Electronic Imaging (Correspondence, 11/10/94, GAO/AIMD-95-26R).

Pursuant to a Defense Finance and Accounting Service (DFAS) request, GAO
provided its views on whether the electronic images produced by the
Distribution and Retrieval Image-based Value Enhancer System constitute
records. GAO noted that: (1) federal agencies are not required to retain
financial records in their original paper form; (2) electronic
technology can be used to process, store, and retrieve data that are
currently retained on paper documents as long as adequate controls are
implemented to ensure data integrity; (3) the accuracy of electronically
stored data can be equal to that of a paper document; (4) DFAS needs to
ensure that electronically stored documents accurately represent the
corresponding paper documents, any changes to an original digital image
can be detected, access to the images is limited, and the digital images
are not destroyed and remain accessible until applicable records
retention periods expire; and (5) DFAS needs to maintain an unaltered
copy of original data images to ensure data integrity.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-95-26R
     TITLE:  Electronic Imaging
      DATE:  11/10/94
   SUBJECT:  Electronic equipment
             Computerized information systems
             Electronic forms
             Financial records
             Records management
             Data integrity
             Computer software verification and validation
             Systems design
             Image data bases
             Forms (documents)
IDENTIFIER:  DFAS Distribution and Retrieval Image Based Value Enhancer 
             System
             
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Cover
================================================================ COVER



November 1994


GAO/AIMD-95-26R

Electronic Imaging

(511474)


Abbreviations
=============================================================== ABBREV


Letter
=============================================================== LETTER


B-259207

November 10, 1994

Mr.  Edwin L.  Manky, Jr.
Director, Support Services
Defense Finance and Accounting Service
DFAS-DE/W
Denver, CO 80279-8000

Dear Mr.  Manky: 

This letter responds to your request for our views on whether the
electronic images produced by the Distribution and Retrieval
Image-based Value Enhancer System constitute records.  It is our
understanding that this system is designed to convert finanical
records, such as payment vouchers and supporting documentation, into
electronic records.  After the conversion, the paper documents would
be destroyed and the electronic records would become the agency's
official records.  Traditionally, agencies maintain, on paper or
similar physical mediums, many of their financial records that are
subject to records retention requirements.  We have not previously
addressed the use of imaging in creating and maintaining records;
however, we believe electronic technology, generally, can be used to
process, store, and retrieve data that are currently contained on
paper documents when adequate controls have been implemented to
ensure data integrity. 

GAO has long recognized that agency records are not required to be
maintained in their original paper-based form.  For example, we have
found microfilm and similar technologies to be acceptable methods for
storing the data on paper documents.  In a 1991 Comptroller General
decision, 71 Comp.  Gen.  109 (1991), which addressed whether
government contracts stored electronically rather than on paper
satisfied a statutory requirement that a contract be "in writing," we
stated that electronic technology that allows the data "to be
examined in human readable form, as on a monitor, stored on
electronic media, recalled from storage and reviewed in human
readable form," can provide data integrity that is equal to that of a
paper document.  We also noted that although electronic documents are
stored in a different manner than paper documents, they ultimately
take the form of visual symbols.  As stated in that decision, we
"believe that it is sensible to interpret federal law in a manner to
accommodate technological advancements unless the law by its own
terms expressly precludes such an interpretation, or sound public
policy reasons exist to do otherwise." We are not aware of any law or
public policy that generally requires financial records such as yours
to be retained in paper form. 

Any system, regardless of the technology used, must incorporate
adequate controls to ensure the integrity of the data.  You will need
to ensure that (1) the digital images accurately represent the
corresponding paper document, (2) any changes to an original digital
image can be detected, (3) access to the images is limited to
authorized personnel for authorized purposes, and (4) the digital
images are not destroyed and remain accessible until the applicable
records retention period expires.  Although you may need to make
authorized changes to an image, your system will need to maintain an
unaltered copy of the original image. 

This letter provides our views only on whether digital images can be
used to replace paper documents for financial records and does not
express an opinion on the adequacy of the controls in your planned
Distribution and Retrieval Image-based Value Enhancer System. 
Accordingly, it does not constitute GAO approval of your financial
management system as defined by 31 U.S.C.  3512(f)(2). 


---------------------------------------------------------- Letter :0.1

We recognize the challenges that your agency faces in automating its
systems and appreciate the opportunity to comment on your proposed
system.  We hope that our comments will assist your efforts.  Should
you have any questions, please contact Chris Martin, Assistant
Director, at (202) 512-9481. 

Sincerely yours,

Rona B.  Stillman
Chief Scientist for Computers
 and Communications

*** End of document. ***