retaining paper logs

[Deleted User]

Would someone refresh my memory and tell me the current regulation on retaining paper logs?

3 years? 7 years?

 

[Deleted User]

I think it might be 2 years but I just want to CYA before I start the shredder up!

 

[aaronread]

Depends on what logs you're referring to. Some things must be kept in your public inspection file for the duration of your current term of license from the FCC. Other things, like the Station Logs, need only be kept for two years. Exactly how they calculate two years is vague; I usually purge the Station Log every six months of everything older than 25 months.

 

[Deleted User]

I have something that corporate sent up to Jeff a while ago that explains what is 3 years, what is forever, what is the term of the license, etc.

Unfortunately the information has no reference to where the opinion came from, I'd kind of like to know the part 75 section just so I know for sure, but my read on it is the paper logs with all the PSA's Promo's, station ID's etc etc etc is 2 years retention . Copies of our paperwork is also sent to NYC where it might be archived, but if the FCC comes knocking on the door I don't want to be the one that has to tell them I don't have the documents they are looking for, but on the other hand we have 5+ years of paper logs in file cabinets right now IIRC and it's getting a little cramped out back.

 

[JIBGUY]

but my read on it is the paper logs with all the PSA's Promo's, station ID's etc etc etc is 2 years retention .

Best to keep program logs a minimum of 2 years. BUT, it's better to keep them for the entire license-period. If someone were to challenge your license renewal saying the station doesn't play any PSA's or public affairs programming, by saving 8 years (license term) of logs, you have 8 years of proof that the challenger is wrong. Always a good idea to keep logs significantly longer than what's required.

 

[Deleted User]

Thanks Bob.

 

[DanStrassberg]

on the other hand we have 5+ years of paper logs in file cabinets right now IIRC and it's getting a little cramped out back.

Somebody else is going to have to tell you whether the FCC will accept document images stored electronically. If yes, a document scanner--a piece of hardware that you get essentially for free if you buy a low-cost "all-in-one" PC printer, software such as Nuance PaperPort (but there are MANY other packages) to manage the image files, a few Gbytes of unused space on a hard drive, and a number of days of effort to scan all of the documents, and you can get rid of all of the filing cabinets and their contents. It would also be a good idea to back up the files, especially if the FCC might revoke the station license if you couldn't prove that you had retained copies of all correspondence. For backups, you might want to consider one of the many on-line storage sites. The costs are moderate. Another advantage of storing document images (assuming the FCC allows it) instead of paper documents is that if the FCC requires you to keep e-mail correspondence as well as paper corresondence, you can save the e-mail on the same hard drive you use to store the document images. Remember, scanning all of those documents at one time is something you have to do only once. After that, you scan new documents as they arrive. You can do that in no more time (probably less) than it takes to file a paper copy.

 

[haverhill01835]

on the other hand we have 5+ years of paper logs in file cabinets right now IIRC and it's getting a little cramped out back.

Somebody else is going to have to tell you whether the FCC will accept document images stored electronically. If yes, a document scanner--a piece of hardware that you get essentially for free if you buy a low-cost "all-in-one" PC printer, software such as Nuance PaperPort (but there are MANY other packages) to manage the image files, a few Gbytes of unused space on a hard drive, and a number of days of effort to scan all of the documents, and you can get rid of all of the filing cabinets and their contents. It would also be a good idea to back up the files, especially if the FCC might revoke the station license if you couldn't prove that you had retained copies of all correspondence. For backups, you might want to consider one of the many on-line storage sites. The costs are moderate. Another advantage of storing document images (assuming the FCC allows it) instead of paper documents is that if the FCC requires you to keep e-mail correspondence as well as paper corresondence, you can save the e-mail on the same hard drive you use to store the document images. Remember, scanning all of those documents at one time is something you have to do only once. After that, you scan new documents as they arrive. You can do that in no more time (probably less) than it takes to file a paper copy.

Interesting idea! But what about making your public record "public" if you go to a digital format? Would you need to set up a viewing station in a cubical somewhere in case someone wants to do a "pokey pokey" into your public file? I wonder if the FCC has taken this up?

Marc

 

[aaronread]

The FCC does specifically allow you to store all your Station Logs (and other Public Inspection File documents) in electronic format. But you must make a means of viewing and printing them available to the public during normal business hours...which is any contiguous 8-hour period between 8am and 6pm on weekdays, excluding federal and, I believe, state holidays.

Minnesota Public Radio, with its dozens of translators and "full power" signal scattered across the state, has been a major adopter of the "electronic documents" system. http://minnesota.publicradio.org/about/mpr/fcc/

 

[DanStrassberg]

Interesting idea! But what about making your public record "public" if you go to a digital format? Would you need to set up a viewing station in a cubical somewhere in case someone wants to do a "pokey pokey" into your public file? I wonder if the FCC has taken this up?

Well, you might post it on the station's Web site, although that would certainly require FCC approval. It would make too much sense for the agency that regulates communications in the 21st century to approve of having radio stations' public files accessible on the Web, though.

Also, I don't think I'd want to let anyone who was unfamiliar with PaperPort 11, use it to view a bunch of files. And for certain, I'd want to make sure that the files available for viewing were read only. Even though I'd restrict public access to copies of the files and I'd limit the actions that could be taken to viewing and printing of files--not changing or deleting them--I'd want to be absolutely certain that the public could not do any mischief even if the mischief were confined to copies. For the station, some advantages of Web access would be keeping the public out of the station premises and ability to have the public view the files even if the station offices were not conveniently located. Also, with the proper security, station management wouldn't have to worry about someone on the Web damaging computers in the station's offices.

 

[necrat123]

Well, you might post it on the station's Web site, although that would certainly require FCC approval.

Also don't forget that FCC rules state that the public EEO records MUST be put online if you have a station website.