Title: Complying with the Law:
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Last saved by: David Bearman
Company: Archives & Museum Informatics

Electronic Records Research 1997: Resource Materials
Compilation Copyright, Archives & Museum Informatics 1998
Article Copyright, Author

Media Migration:

A New Issue That Needs New Accounting

by Robert F. Williams
Electronic imaging has created the need for new perspectives regarding changing from one storage media to another.  Historically, when there was a media change as, for example, from paper to microfilm, it was described as a “conversion.”  Typically, such conversions involved the older records -- the backfile -- and the primary benefit of the conversion was operating with one system and one media.  With electronic imaging, backfile conversions are still necessary, but because the records are digital, there is a new need:  media migration.  There are two reasons why media migration is an indispensable part of the on-going process of electronic records management.
1.	Hierarchical media management.  The essence of hierarchical media management is that performance requirements necessitate the use of multiple media in the course of a record’s life cycle.  For example, given the comparatively slower speed at which documents are recorded on optical media, some COLD systems provide a capability initially retaining the files destined for COLD onto magnetic disk (DASD) -- for “on line” speed of retrieval during the highest access period.  Once the high access time period has expired, the information is deleted from DASD and access is exclusively from the optical media stored “near-line” in a jukebox.  In time, when the access frequency to the file is very, very low, the optical media may be migrated again -- from its location in the jukebox to “off-line” shelves for the remainder of the record’s retention schedule.  This hierarchical migration of records, involving both a change in the type as well as location of the records storage media, is becoming an integral part of electronic records management.  The specific media, its location and the time that the record is stored there are a function of file size, access volume, and the type of record which, in turn, defines the record’s retention requirements.
2.	Long-term records retention.  Two problems are associated with the digital storage of records:  (1) a system (hardware and software) is required for any information retrieval; and (2) magnetic media needs to be regularly refreshed and both optical as well as magnetic media periodically need to be upgraded to the current “state-of-the-art” format.  (The January 1995 issue of Scientific American has a comprehensive article on this subject, entitled “Ensuring the Longevity of Digital Documents”.)  With the rapid and ever-present changes in both information storage and retrieval systems as well as in storage technologies, any electronic record that has to be retained for more than five to ten years will undoubtedly need to be migrated.  For permanently retained records, these migrations will probably occur approximately every decade.
If the migration of records is an essential component of managing electronic records, then there is the need to rethink how the costs associated with this activity are to be allocated.  Should they continue to be expensed or should they be amortized?  The problem with expensing is that it creates large deviations in operating costs.  If electronic records are viewed as an asset like buildings and equipment, then the need for their migration should be recognized in the same way buildings and equipment need to be periodically replaced or upgraded.  Capitalizing and amortizing the cost of migrating the records will significantly improve the accuracy of digital storage expenditures by reducing the deceptive peaks and valleys associated with expensing these costs.
The occasion of migrating electronic records also can be used as an opportunity to apply retention schedules.  If multiple types of records with different retention schedules are stored on a unit of media, the migration can selectively copy only those records that need to continue being retained.
Finally, managers of electronic records must appreciate that all migrations of their digital documents have legal implications.  Therefore, a specific action plan for migrations should be defined in advance and implemented in accordance with established policies and procedures.  Every migration constitutes a “change of custody” in the eyes of the law.  It is imperative that the process by which this change occurs is accurate, reliable and trustworthy.  Regarding all records migrations, there is a need not only for policies and procedures, but also for logs of who did what when.