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Does the SEC restrict which type of archiving media we can use?

Dorian Cougias EXPERT RESPONSE FROM: Dorian Cougias

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QUESTION POSED ON: 18 August 2004
Do governing bodies like the SEC still restrict which types of archiving media we can use in order to stay compliant?

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EXPERT RESPONSE
No, and they never meant to in the first place. Remember to check all of the final rules on regulations, as well as the commentaries (and responses to the commentaries in the final rule) and you'll see that the regulators don't really care which media is used, as long as the principles of availability, integrity, confidentiality and accountability are met. These principles were outlined long ago in NIST 800-33 by Gary Stoneburner and should serve as a bellwether guideline as to whether or not your media is capable of withstanding the pressures of a preservation order audit.

Also, turn to standards bodies such as ISO and NIST for guidance on media selection because it becomes very important down the road in the Disposition Authority document you'll have to create. Remember, there are going to be records you have to maintain that are going to outlive any media that you are using today (name a hard drive that has lasted over 10 years, or an optical or tape format that has lasted that long, other than DAT, and I don't know anyone who has DAT drives in their tape libraries anymore).

The questions that the auditors will ask you is whether or not the media serves the purpose of good faith retention (does it meet the NIST 800-33 guidelines), and how you are going to handle continuing retention through transfer of media, etc. while preserving the integrity of the archive index.


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