Keep your Data Map updated.
If you have paper and electronic, you need to keep the source—electronic. But, if you write anything on the paper, then the paper report becomes a unique document, so you must keep it.
MS Access DB may have to be provided, BUT ALSO reports may have to be run and provided, as these reports may use computations and data combinations, which makes them unique.
MS Excel spreadsheets also give formula information, unlike a paper report from it.
Encryption has to be selective. One company used a single encryption key and had to share that key, which allowed reading all their data, not just what was asked for.
A company must show that it exerted complete control over held documents, by showing restrictions to access, so that the data was not changed.
Data on portable devices is a problem. Get it off these gizmos.
For those people who have hold documents, put RED FLAGS, so that if they try to get a new PC, laptop, that the data on the old one is not destroyed or compromised.
Have documented, enforced, and monitored rules regarding email access and downloading You may end up searching for hold documents on numerous portable devices.
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