Version: 10/10/07
1. Introduction and Purpose
The purpose of this document is to provide guidance from the SCEIS project
to state agencies on document retention, in light of the paperless nature of
SCEIS. A major factor in the SCEIS project’s cost justification is
elimination of paper throughout state government. Therefore, it is an
important objective of the project to achieve a substantially paperless
environment in state agencies as they go-live with SCEIS. This includes a
transition to retention of electronic documents instead of hardcopy files to
meet document retention requirements. SCEIS supports these goals in several
ways. SAP will replace many types of paper documents that currently exist in
government processes with online documents. SCEIS solicitation/award
processes will be conducted online in a paperless fashion between the state
and many of its vendors. SCEIS imaging enables conversion of the remaining
paper documents into electronic document images at the earliest possible
point in an agency’s business process.
This document provides guidance to agencies on document retention as they
migrate to SCEIS and explains the framework within which the state
government will make this transition.
2. Scope
The scope of this guidance includes documents that are part of SCEIS
business processes for agencies in Phase 1. An update of this document is
expected for subsequent phases. Section 3 provides specific guidance to
agencies. Sections 4 and 5 provide background information that is relevant
to the guidance. It is provided to help facilitate understanding and
informed discussion within agencies.
3. SCEIS Guidance to Agencies for Phase 1
Agencies do not need to take any action for retention management of
electronic documents in the SCEIS environment. These documents will be
retained by SCEIS on the CIO infrastructure, with no plans for destruction.
They will be stored on SAN storage at the CIO, backed up to tape and stored
offsite in accordance with backup/recovery policies. A comprehensive
retention management plan will be established in the future for scheduled
destruction/retention of SCEIS electronic records, in collaboration with
agencies, SC CIO and SCDAH. Agencies should retain
paper documents after they have been imaged into
SCEIS, according to each agency’s current retention management plan. This
policy will remain in place until further guidance from SCEIS. Documents
that were in paper form prior to SCEIS, which are in electronic form in the
SCEIS environment, should not be printed for filing purposes or retention
management purposes. This guidance is expected to remain in place for at
least 6 months, to allow agencies to develop a level of comfort with the
SCEIS environment. Agencies should consult with the SCEIS project if they believe that there
are electronic documents that they must print and retain in hardcopy form in
order to comply with South Carolina or Federal government requirements.
SCEIS will help facilitate consultation on electronic records. It is
important to examine each requirement closely with intent to adopt a
paperless environment wherever possible. Agencies should consult with the SCEIS project if they find themselves
printing paper documents for convenience. SCEIS will provide process
consultation to help reengineer agency processes to make effective use of
the SCEIS environment.
4. “Documents” in the SCEIS Environment
Different forms of documents are part of the SCEIS environment. These forms
are technical distinctions that are important to the topic of retention
management.
- SAP Documents
SAP documents are created within SAP when an SAP transaction is performed.
SAP documents are electronic, reside in the SAP system and have an SAP
document number assigned. Imaged Documents Imaged documents are created by scanning paper documents into the SCEIS
imaging system or importing electronic files into the SCEIS imaging system.
Imaged documents are “attached” to SAP documents during the business
process. After they have been attached to an SAP document, they can be
retrieved in the “attachment list” of the SAP document to which they are
attached. Imaged documents reside in the SCEIS imaging system; therefore,
they can also be retrieved directly from the imaging system outside of SAP.
(Note: Access to imaged documents outside of SAP is only available for
certain procurement-related documents by ITMO and MMO in Phase 1A).
Paper Documents Paper documents are received by agencies from external sources (e.g.
vendors) and may occasionally be produced by agencies. SCEIS converts paper
documents into imaged documents at the earliest possible point in the
business process. After paper documents are imaged and attached to SAP
documents, they are no longer needed for the business process in the SCEIS
environment. Electronic Document Files Electronic document files are created outside of SAP (e.g. word, pdf, etc)
and are “attached” to SAP documents during the business process. After
document files have been attached, they can be retrieved from the
“attachment list” of the SAP document to which they are attached. In
contrast to imaged documents, document files that are attached to SAP
documents without imaging reside in the SAP system; therefore, they can only
be retrieved through SAP. This form of document is limited to the SRM module
in SCEIS Phase 1. Relationships of Different Forms of Documents
5. Framework for Electronic Document Retention
A framework is in place to allow paper documents to be permanently disposed
of and electronic documents used to meet document retention requirements. It
is each agency’s responsibility to review its retention management
requirements and adopt the guidance provided by SCEIS, or implement
modifications according to need. The retention management framework consists
of several components, as follows: SCEIS Processes SCEIS uses electronic documents instead of paper documents in the execution
of business processes. SCEIS business processes involve exchange of
information within agencies and between agencies; thereby, making electronic
documents the document-of-record for audit and retention purposes. Most
documents originate in SAP and are stored as electronic documents without
ever becoming paper documents. For documents that do originate in paper
form, SCEIS imaging converts paper to electronic form at the beginning of
the business process. SCEIS imaging also enables agencies to convert
historical paper files into images, and use those images going forward after
SCEIS is implemented (e.g. contracts, grants).
SCEIS Technical Infrastructure SCEIS’ computer infrastructure is in place for storage, security and
backup/recovery of SCEIS electronic documents. The infrastructure is managed
by the Budget & Control Board, Division of the State Chief Information
Officer. South Carolina Department of Archives and History
(Refer to: Public Records Information Leaflet No. 13, “Public Records Stored
as Digital Images Policy Statement,”
http://www.state.sc.us/scdah/lflt13.pdf
) South Carolina Department of Archives and History allows electronic
documents to be stored instead of paper documents to meet document retention
requirements, provided certain requirements are met. It is an agency’s
responsibility to verify that electronic images are accurate representations
of the original document. It is also an agency’s responsibility to fill-out
and submit a form notifying SCDAH before paper documents are destroyed. For
long term retention, SCDAH recommends auditing images once a year and
migrating electronic documents to a new storage media every 10 years. This
recommendation is in concert with the CIO Architectural Oversight
Committee’s standards for electronic document management.
South Carolina Uniform Electronic Transaction Act (UETA)
(Refer to: South Carolina Code of Laws, Title 26, Chapter 6,
http://www.scstatehouse.net/code/t26c006.htm
) UETA facilitates electronic commerce and electronic government services by
legally placing electronic records and signatures on equal footing with
their paper counterparts. UETA places responsibility with agencies to determine their use of and
retention policies for electronic documents.
SECTION 26-6-170. Creation and retention of electronic records by government
agencies.
Each governmental agency of this State shall determine if, and the extent to
which, it will create and retain electronic records and convert written
records to electronic records.
UETA places responsibility with Budget and Control Board to adopt standards
to enhance the utilization of electronic records by public entities of the
State.
SECTION 26-6-190. Development of standards and procedures; service of
process.
(A) The South Carolina State Budget and Control Board shall adopt standards
to coordinate, create, implement, and facilitate the use of common
approaches and technical infrastructure, as appropriate, to enhance the
utilization of electronic records, electronic signatures, and security
procedures by and for public entities of the State. Local political
subdivisions may consent to be governed by these standards.
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