CAUBO Imaging: Document Management & Workflow June 26, 2007 - Charlottetown, P.E.I.

CAUBOImaging: Document Management & Workflow

June 26, 2007 - Charlottetown, P.E.I.

June 26, 2007

Panelists

> Germain Tremblay, Director Finance & Awards Administration, NSERC/SSHRC

> Ken Chasse, Barrister & Solicitor - eVida Group

> Mary Anne Rait, System Administrator, Financial Services, Ryerson University

> Peter Gee, Assistant Director, Financial Services,

Ryerson University

June 26, 2007

AGENDA

• Introductions

• Ryerson Journey (Gee)

• Imaging System – Overview & Demonstration (Rait)

• Document Management and Workflows - NSERC SSHRC Comments (Tremblay)

• Imaging & Electronic Records – The Legal Issues (Chasse)

June 26, 2007

Background - What’s Happening?

• 1980 - European Commission predicted that by Year 2000, 50% of all business documents would be delivered electronically

• YES - For memos & informal communications.

• NO - For financial documents.

June 26, 2007

Background - Purchase to Pay (P2P)

• Despite increasing interest & adoption of solutions to automate Purchasing, AP & AR processes, enterprises of all sizes are burdened by PAPER.

• Institute of Accounts Payable Professionals (IAPP) - on average 13% of invoices received are electronic.

• Gartner Research > 90% of invoices are paper based.> 80% of B2B payments in North

America are made by cheque.

Invoic ing Methods

91%

9%

Paper

Electronic

June 26, 2007

Background - AP Benchmarking

Average AP Department in a $1 Billion Company• Corrects 5% of supplier invoices because of errors,• Has 12 FT staff for every manager,• Utilizes 2 applications/systems for AP,• Uses WEB technology primarily for Requisitioning,• Processes 250,000 invoices annually,• Average time to process an invoice is 12 days,• 1 in 5 invoices has a problem that delays processing and increases

administrative costs (can be 50%),• 25% of invoices are paid late.

June 26, 2007

Basic Truism• Less paper and more e-invoicing is a characteristic of a world class

company (Hackett Value Grid)

• Why ?? Electronic workflow for invoice review and approval provides> Access to timely and accurate financial information

> Cost savings

> Improved vendor relationships

• Asked which medium they trusted more, 52% of AP departments thought electronic data was likely more reliable. This is a judgment on the ease of processing

June 26, 2007

Demand for P2P AutomationSource: 2007 Institute of Management & Administration (IOMA) AP Benchmark Study

• 41% of AP departments planning to add e-invoicing capabilities in 2007 – Doubles since 2005

• Over 70% of companies already use e-payments or are planning to use them in 2007. However less than 25% of all B2B invoices are paid electronically.

• 36% plan to add invoice imaging

June 26, 2007

Initiatives to Eliminate Paper

• EDI: moderately successful in industries where they are used to exchanging invoice and purchase order data. Lack of standards and cost of participation have hindered wider adoption.

• Purchasing Card Programs: VERY successful for petty cash type transactions as is usually limited to transactions below $1500 because of post. Invoice data from vendors is often lacking.

• Document Management and Workflow

June 26, 2007

Invoice Imaging – The Reality

• Imaging and Workflow now seen as the most useful technologies (Hackett Group - 2005)

• NO silver bullet - imaging technology does not instantly get rid of the paper – need to consider business process.

• OCR is a technology that captures invoice data with reduced manual correction. Then you can> Validate data against information already in the ERP

> Automatically scrub the data with identifiable problems like missing/wrong PO number.

> Deliver cleansed data to the ERP for scheduled payment processing

> Deliver images to archives for referencing

June 26, 2007

Ryerson University• Students:

> 23,000 full time,> 1000 graduate students> 65,000 continuing education registrations

• Financial Systems:> Financial: Oracle eBusiness V11.5.10,> Document Management: 170 Systems Markview V5.5,

• Other Systems> PeopleSoft - Student Administration > Ruffalo Cody – Alumni & Fundraising> Highline - Human Resources/Payroll

June 26, 2007

Audit and Acceptance Issues

• Requirements for retention of original documents is established federally by CRA, provincially by Ministry of Finance and internally by Records Management (Archives) policy

• In Canada, Ontario and numerous other provinces there is already a number of precedences and regulatory bills/interpretations that exist as it pertains to imaging.

• REAL ISSUE - Acceptance of imaging concept is not standardized across all levels of federal and provincial government and agencies. Has not really been considered by many ministries and agencies.

• Corporate - Seek internal corporate approvals for approach, then establish policy, procedures and compliance standards and GO FORWARD date of new policy.

June 26, 2007

Overview of Ryerson Timelines• 170 Systems Contract Signed - April 30, 2004• 170 System Development – May to September 2004• System walk through – September 2004 • TEST Install – September 2004• Preliminary UAT Testing – October 2004• User Training – October/November 2004 (ongoing)• Final UAT Testing – November 2004• TEST Migration to Development – November 2004• Production GO LIVE - December 06, 2004

• Destruction Research November 2004• Attempts to obtain Formal Acceptance Approvals February 2005• Markview System Upgrade - November 2006• eVida Certificate of Compliance - December 2006• Destruction of Originals – scheduled for June 15, 2007

June 26, 2007

Acceptance of Imaged Documents

Basic Principle

If the original paper documentation still exists, then electronic document images are merely copies

Catalyst:> Tri-Council grant review occurred at same time as Imaging Go

LIVE.> CIDA grant monitoring visit (Feb 2005), > Initial reactions indicated some audit discomfort. Recognized

better further explore these uncharted waters.> Chose key agencies to obtain written acceptance - NSERC,

SSHRC, CHIR, CIDA, AUCC, HRSDC, CFI, MEDT

June 26, 2007

Acceptance of Imaged Documents

• Dilemma:> A negative response from any single organization could effectively

negate the positive responses received from others by effectively not allowing the University to fully introduce and leverage the imaging capabilities.

Manuel of Good Practices (November 2003)

> NSERC, SSHRC, CAS (Common Administrative Service)

> Section 2.3 of manual referenced:• Digitizing of Vouchers - UQAM• Digitization of Invoices for Authorization – University of Victoria

June 26, 2007

Existing Canadian InitiativesUQAM Approach

> Additional space (and boxes) was needed to store vouchers for the 7 years required under federal legislation.

> Process was cumbersome - introduced digitization to retain copies of vouchers.

> UQAM obtained necessary authorization from provincial and federal governments.

> AFTER - Once vouchers verified and payment authorized, digitize each voucher and save for future consultation and/or printing.

June 26, 2007

Existing Canadian Initiatives University of Victoria Approach

> BEFORE - AP digitize invoices received and send digitized invoice by e-mail to person placing the order.

> Individual views invoice on screen, ensures it matches goods or services received. Account holder authorizes invoice payment by returning invoice to AP by e-mail.

> Process ensures the recipient actually receives the invoice for authorization, the e-mail being proof, and makes it easy to send reminders to those who forget to authorize the payment.

June 26, 2007

Compliance Requirements Compilation of Responses

• Certification by an independent organization that the Ryerson Document Management & Imaging system complies with Canadian General standards Board (CGSB) standards> CGSB 72.11-2000 - Microfilm and Electronic Images as Documentary

Evidence,> CAN/CGSB 72.34-2005 - Electronic Records as Documentary

Evidence.

• Certificate of Image Authorization – statement from senior management that university relies upon electronic record keeping in the “usual and ordinary course of business.

• Imaging Policy - Electronic Imaging and Document Management (May 17, 2006) approved and issued in accordance with university policy.

• Imaging Procedure manual - Formal procedure entitled “Electronic Images Procedure” draft was August 2, 2006. eVida suggestions were incorporated into Final approved procedures.

June 26, 2007

Elements of Compliance

• Management Authorization & Accountability> Usual & ordinary course of business> Approval by senior management

• Documentation> Sufficiently detailed procedures manual> Evident to all parties and followed – communication, training

• Reliability> Authenticity (of records & documents)> Integrity (of the electronic system)

June 26, 2007

Compliance Report Requirementss

• Ryerson Wanted

> Independent organization to verify compliance with CGSB –eVida Group.

> Organization that understood records management, the legal issues as it pertains to document imaging AND assigned individuals with impeccable qualifications and credentials.

> Formal Letter of Compliance.

> Detailed report with GAP analysis and recommendations on areas that MUST be strengthened.

June 26, 2007

Compliance Report Results• EVida report contained

> eVida Letter of Compliance - statement that Ryerson’s process of converting financial records under the 170 Systems Markview product met national standards:

• CGSB 72.11-2000 - Microfilm and Electronic Images as Documentary Evidence.

• CGSB 72.34-2005 - Electronic Records as Documentary Evidence

> Certification statement that analysis was made in comparison with the National Standards of Canada (CGSB standards). The current system was examined with a view to converting paper records to electronic images, and maintaining all electronic images and associated bibliographic and biographical records, as authentic, reliable and accurate records.

> Detailed analysis report (as of October 31, 2006) with specific areas requiring attention in both our electronic and paper records. Provided recommendations that could further help in maintenance of our process to meet the evidentiary process on the management of records.

June 26, 2007

Compliance Report (eVida Group) • All conversions from paper to images since inception of the 170 MarkView System subjected to a

quality assurance program to verify the acceptable quality of images and recording data in accordance with the requirements of the CGSB national standards.

• For converted paper records, such proof would include evidence that the electronic records have reliably captured their source records. This permits the university to maintain only one set of records (electronic) as the primary source of information and evidence, and allow disposal of paper records once fully captured by the 170 MarkView System.

• IT audit policy to include examination of electronic records as per national standards as a further enforcement of control over the management of records. Introduce audit functions to supplement internal quality assurance procedures to verify process is conducted as per university policy and procedures.

• Records Management (Archive) policies should be altered to reflect new electronic records management practices.

• Key documents (Policy & Procedures) needs to be in place to demonstrate the electronic record system integrity, authenticity of the records, and trustworthiness of your process.

• Scanning operators, AP and other document process review staff trained in regards to “system integrity” requirements of management records.

June 26, 2007

Canadian General Standards Board (CGSB)

CGSB - 10 Points of EvidenceJudging the Integrity of an Electronic Records system.

Handout

June 26, 2007

Ryerson Documentation that Supported

the Recommendation for Destruction of Documents

• Electronic Imaging: Certification & Recommendations (March 2007 -Gee)

• Aird & Berlis Legal Opinion: Legality, Enforceability & Admissibility of Imaged documents (June 2005 – Brooks

• eVida Group Certification of Compliance with National Standards of Canada (December 2006)

• Electronic Records as Audit Evidence memo: Richard C. Kennedy, A/Chief Internal Auditor & Asst. Deputy Minister, Ontario (March 2007),

June 26, 2007

Overview of Support Documentation for the Recommendation for Destruction of Documents

Continued

• eVida Group - Review of Ryerson Financial Record: Certification of Compliance on eRecords of Financial system (Mark View) measured against CGSB Standards,

• eVida Group - Consultant Biographical & Qualifications,• Imaging Policy• Imaging Procedures manual• Certificate of Image authorization by senior Management- “usual &

ordinary course of business”.• IN PROCESS – Alignment of Records Management & Archives

policy

June 26, 2007

Statutory & Legal References

• Canada Revenue Agency (CRA) – Keeping Records (Canada - RC4409),

• Books & Records Retention/Destruction (Canada – IC78-10R3),

• CGSB 72-11-93 Microfilm & Electronic Images as Documentary Evidence

• CGSB 72-34-2005 Electronic Records as Documentary Evidence

• Personal Information Protection & Electronic Documents Act (PIPEDA – Canada Bill C6)

• Evidence Act (Ontario)

• Canada Evidence Act (Canada)

• Electronic Commerce Act (Ontario – Bill 88 2000)

• Records disposition Authority No. 96/023 – Records Relating to Electronic Imaging,

• Archives Ontario – Information Bulletin #6 Electronic Records systems – Recorded Information Management (RIM) Requirements.

Imaging SystemOverview & Demonstration

Mary Anne Rait

June 26, 2007

Ryerson MarkView Solution

• Accounts Payable – workflows to handle:

Non PO Invoice Entry – invoices received with no quoted PO # PO Invoice Entry Pre-Approved Invoice – invoice received in Financial Services

previously manually authorized Previously Entered – rush invoices Invoice Gateway – decentralized entry process which is

validated before imported into Financial System Internet Expense – online expense submission

June 26, 2007

Ryerson MarkView Solution

• Accounts Receivable & Purchasing Automated creation of ‘virtual’ (or rendered) invoices

and automatic faxing and e-mail capabilitiesCreation of document sets – attaching supporting

documentation and identification of documents that must be sent to the customer/supplier

• General LedgerAbility to attached scanned documents to an actual,

budget or encumbrance journalsAbility to associate an image that previously exists

within 170 MarkView to an actual, budget or encumbrance journals

June 26, 2007

Ryerson MarkView Solution

• Records Management

To scan, index, and search documents not associated with Oracle Transactions, including: Insurance, Financial Reports, Contracts, Completed Forms, & Budget documents

June 26, 2007

Benefits on Imaging

• Quicker & More Efficient Document Processing

• Easy Universal Access

• E-Mail Notifications

• User “To Do” Lists (Web Inbox)

• Reassignment of Responsibility when users go on vacation/sabbatical etc

June 26, 2007

Benefits Cont’d• Enhanced Loss Prevention

• Enhanced Security

• Central Electronic Storage, Reduced Filing, Space & Equipment Needs

• Time Saving

• Enhanced document tracking through the use of workflow

June 26, 2007

Benefits Cont’d

• Queue monitoring - Graphic & detail,

• Tightly integrated - Oracle eBusiness suite,

• Audit reports & Quality Verification queues,

• Simplifies year end accruals.

June 26, 2007

Security

• Drilldown from Oracle GL is limited to only those documents that the user can view from their responsibilities.

• User have no access to inquiry from Payables or Receivable modules.

• Documents scanned in are always maintained in Markview.

• Recycle queue maintains a history of documents that were deemed to be duplicates or not required.

June 26, 2007

Challenges• Upfront effort required to ensure scope of project is as complete as

possible, leave nothing to assumptions.

• Communication – communicate well in advance to Users AND continue to update users with changes to processes.

• Know your Users – identify the various key Users with regards to skill set and previous experience with organizational systems

• Processes – review and modify processes. Document and communicate changes.

• Approvals and compliance with standards in order to destroy original paper documents.

June 26, 2007

DEMO I

AP entry and linking of record to image

June 26, 2007

Demo II

Document tracking capabilities

June 26, 2007

Germain Tremblay, Director, Finance and Awards Germain Tremblay, Director, Finance and Awards Administration Division, NSERC/SSHRCAdministration Division, NSERC/SSHRC

Document Management and Document Management and WorkflowsWorkflows

CAUBO Conference – June 26, 2007CAUBO Conference – June 26, 2007

June 26, 2007

OutlineOutline

Expectations – Imaging Expectations – Imaging Control FrameworkControl Framework AuthorizationAuthorization Supporting DocumentationSupporting Documentation VerificationVerification RetentionRetention

June 26, 2007

Agencies’ RequirementsAgencies’ Requirements

Whether a process is paper based or electronic, agencies Whether a process is paper based or electronic, agencies have a number of requirements regarding the management have a number of requirements regarding the management of research funding as specified in the:of research funding as specified in the:

» Memorandum of Understanding (MOU); andMemorandum of Understanding (MOU); and

» Tri-Agency Financial Administration Guide.Tri-Agency Financial Administration Guide.

June 26, 2007

ImagingImaging Agencies’ expectations in terms of imaging Agencies’ expectations in terms of imaging

practices: practices: – Follow industry standardsFollow industry standards

» CGSB;CGSB;

– Scanning should be part of usual and ordinary Scanning should be part of usual and ordinary activities of the business;activities of the business;

– A control system and procedures are A control system and procedures are established and documented; andestablished and documented; and

– Images are of acceptable quality and are Images are of acceptable quality and are legible.legible.

June 26, 2007

ImagingImaging

A system of inspection and quality control is established.A system of inspection and quality control is established.

Ensure that adequate controls are in place that safeguard Ensure that adequate controls are in place that safeguard the accuracy, security and integrity of the data:the accuracy, security and integrity of the data:

» Access controls;Access controls;

» Input and output controls; andInput and output controls; and

» Tampering controls.Tampering controls.

Electronic records must provide a proper trail from the Electronic records must provide a proper trail from the source document (whether paper or electronic) to the source document (whether paper or electronic) to the summarized financial accounts.summarized financial accounts.

Source: CRA, IC05-1 on Electronic Record Keeping, June 2005

June 26, 2007

As outlined in the MOU, the institution As outlined in the MOU, the institution should have in place:should have in place:

policies and procedures:policies and procedures:

– roles and responsibilities definedroles and responsibilities defined

– procedures established and documented; andprocedures established and documented; and

A framework approved by a governing board.A framework approved by a governing board.

Control FrameworkControl Framework

June 26, 2007

Control FrameworkControl Framework

A good control framework will ensure that:A good control framework will ensure that:

all expenses are authorized by the PI, or his or her all expenses are authorized by the PI, or his or her delegate;delegate;

delegation of spending authority is done in writing (must delegation of spending authority is done in writing (must be kept on file and verified); andbe kept on file and verified); and

In addition, for travel expensesIn addition, for travel expenses

– One over one approval One over one approval

June 26, 2007

Control FrameworkControl Framework

Supporting document requirements:Supporting document requirements:

Original documentation must be kept in support of the Original documentation must be kept in support of the expense:expense:– Purchase order, invoice, hiring contract, JV, travel Purchase order, invoice, hiring contract, JV, travel

claims, original receipts, etc.claims, original receipts, etc.– Missing receipts should be documented and approved by Missing receipts should be documented and approved by

the PI.the PI.– Proper documentation in place before expense is paid.Proper documentation in place before expense is paid.

For review purposes, original documentation is required.For review purposes, original documentation is required.

June 26, 2007

Control FrameworkControl Framework

The institution must have a process in place to The institution must have a process in place to ensure that:ensure that:

all expenses are reviewed for compliance and eligibility all expenses are reviewed for compliance and eligibility (must be someone other than PI);(must be someone other than PI);

the review can be performed before the expense is paid, or the review can be performed before the expense is paid, or after; andafter; and

the review can be performed on a sampling basis.the review can be performed on a sampling basis.

June 26, 2007

Control FrameworkControl Framework

Document Retention:Document Retention:

Originals must be retained for seven years after Originals must be retained for seven years after the expense has occurred.the expense has occurred.

Originals should be kept in a central location.Originals should be kept in a central location.

Imaging and Electronic Imaging and Electronic Records – The Legal IssuesRecords – The Legal Issues

By: By:

Ken Chasse, LL.BKen Chasse, LL.BBarrister & SolicitorBarrister & Solicitor

Member of the Law Society of Upper Canada Member of the Law Society of Upper Canada and Law Society of British Columbiaand Law Society of British Columbia

CAUBO Conference, Charlottetown, P.E.ICAUBO Conference, Charlottetown, P.E.IJune 26, 2007June 26, 2007

June 26, 2007

Industry WatchIndustry WatchConfidence Level on Legal Confidence Level on Legal

SubmissionSubmissionSource: 2007 AIIM SurveySource: 2007 AIIM Survey

How confident are you, that if How confident are you, that if challenged, your organization could challenged, your organization could demonstrate that your electronic demonstrate that your electronic information is accurate, accessible, and information is accurate, accessible, and trustworthy?trustworthy?

20062006 20072007

Very confidentVery confident 12%12% 9%9%

Quite confidentQuite confident 23%23% 19%19%

ConfidentConfident 28%28% 26%26%

Slightly confidentSlightly confident 22%22% 27%27%

Not confident at allNot confident at all 12%12% 20%20%

June 26, 2007

Validation of Electronic Validation of Electronic Records Management Program Records Management Program

with Legal Requirementswith Legal Requirements

June 26, 2007

Six Areas of LawSix Areas of Lawapplicable to Paper and Electronic Recordsapplicable to Paper and Electronic Records

1.1. The laws of evidence applicable to electronic The laws of evidence applicable to electronic and paper records;and paper records;

2. 2. National Standards of Canada concerning National Standards of Canada concerning electronic records;electronic records;

3. 3. The records requirements of government The records requirements of government agencies, such as the Canada Revenue agencies, such as the Canada Revenue Agency;Agency;

4. 4. The electronic commerce legislation;The electronic commerce legislation;5. 5. The privacy laws;The privacy laws;6. 6. The guidelines for electronic discovery in The guidelines for electronic discovery in

legal proceedings.legal proceedings.

June 26, 2007

Different Types of Records - Different Types of Records - Different Legal RulesDifferent Legal Rules

1.1. Original paper records;Original paper records;

2.2. Electronic records, Electronic records, i.e.i.e., they are created or , they are created or stored electronically;stored electronically;

3.3. Microfilmed or imaged records;Microfilmed or imaged records;

4.4. ““Relied upon printouts” of electronic records Relied upon printouts” of electronic records within the meaning of s. 34.1(6) of the within the meaning of s. 34.1(6) of the Ontario Evidence Act, and s. 31.2(2) of the Ontario Evidence Act, and s. 31.2(2) of the Canada Evidence Act, For example;Canada Evidence Act, For example;

5.5. Records created through EDI (electronic data Records created through EDI (electronic data interchange).interchange).

June 26, 2007

Legal Tests for Acceptable Legal Tests for Acceptable RecordsRecords

1.1. ““The integrity of the electronic records The integrity of the electronic records system;” system;”

2.2. ““Relied upon printouts” of electronic records;Relied upon printouts” of electronic records;

3.3. ““The usual and ordinary course of business;” The usual and ordinary course of business;”

4.4. ““The circumstances of the making of the The circumstances of the making of the record.” record.”

June 26, 2007

Compliance TestsCompliance Tests for the National Standard of Canada, for the National Standard of Canada,

Electronic Records AsElectronic Records As Documentary EvidenceDocumentary Evidence CAN/CGSB-72.34-2005CAN/CGSB-72.34-2005

• Using this national standard to show that a Using this national standard to show that a records system has the necessary “system records system has the necessary “system integrity” required by the electronic records integrity” required by the electronic records provisions of the Evidence Acts. provisions of the Evidence Acts.

• Section 34.1(8) of the Ontario Evidence Act, Section 34.1(8) of the Ontario Evidence Act, and s. 31.5 of the Canada Evidence Act and s. 31.5 of the Canada Evidence Act provide for the use of such standards.provide for the use of such standards.

• 12 principal groupings of the principles 12 principal groupings of the principles provided by this national standard.provided by this national standard.

June 26, 2007

Avoiding the Consequences Avoiding the Consequences of of Failure to ComplyFailure to Comply

• An inability to take advantage of the two purposes for which the An inability to take advantage of the two purposes for which the electronic record provisions of the Evidence Acts were created:electronic record provisions of the Evidence Acts were created:

(a) electronically-produced records are to have equal (a) electronically-produced records are to have equal status in status in law to original paper recordslaw to original paper records

(b) original paper records can be disposed of once their (b) original paper records can be disposed of once their electronic electronic form is stored in a secure records management form is stored in a secure records management environment.environment.

• A failure to comply with the National Standards of Canada A failure to comply with the National Standards of Canada (particularly (particularly Electronic Records As Documentary EvidenceElectronic Records As Documentary Evidence CAN/CGSB-72.34-2005) will make compliance with the legal CAN/CGSB-72.34-2005) will make compliance with the legal tests for acceptable records much more difficult.tests for acceptable records much more difficult.

• One’s records might not be acceptable to the taxing authorities One’s records might not be acceptable to the taxing authorities of government such as the Canada Revenue Agency of government such as the Canada Revenue Agency

June 26, 2007

Avoiding the Consequences Avoiding the Consequences of of Failure to ComplyFailure to Comply

(continued)(continued)

• The unavailability of essential evidence for important The unavailability of essential evidence for important litigation.litigation.

• An institution’s failure to have its records accepted as An institution’s failure to have its records accepted as evidence may quickly result in its records being challenged evidence may quickly result in its records being challenged in many more legal proceedings, which may cripple its in many more legal proceedings, which may cripple its ability to enforce the legal foundation upon which it exists.ability to enforce the legal foundation upon which it exists.

• An inability to comply with its own records management An inability to comply with its own records management bylaws or similar policies, with the consequences of such bylaws or similar policies, with the consequences of such failure.failure.

• Being in the embarrassing position of requiring records from Being in the embarrassing position of requiring records from other institutions and persons that comply with the laws and other institutions and persons that comply with the laws and national standards for records and information national standards for records and information management, but not being able to do so oneself.management, but not being able to do so oneself.

June 26, 2007

EmailEmailthe Electronic “Smoking Gun” of the Electronic “Smoking Gun” of

CasualnessCasualness

• Email, almost always a casual, informal mode Email, almost always a casual, informal mode of communication, nevertheless creates a of communication, nevertheless creates a record that is more often than not a business record that is more often than not a business record, and is therefore subject to all laws, record, and is therefore subject to all laws, policies, and procedures applicable to business policies, and procedures applicable to business and government records.and government records.

June 26, 2007

QUESTIONSQUESTIONS