Developing a Scanning Plan
A detailed, written scanning plan should be developed that addresses pre-scanning controls and document preparation, and processing controls, including quality assurance and quality control procedures, and post-scanning controls.
Designing an Indexing Methodology
Central to the effective utilization of an imaging system to electronically manage records and data is a sound, comprehensive indexing methodology. A thorough and comprehensive indexing methodology is crucial to the successful utilization of an electronic imaging system. Indexing methodology tools can include Optical Character Reading (OCR), Intelligent Character Recognition (ICR), Barcoding, and/or
custom-designed data entry interfaces. The tools and methodology used should be the most efficient for the specific licensee’s operation. Every licensee’s indexing structure will be somewhat unique as it is built around its specific system capabilities and the types of records it wishes to store electronically.
Storage & Retrieval
Storage and retrieval issues should be addressed during the planning stage, considering which output media options (e.g., CD-ROM disks, ZIP disks, Worm (Write Once Read Many) optical disks, etc.) is most appropriate for storage of its electronic images. Other considerations include procedures to ensure re-writable CDs, if used, are not able to be written over. The output media should contain the exact duplicate of the original document. All records electronically stored should be maintained with a detailed index containing the gaming department and date.
The backup policy should address who performs the backup function, the timing and frequency of performing backups, the type of output media, any rotation of the output media, and storage of the output media. The working hard drive should be backed up on a daily basis. Archival should occur in a timely manner to ensure the integrity of the scanned images. Archival procedures should address who performs the archive, the timing and frequency of the archival, the type of output media, and storage of the archived data. At a minimum, one complete set of archives should be maintained onsite, and a second complete set is to be secured at an off-site location.
Testing Procedures
The primary objective of field testing the electronic imaging system is to ascertain that the system controls, manages, and maintains, in the form of electronic images and files, required gaming records in accordance with all applicable rules, and regulations. Determination of the most effective testing procedures and test schedule is at the licensee’s discretion. Testing procedures should include not only the field testing procedures, but also procedures for periodic and routine (i.e., semi-annual) testing of the imaging system.
Quality Control
The licensee should develop quality control (QC) procedures designed to avoid human/machine errors and to detect any errors that do occur in a timely manner. QC procedures ensure, among other things, that all documents are scanned and transferred to the proper folder/index. QC procedures are designed to avoid human/machine errors and to detect any errors that do occur in a timely manner. QC procedures should ensure, among other things, that all documents are scanned and transferred to the proper folder/index. One procedure may be to, on a sample basis, trace individual physical documents to the electronic image. Another procedure may be to check the total of the scanned image count and verify that it agrees to the pre-scan document count for each batch that is scanned.
Quality Assurance
The licensee should also develop quality assurance (QA) procedures that, in effect, test the effectiveness of the QC procedures. Through random sampling or 100% testing, QA procedures should be implemented. Any errors found should be corrected and documented to allow the licensee to quickly identify and address a consistent source of error. QA procedures should ensure that electronic images are legible, retrievable, and viewable. One procedure may be to visually examine the first scan of every batch to ensure optimal quality followed by a random sampling of subsequent images to ensure consistency of data. Another procedure should involve confirming the validity of backup media. Any errors found should be corrected and documented to allow the licensee to quickly identify and address a consistent source of error.
Access to Records
The licensee should ensure that any request for gaming records by a Gaming Commission representative can be met in accordance with regulations. It is the responsibility of the licensee to determine the best manner of satisfying this requirement. At a minimum, the licensee should have an employee available during all hours of operation who is knowledgeable enough to respond to any such request (i.e., produce the requested information) upon demand. Another consideration that should be addressed by the licensee is the Commission’s access to the electronic images. Hardware and/or software should be provided by the licensee in order for the Commission to perform its auditing procedures. It is up to the licensee to take whatever measures necessary to ensure the Commission has access to all electronic gaming records to perform its auditing procedures. The licensee should have controls in place to ensure the accurate reproduction of records, up to and including the printing of stored electronic documents used for Commission auditing purposes.
Inventory Control
The licensee should develop written inventory control procedures for all original media. Once the original gaming records are audited and subsequently electronically imaged, they should be maintained for 90 days from the gaming date of the document. This applies to all first run reports, audit adjustments, variance explanations, final reports, multi-part slips, and all other required gaming records. After the 90 day period, the original media (only the media that has been imaged) may be disposed of in accordance with the procedures outlined in the licensee’s written inventory control procedures.