must be dig- itally captured to be used with an electronic document manage- ment system (EDMS). Once cap- tured, the question becomes, “What do I do with the paper?” Several options exist, from de- stroying the document to retain- ing the paper. But, is there a hard and fast rule that can always be used? The answer lies in the type of document and industry—specific regulation. There are typically three categories of document retention that I have experienced: 1) The original paper must be kept; 2) You can keep the paper if you want but it is not required; 3) No paper is needed.

By
Abraham
Niedzwiecki

Where to Begin

Find out if the types of documents you are maintaining electronically are regulated by any agency. If they are regulated, these agencies will more than likely have a policy governing document retention and originality. This policy will typically specify whether or not an electronic copy of the document satisfies the “original” document requirement. The ironic thing is that proving the originality of a paper document is much less regulated than proving the originality of an electronic document. When you are dealing with regulated documents, you really have only one choice when it comes to keeping or destroying the paper: Follow the policy of the regulating agency.

Even if the policy dictates the need to keep the paper, using an EDMS has many benefits, from freeing up filing space to rapid retrieval for customer service purposes. The typical scenario (if paper is required) is to create the electronic version, then box up and store the original documents for retrieval if they are ever required. One good practice in this case is to index the documents as they are filed to the EDMS with a “Box Location” code so you can rapidly locate the original paper document in the correct box. This simple step can save countless hours when attempting to locate the paper-based document.

The second type of regulating agency policy typically leaves the decision to maintain paper documents in your hands. With this type of policy it is really your decision whether or not the paper document or the electronic document is the “original.” Once you have made a decision, make it your policy and stick to it.

One thing that will cause you problems is not deciding which document is the original. Maintaining both paper and electronic copies and having no policy as to which document is the original leaves the door open to possible litigation issues and confusion within your organization. A best practice for this scenario

is to clearly define a company policy stating which document is considered the legal original. Once that is done, get rid of the paper if the electronic copy is the chosen format. Ensure at least one good data backup is completed before destroying the paper copy.

The third type of policy is the easiest to implement. It has only a subtle difference from the second type. No need to keep the paper and no need to worry about whether or not some regulatory agency will require the original. In this method, the paper documents are put into the EDMS and then destroyed. The main thing is to ensure you have a reliable backup of your data and documents prior to destroying the paper documents.