Living in a hybrid Living in a hybrid records worldrecords world

Practical skills for Practical skills for synchronizing paper AND synchronizing paper AND

electronic recordselectronic records

AgendaAgenda

What is a “hybrid” world?What is a “hybrid” world?– Requirements to synchronize practicesRequirements to synchronize practices

Standards – based strategiesStandards – based strategies Coffee BreakCoffee Break Low-cost or zero-cost strategiesLow-cost or zero-cost strategies ImplementationImplementation

1. A hybrid world1. A hybrid world

A MULTIMEDIA world – mix of information A MULTIMEDIA world – mix of information assetsassets

Growth in paper records and electronic Growth in paper records and electronic formatsformats– Recent – digitalRecent – digital

““born digital”born digital” Decisions in e-mailDecisions in e-mail

– Legacy – paper – Legacy – paper – convert to digitalconvert to digital

Despite predictions, Despite predictions, generally a 50-50 splitgenerally a 50-50 split

Impact on organizationsImpact on organizations

RIM efforts focused RIM efforts focused on paper formatson paper formats– growth of electronic growth of electronic

assets – diverse or assets – diverse or no controlno control

Exposure to riskExposure to risk What’s happening What’s happening

at your shop?at your shop?– Strategic Strategic

opportunity?opportunity?– SWOTSWOT

2. A standards – based 2. A standards – based approachapproach

In the absence of In the absence of laws or regulations, laws or regulations, a reasonable a reasonable approachapproach

International International StandardsStandards

Canadian Canadian StandardsStandards

Practice StandardsPractice Standards

RIM Program StandardsRIM Program Standards

– International Standards Organization International Standards Organization ISOISO

15489 Information and Documentation – 15489 Information and Documentation – Records Management – Part 1 – General Records Management – Part 1 – General and Part 2 – Guidelines (2001)and Part 2 – Guidelines (2001)

Required Program ComponentsRequired Program Components

Include:Include:– Policies and processes to assert control Policies and processes to assert control

over records life cycleover records life cycle– Basic instruments are records Basic instruments are records

classification, disposition, authority, and classification, disposition, authority, and security, and access evaluationssecurity, and access evaluations

Delivered through Policy, and Delivered through Policy, and Records Classification and Retention Records Classification and Retention ScheduleSchedule

Electronic Records StandardsElectronic Records Standards

Canadian General Standards BoardCanadian General Standards Board CAN/CGSB – 72.11-93 Microfilm and CAN/CGSB – 72.11-93 Microfilm and Electronic Images as Documentary Electronic Images as Documentary Evidence, including amendment 1 Evidence, including amendment 1 (2006)(2006)

Canadian General Standards Board. Canadian General Standards Board. CAN/CGSB – 72.34-2005 Electronic CAN/CGSB – 72.34-2005 Electronic Records as DocumentaryRecords as Documentary Evidence Evidence (2005)(2005)

““Authentic” and “Reliable” Authentic” and “Reliable” Electronic Records?Electronic Records?

How to prove authenticity and reliability of How to prove authenticity and reliability of electronic records?electronic records?

ISO 15489 – ISO 15489 – AuthenticityAuthenticity::a.a. Implement and document policies & proceduresImplement and document policies & procedures

b.b. Ensure creators are authorized and identifiedEnsure creators are authorized and identified

c.c. Ensure records are protected from unauthorized Ensure records are protected from unauthorized addition, deletion, alteration, us and concealmentaddition, deletion, alteration, us and concealment

ReliabilityReliability::– Versions of records are documented and evidentVersions of records are documented and evident

Integrity of Electronic Records Integrity of Electronic Records Management SystemsManagement Systems

Provides support for electronic records as Provides support for electronic records as evidenceevidence

Provincial and Federal Evidence ActsProvincial and Federal Evidence Acts, , juridical decisionsjuridical decisions

CGSB CGSB Electronic Documents as Electronic Documents as Documentary EvidenceDocumentary Evidence– Procedures manual as required in policy should Procedures manual as required in policy should

meet evidentiary standards for admissibilitymeet evidentiary standards for admissibility– Manual as “eyewitness” to prove records created Manual as “eyewitness” to prove records created

in the usual and ordinary course of businessin the usual and ordinary course of business

Practice StandardsPractice Standards

Technical RIM StandardsTechnical RIM Standards– Requirements for Managing Electronic Requirements for Managing Electronic

Messages as Records (2004)Messages as Records (2004)– Retention ManagementRetention Management– Digital Records Conversion Process Digital Records Conversion Process

(2007)(2007)– Etc.Etc.

A. Review Policy EnvironmentA. Review Policy Environment

Has your organization established a Has your organization established a RIM policy?RIM policy?– defines “records”defines “records”

Other policiesOther policies– E-mail ManagementE-mail Management– Appropriate Use of TechnologyAppropriate Use of Technology– Privacy ManagementPrivacy Management

RIM Policy ComponentsRIM Policy Components

Defines expectations upon staff, and links Defines expectations upon staff, and links expectations to practicesexpectations to practices

Ensures that evidence, accountability and Ensures that evidence, accountability and information about practices are metinformation about practices are met

Outlines what organization intends to doOutlines what organization intends to do– program and proceduresprogram and procedures– identifies senior manager with lead responsibilityidentifies senior manager with lead responsibility

Supported by procedures and guidelines, planning Supported by procedures and guidelines, planning and strategy statements, disposition authorities and strategy statements, disposition authorities and other documentsand other documents

Policies are statements of intentPolicies are statements of intent

Procedures ManualProcedures Manual

““Proof” of managementProof” of management Same classification, retentionSame classification, retention Procedures differ for paper and Procedures differ for paper and

electronicelectronic Paper – folders, groupsPaper – folders, groups Electronic – documents, foldersElectronic – documents, folders

Chain of EvidenceChain of Evidence

Records are considered as documentary Records are considered as documentary evidence, and must demonstrate that they were evidence, and must demonstrate that they were created as follows:created as follows:

1.1. Created in “usual and ordinary course of Created in “usual and ordinary course of business”;business”;

2.2. Meet business requirements and comply with Meet business requirements and comply with RIM best practices;RIM best practices;

3.3. Comply with national and international standards Comply with national and international standards for RIM;for RIM;

4.4. Comply with information technology Comply with information technology requirements and standards;requirements and standards;

5.5. Comply with applicable provincial and federal Comply with applicable provincial and federal laws, and court rulings.laws, and court rulings.

B. Records InstrumentsB. Records Instruments

Classification/Taxonomy/Information Classification/Taxonomy/Information Map?Map?– Subject or function basedSubject or function based– Specific to generalSpecific to general

Retention?Retention?– Granular or big bucket?Granular or big bucket?– Procedures?Procedures?

Security?Security? Accountability?Accountability?

Universal approach, diverse Universal approach, diverse practicespractices

RIM program requirementsRIM program requirements– Policy levelPolicy level

ResponsibilityResponsibilityDefined processesDefined processesQuality assurance and controlQuality assurance and control

– Common instrumentsCommon instrumentsClassificationClassificationRetentionRetention

C. Legal contextC. Legal context

Format neutralFormat neutral– Anything that recordsAnything that records

Processes not systemsProcesses not systems AccountabilityAccountability Risk managementRisk management

Legal trends*: “going electronic” Legal trends*: “going electronic” Potential adoption of best practices, like Potential adoption of best practices, like

Sedona Canada Principles for Electronic Sedona Canada Principles for Electronic Discovery Discovery (www.thesedonaconference.org)(www.thesedonaconference.org)

New BC Supreme Court Rules potentially New BC Supreme Court Rules potentially adopting proportionality discovery rules adopting proportionality discovery rules similar to Sedona Canada Principles for similar to Sedona Canada Principles for Electronic Discovery Electronic Discovery (www.bcjusticereviewforum.ca/civilrules/)(www.bcjusticereviewforum.ca/civilrules/)

* * Information provided by Stuart Rennie, LLB, Information provided by Stuart Rennie, LLB, MLIS, member of Sedona CanadaMLIS, member of Sedona Canada

Sedona Canada principlesSedona Canada principles

  

Sedona Canada: RIM Sedona Canada: RIM implicationsimplications

E-discovery should apply to all E-discovery should apply to all relevant electronically stored relevant electronically stored information and should be information and should be proportionate as to costs and proportionate as to costs and accessibility of production of this accessibility of production of this information (Principles 1,2,5)information (Principles 1,2,5)

Sedona Canada: RIM Sedona Canada: RIM implicationsimplications

The reasonable costs of discovery should be The reasonable costs of discovery should be borne by the party producing the e-borne by the party producing the e-documents. Parties should agree on documents. Parties should agree on preservation, access and production, using preservation, access and production, using agreed upon electronic tools and formats but agreed upon electronic tools and formats but also protecting privileges and confidential also protecting privileges and confidential information. Parties should respect the rules information. Parties should respect the rules of the forum in which the litigation takes of the forum in which the litigation takes place (Principles 3,6,7,8,9,10,12) place (Principles 3,6,7,8,9,10,12)

Sedona Canada: RIMSedona Canada: RIM Sanctions should be considered by the court Sanctions should be considered by the court

where a party will be materially prejudiced by where a party will be materially prejudiced by another party’s failure to meet any obligation to another party’s failure to meet any obligation to preserve, collect, review or produce preserve, collect, review or produce electronically stored information. The party in electronically stored information. The party in default may avoid sanctions if it demonstrates default may avoid sanctions if it demonstrates the failure was not intentional or reckless the failure was not intentional or reckless (Principle 11) (Principle 11)

““Compliance with a reasonable records Compliance with a reasonable records management policy, or justifiable inadvertent management policy, or justifiable inadvertent destruction or non-production of relevant destruction or non-production of relevant documents should not, in the ordinary course, documents should not, in the ordinary course, constitute sanctionable conduct.”constitute sanctionable conduct.” (Comment (Comment 11.e on Principle 11)11.e on Principle 11)

Life Cycle of Electronic RecordsLife Cycle of Electronic Records

A. Creation: A. Creation: record keeping activities are record keeping activities are undertaken under the custody and control of the undertaken under the custody and control of the creatorcreator

– Application specificApplication specific– ““Saving” requires document naming Saving” requires document naming

Needs consistent metadataNeeds consistent metadata– Forms and templates (Forms Management)Forms and templates (Forms Management)

B. RegistrationB. Registration– Valid? Complete? Drafts vs. Final?Valid? Complete? Drafts vs. Final?– AttachmentsAttachments– VersionsVersions

Life Cycle of Electronic RecordsLife Cycle of Electronic RecordsContinuedContinued

C. Use/Maintenance/RetrievalC. Use/Maintenance/Retrieval– Directory/Folder system Directory/Folder system – Shared filing placesShared filing places

OpenOpen All applications/networkAll applications/network

– Closed or secure filing spacesClosed or secure filing spaces Privacy protection/confidentialPrivacy protection/confidential User access permissionsUser access permissions

– Protection through back-up Protection through back-up

Life Cycle of Electronic RecordsLife Cycle of Electronic Records

D. Disposition/DeletionD. Disposition/Deletion– How? Must be authorizedHow? Must be authorized– Difficult to segregate by retentionDifficult to segregate by retention– MigrationMigration

E. PreservationE. Preservation– Challenge (migration?)Challenge (migration?)– Not currently guaranteed/ ResearchNot currently guaranteed/ Research

F. Quality Assurance & Audit TrailF. Quality Assurance & Audit Trail– To prove reliability of systemsTo prove reliability of systems

COFFEE BREAKCOFFEE BREAK

Image taken from Answers.com

3. Low cost or zero cost 3. Low cost or zero cost strategiesstrategies

Assumptions Assumptions – No funding for EDMS, large No funding for EDMS, large

projectsprojects– Possible slowdown in Possible slowdown in

general environmentgeneral environment– Opportunities for cost Opportunities for cost

sharing and savingssharing and savings

Potential of strategic Potential of strategic approachapproach– Alliances with IT, RIM, Alliances with IT, RIM,

LegalLegal Practice for EDMS Practice for EDMS

implementation (if, implementation (if, when…)when…)

A. Identify challenges/set A. Identify challenges/set prioritiespriorities

Find the challenges, frame the Find the challenges, frame the message!message!

Organization awareness?Organization awareness? Organization risk?Organization risk? Leadership?Leadership? Lack of time?Lack of time? Lack of tools?Lack of tools?

B. Conduct Risk assessmentB. Conduct Risk assessment

Records censusRecords census ““Worst first”Worst first” ExamplesExamples

– Ingest of documents Ingest of documents into EDMS*into EDMS*

UBC InterPARES case UBC InterPARES case studystudy

– Management of e-mailManagement of e-mail– Conversion of legacy Conversion of legacy

paper to digitalpaper to digital

C. Drive and folder managementC. Drive and folder management

Drives:Drives: Partition by retentionPartition by retention Apply classificationApply classification

– SimplifySimplify– Based on network managementBased on network management

Layers from drive, to folders, to Layers from drive, to folders, to documentsdocuments– Extra level at documentsExtra level at documents

Drives by document typesDrives by document types

P drive - P drive - Personal for work in Personal for work in progressprogress

S drive - S drive - Shared for final work to be Shared for final work to be sharedshared

Dedicated drives for graphics (G), Dedicated drives for graphics (G), applications (A), archives (X)applications (A), archives (X)

Ghost drive for past documentsGhost drive for past documents

FoldersFolders

Parallel to subjects and functions of Parallel to subjects and functions of classificationclassification

Shared drives – classification, Shared drives – classification, simplified, from records classificationsimplified, from records classification– No file codesNo file codes

Personal drives – topics Personal drives – topics relevant to relevant to staff work onlystaff work only– Same topics as file plan (max 10 topics)Same topics as file plan (max 10 topics)

Sample structureSample structure

DocumentsDocuments

Once saved, READ ONLY in shared Once saved, READ ONLY in shared drivedrive

Final versions in .PDF formatFinal versions in .PDF format Once saved, READ ONLY in archives Once saved, READ ONLY in archives

drivedrive Once saved, access only by Once saved, access only by

permission in ghost drivepermission in ghost drive Need document naming conventionNeed document naming convention

Sample Naming ConventionsSample Naming Conventions

1.1. TitleTitle – free form text that clearly describes the content of the – free form text that clearly describes the content of the document;document;

2.2. VersionVersion – two digit version number to facilitate sorting and – two digit version number to facilitate sorting and display of documents;display of documents;

3.3. DateDate – YYYY_MM_DD – significant date relevant to the – YYYY_MM_DD – significant date relevant to the document, e.g. Version date or publication date;document, e.g. Version date or publication date;

4.4. AuthorAuthor – first initial and last name; – first initial and last name;5.5. Business unit/programBusiness unit/program – name of business unit or program – name of business unit or program

area;area;6.6. TypeType – document type, e.g. AGD (agenda) AGR (agreement) – document type, e.g. AGD (agenda) AGR (agreement)

PRC (procedures);PRC (procedures);7.7. ExtensionExtension – application in which the document has been – application in which the document has been

created, e.g. ..doc; .xls.created, e.g. ..doc; .xls.

Alberta. Information Management Branch. “Naming Conventions for Electronic Documents.”Electronic Information Management. Alberta. Information Management Branch. “Naming Conventions for Electronic Documents.”Electronic Information Management.

August 2005. http://www.im.gov.ab.ca/index.cfm?page=imtopics/eim.htmlAugust 2005. http://www.im.gov.ab.ca/index.cfm?page=imtopics/eim.html..

Naming Conventions: ExamplesNaming Conventions: Examples

Using the full naming convention:Using the full naming convention:– Document Naming Conventions_V09_2009-Document Naming Conventions_V09_2009-

0501_sb_armacalgary_PRE.doc;0501_sb_armacalgary_PRE.doc;– Elements are: Elements are:

Title_Version_Date_Author_Organization_Type_extention;Title_Version_Date_Author_Organization_Type_extention;

Using the folder structure:Using the folder structure: ARMA PresentationsARMA Presentations

Calgary Chapter\Meetings\Calgary Chapter\Meetings\

The naming convention may consistThe naming convention may consist of:of: Meeting Date_Version_Author.doc;Meeting Date_Version_Author.doc; 2009-05-01_V01_sbradley.doc;2009-05-01_V01_sbradley.doc; 2009-05-01_V02_sbradley.doc; 2009-05-01_V02_sbradley.doc;

PermissionsPermissions

As open as possible As open as possible – Facilitate SHARING, rather than Facilitate SHARING, rather than

SECURITYSECURITY Closed for:Closed for:

– Privacy mattersPrivacy matters– Business confidential mattersBusiness confidential matters

Can be the most contentious issueCan be the most contentious issue

Migrate old files to new structureMigrate old files to new structure

Pick go forward datePick go forward date Defined time period for migrationDefined time period for migration

– Set criteria, e.g. In use? Decision?Set criteria, e.g. In use? Decision? Cut offCut off Close off, move to “ghost drive”Close off, move to “ghost drive” Available only if necessaryAvailable only if necessary Project to review, and then disposeProject to review, and then dispose

D. Retention ManagementD. Retention Management

Big buckets?Big buckets?– Aggregate to assist IT backup and Aggregate to assist IT backup and

retentionretention Depends on your organization, Depends on your organization,

accountabilityaccountability Example from project (Non-profit Example from project (Non-profit

legal research organization)legal research organization)

Legal Citations (where Legal Citations (where present)present)

LEGAL CITATION LEGAL CITATION NUMBERNUMBER

INFORMATION INFORMATION

MAP TOPIC(S)MAP TOPIC(S) SUMMARY OF SUMMARY OF LEGAL LEGAL RETENTION RETENTION

REQUIREMENTREQUIREMENT

11 Administration: Administration: Personnel/HR Personnel/HR Recruitment Recruitment Projects Projects Employment Employment Applications;Applications;

Operations: Operations: Development Development Donors Donors (Personal)(Personal) Donor informationDonor information

Personal Personal Information Information Protection ActProtection Act, , S.B.C.2003, c. 63S.B.C.2003, c. 63 in in section 35 requires section 35 requires that an individual's that an individual's personal information personal information must be retained for must be retained for at least 1 year after at least 1 year after being used.being used.

Model “buckets”Model “buckets”

9 categories of retention:9 categories of retention: Group 1 – Group 1 – CY; nil, D (Transitory records: Keep for current CY; nil, D (Transitory records: Keep for current

year at maximum, then destroy). This would apply to year at maximum, then destroy). This would apply to duplicateduplicate materials, materials, transitorytransitory documents and documents and draft draft itemsitems

Group 2 – Group 2 – SO, nil, D (SO, nil, D (Templates and formsTemplates and forms: keep active : keep active until updated, replaced or expired, then destroy)until updated, replaced or expired, then destroy)

Group 3 – Group 3 – CY+1; 6y; D (Keep in active workspace for CY+1; 6y; D (Keep in active workspace for current year plus one additional year. Move to storage current year plus one additional year. Move to storage space for six years. Destroy in the 8th year.) This would space for six years. Destroy in the 8th year.) This would generally apply to most generally apply to most financial and taxation reporting financial and taxation reporting recordsrecords

Group 4 – Group 4 – CY+1; 8y; D (Keep in active workspace for CY+1; 8y; D (Keep in active workspace for current year plus one additional year. Move to storage for current year plus one additional year. Move to storage for 8 years. Destroy in the 11th year.) This would apply to 8 years. Destroy in the 11th year.) This would apply to most most working notes, project drafts and other items working notes, project drafts and other items excepting for final reports and recommendationsexcepting for final reports and recommendations

Model buckets, cont’dModel buckets, cont’d Group 5 – Group 5 – SO; 6y; D (Keep active until updated, replaced or SO; 6y; D (Keep active until updated, replaced or

expired and all obligations to the organization cease. Move to expired and all obligations to the organization cease. Move to storage for six years, Destroy in the 7th year.) This would storage for six years, Destroy in the 7th year.) This would generally apply to most generally apply to most agreements, arrangements, and agreements, arrangements, and other continuing items, where the retention period other continuing items, where the retention period applies after the agreement is completed or the applies after the agreement is completed or the relationship is terminated of and all obligations are relationship is terminated of and all obligations are completedcompleted

Group 6 – Group 6 – CY+1, 8y, D (Keep active for 2 years, close and CY+1, 8y, D (Keep active for 2 years, close and store for 8 years, then destroy). This would apply to store for 8 years, then destroy). This would apply to legal legal adviceadvice provided by staff lawyers on establishing an provided by staff lawyers on establishing an easement, covenant, right of way, conveyance or providing easement, covenant, right of way, conveyance or providing tax advice.tax advice.

Group 7 – Group 7 – SO, 6y, D (Keep active until no longer referenced SO, 6y, D (Keep active until no longer referenced or related to current program work, close and store for six or related to current program work, close and store for six years, then destroy. Upon file closing, remove any years, then destroy. Upon file closing, remove any documents that are publicly available, such as pleadings or documents that are publicly available, such as pleadings or court documents.) This would apply to WCEL court documents.) This would apply to WCEL program, program, summary advice or client representation.summary advice or client representation.

Model buckets, cont’dModel buckets, cont’d Group 8 – Group 8 – CY + 2, 7y, D (Keep active for three years, close CY + 2, 7y, D (Keep active for three years, close

and store for seven years, then destroy. Upon file closing, and store for seven years, then destroy. Upon file closing, remove all application information except financial remove all application information except financial information.) This would apply to records of the Fund.information.) This would apply to records of the Fund.

Group 9 – Group 9 – SO, nil, P (Keep active until updated, replaced or SO, nil, P (Keep active until updated, replaced or expired.) (expired.) (Archival records:Archival records: move to a permanent move to a permanent storage location and retain for the duration of the storage location and retain for the duration of the organization.)organization.)

This would apply to society incorporation documents and This would apply to society incorporation documents and related board and financial reporting information, related board and financial reporting information, agreements, policies, procedures and activities that are agreements, policies, procedures and activities that are required for the lifetime of the organization, as well as required for the lifetime of the organization, as well as reports and data useful for long term planning and analysis.reports and data useful for long term planning and analysis.

Match drives, folders to bucketsMatch drives, folders to buckets

Link retention periods to largest Link retention periods to largest element element – DrivesDrives

FolderFolder– Subfolders by date Subfolders by date

Work with IT for back up, disposalWork with IT for back up, disposal

E. E-mail ManagementE. E-mail Management

What are the concerns about this What are the concerns about this format?format?

What are the biggest challenges?What are the biggest challenges? What are some of the solutions What are some of the solutions

currently in play?currently in play?– Size limitations on mailboxSize limitations on mailbox– Print and filePrint and file

E-mail Filing ResponsibilitiesE-mail Filing Responsibilities

Set up message directories the same as Set up message directories the same as electronic directories (apply the same electronic directories (apply the same retention)retention)

Establish protocol, e.g. Establish protocol, e.g. – Author saves e-mails sent internallyAuthor saves e-mails sent internally

Originating author saves threaded messageOriginating author saves threaded message

– Recipient saves e-mails received from external Recipient saves e-mails received from external sourcessources

– First recipient of multiple recipients saves First recipient of multiple recipients saves messagemessage

– Workgroups should designate e-mail Workgroups should designate e-mail gatekeeper to save and filegatekeeper to save and file

E-mail retention proceduresE-mail retention procedures

Separate transitory from substantiveSeparate transitory from substantiveDate or time limit (90 days) to force decisionDate or time limit (90 days) to force decision

Approved processes for deleting Approved processes for deleting transitorytransitory

DuplicatesDuplicatesFacilitative, such as bookings, schedulingFacilitative, such as bookings, schedulingCopies for information onlyCopies for information onlyThreaded messages when the final is the Threaded messages when the final is the

complete messagecomplete messagePersonal messagesPersonal messages

Procedures for other Electronic Procedures for other Electronic FormatsFormats

Scanning Scanning Digital photographsDigital photographs Graphic applications, e.g. drawing, Graphic applications, e.g. drawing,

mappingmapping Records in databasesRecords in databases Web contentWeb content Instant messaging, etc.Instant messaging, etc.

Deal with as you have time, and there is Deal with as you have time, and there is benefitbenefit

ScanningScanning

Conversion of paper to digital formConversion of paper to digital form JustificationJustification MethodMethod Reliability and integrity of digital Reliability and integrity of digital

formform ““best evidence”best evidence” Adherence to standardsAdherence to standards

4. Implementation and Change 4. Implementation and Change ManagementManagement

Pilot and user groupsPilot and user groups– Team leadersTeam leaders

Desk top supportDesk top support– Cheat sheetsCheat sheets– KISSKISS

5. Return on Investment?5. Return on Investment?

Legal context - risk avoidanceLegal context - risk avoidance– Demonstration of expert controlDemonstration of expert control

IT context – network/resources IT context – network/resources optimizationoptimization

Business owners – Business owners – – information access,information access,

ease of useease of use

Thank youThank you

Alexandra (Sandie) Bradley, CRMAlexandra (Sandie) Bradley, CRM

Harwood Information Associates LimitedHarwood Information Associates Limited

1236 Fulton Avenue1236 Fulton Avenue

West Vancouver BC V7T 1N6West Vancouver BC V7T 1N6

harwoodinfo@telus.netharwoodinfo@telus.net