How big of a deal is it to retain all data from a website on any given day? I am currently reviewing our website and one of the questions on the checklist is:

Is there a procedure in place to retain all data from the website on any given day? This includes all "blinking" text, as well.

We currently do not have a procedure in place within the bank and the vendor that created/maintains our website has stated that they do not currently have the ability to do this.

Thanks.

This is a tough question. It's been a decade since I looked at specifics, but there can never be a "one size fits all" answer. For that reason, regulators will be reluctant to offer guidance. There are many factors to consider and you have to look at it the same way you judge the need to retain every type of paper-based record for every product or service you offer.

Depending on the content of your site, many different federal regs can apply. Each reg will have its own record retention rules. Your state(s) might have laws and rules requiring retention of certain items, but in all cases, state law governs contracts. In disputes about contracts, you may find it necessary to present evidence of not only a copy of the contract or service agreement, but also the pre-consummation representations.

There may be better products site capture today, but the full commercial version of Adobe Acrobat used to be the cheapest and easiest way to capture some types of websites. Static pages were captured with almost every feature functioning as it did online. Sites that generate pages from databases on the fly are the toughest. Fortunately, the systems that house the DBs should have their own backup & retention capability.

The worst possible way to capture and retain website content is printed paper.

Thanks for your help Richard. I'm going to check with our IT department to see if they have any suggestions and thoughts. I've read some past forums and have seen many comments stating they do retain website information in printed paper - something I do not think we want to do! This just sounds horrendous. I will start with IT and move forward from there. I appreciate your help!

Thanks

There might be a page or two on your site that's best captured and retained on paper, but it's labor-intensive and can be difficult to index and use. Don't be surprised if you end up with a patchwork of two or more retention methods. However you do it, remember that it's the rendered page that will be needed as evidence of compliance--preferably with a time/date stamp on the pages themselves. Retaining the raw DB data that was supposed to be used to render the page is better than nothing, but it's a heavier lift to convince a critic that what was actually rendered was the same as you intended.

Do take a look at Acrobat as a possibility. Assuming that no features have been removed over the years, it has the ability to start from any point in the site and capture every page it encounters by following every link discovered. That can result in VERY large files, but it should all be automatic.

I will definitely suggest looking at Acrobat as a possibility. It sounds like we have a lot to look at to put something in place. Again - I appreciate all of your help!

This may help, Bankwoman:

https://archive.org/about/