Virginia Regulatory Town Hall
Agency
Library of Virginia
 
Board
Library of Virginia (Library Board)
 
chapter
Regulations Governing the Destruction of Public Records Containing Social Security Numbers [17 VAC 15 ‑ 120]
Action Regulations Governing the Destruction of Public Records Containing Social Security Numbers
Stage Proposed
Comment Period Ended on 11/2/2007
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10/29/07  10:37 am
Commenter: Richard Harrington, Fairfax County

Clarification on "burning" being allowed for all media and on statement "privacy protected info"
 

Although other forms of destruction are mentioned in the first paragraph, it should be clarified that burning can be done for all the media below including CD's as an acceptable form of destruction for records containing SSN's and other "privacy protected information" if this is defined in the paper.  Adding "other privacy protected information" is not appropriate for this regulation unless you change the title and define what is meant by this statement. 

I concur with Mr. Breeden's comments about if back-up tapes are really considered a "record", and also the other's comments about it is impractical to require that they be erased at the same time as the destruction of the records.  Allowing a reasonable time within the destruction time frame seems more appropriate for back-up tapes especially since they may contain other information that is not yet eligible for destruction.  This would entail identifying what is eligible for destruction on the tapes from what is not - a difficult and time consuming task on back-ups.

 

   

CommentID: 525