INFORMATION MANAGEMENT
Long Term Storage
Paper versus Electronic
Alan Wheelock
Iron Mountain Consulting Services
October 17, 2012
What do these words have in common?
–Glamorous
–Romantic
–Captivating
None of them pertain to our
industry!
– Despite that sobering truth . . .
Long Term Storage – Paper vs Electronic
Agenda
Common Characteristics of Current Information Management
Programs
The Cart Can’t Come Before the Horse
Some Specific Document Types that Need to Stay in Paper
• Wills, codicils, other testamentary documents
• Promissory Notes
• Broker Trading Documents
•Real Estate Deeds and Written Documents
Common Characteristics of Information
Management Programs these Days ……
• 72% of organizations stated
that they are ‘very committed’
to RIM improvement
• But 72% have no strategic plan
• 80% now have Formal RIM
Policies
• But 63% are inconsistent in
their application of the Policies!
… and
• Only 43% of companies
believe that they have a
legally credible retention
schedule in place
• Only 37% of companies
say that their P&P’s are
consistently applied
• Only 15% of companies
have a formal , consistent
audit and review of their
RIM policies and
procedures
INFORMATION
MANAGEMENT
The Cart Can’t Come Before the Horse
Prior to Making Long Term Storage Decisions
Prerequisites
– Form and consistently convene an Information
Governance Steering Committee
– Bring your program to the appropriate ‘maturity’
level
– Consider the concept of “Unified Records
Management” as the basis for your “go forward”
strategy
So, What’s “Unified Records Management”??
Unified Records Management
 Establish a foundation
77% have formal, policy-driven processes to protect private information
from unauthorized or inadvertent access
 Unify physical records
83% report that they are unable to locate hardcopy records when needed,
due in large part to the fact that not all records, across all locations, are
indexed
 Unify electronic records
Only 35% say they can classify and index user-created electronic records
at time of creation or later in their lifecycle
Unified Records Management
Unified
Records
Management
XYZ Corp Records Data Analysis
Cartons that have a Division:
110,748
Cartons that have a Department:
716,910
Cartons that have a Record Code:
173,526
Cartons that have a Date:
986,085
Records Date
472,783
Receipt Date Only
513,302
Cartons with Contents Description:
850,447
Cartons that have a Destruction Date:
427,562
Cartons that have a Hold Code or Destr. Indic.: 81,194
Cartons with No Div/Dept/Record Code/Desc.: 48,868
Total Cartons
989,633
IM Connect Usage: 33%
What does Good Look Like?
Cartons that have a Division:
Cartons that have a Department:
Cartons that have a Record Code:
Cartons that have a Date:
Records Date
Receipt Date Only
Cartons with Contents Description:
Cartons that have a Destruction Date:
Cartons that have a Hold Code or Destr. Indic.:
Cartons with No Div/Dept/Record Code/Desc.:
Total Cartons
1,377,030
1,374,150
1,371,799
1,377,030
1,375,451
1,579
1,361,440
1,357,522
1,013,346
0
1,377,030
IM Connect Usage: 87%
This is a real IM client
Records Aging Analysis
Records More than 10 years old
XYZ Corp: 36% Sample Customer: 18.3%
Policy and Procedures
– Include electronic records management based on:
• ISO Standard 15489 – Records Management
• NARA Policy/Guidelines
• ARMA’s Generally Accepted Recordkeeping Principles (GARP)
• Model Requirements for the
Management of Electronic Records
(MoReq2)
– Include social network usage
• Facebook
• Twitter
• Blogs
• Wikis
– Reconcile with Info Sec and Info
Privacy policies
• Personally Identifiable Information (PII)
• Payment Card Industry (PCI)
• Personal Health Information (PHI)
Assess your Schedule
– Age
• Legal research date
• Mergers/acquisitions/divestitures
– Construction
• Size: trend is bigger “buckets”
• Orientation (function is best practice)
– eRecords inclusion
• 90% business records are electronic
– Global requirements
• Enterprise-wide is best practice
– Adoption and compliance
• Consistency leads to defensibility
Consider development of “e-version” to facilitate management
of electronic records
Apply retention to paper records
– On-site: active/inactive
• Conduct periodic “clean-up” or “compliance” days
• Institute a “System of Record” to manage active records
• Establish a process to transition records from active to inactive
– Off-site
• Classify cartons according to Retention Schedule
• Calculate destruction eligibility
• Institute formal destruction authorization/certification process
• Use ROI to fund other Records and Information Management projects
– Imaged originals
• Determine which need to be kept in paper format to satisfy state or federal authorities
• Consider long-term retention requirements for imaged records (explore alternative
media)
• Institute consistent destruction of originals, when permissible
Apply retention to structured records
– Use risk-based approach
• Determine risk categories based on litigation, investigation, FOIA requests, and audit
profile
• Prioritize based on potential for fines, sanctions, damage to brand , growth
– Assess applications
• Identify high-risk business processes / work flows
• Compare records management functionality to best practice
• Develop plan for filling gaps
– Apply macro rules for destruction
• Apply “haystack” rules based on function to determine destruction eligibility
• Protect preservation of “held” data
Collaborate with Legal, IT, Compliance, and Records Management
Apply retention to unstructured records
– SharePoint 2010
• Enforce governance for site creation/provisioning
• Establish rules in Retention Center
• Use Schedule terms in Content Hub
• Provide pre-tagged templates
– File Shares
• Provide alternative (SharePoint, ecrm)
• Establish department level foldering consistent with Schedule
– Desktops/laptops
• Protect content (PII, IP) using technology
Consider auto-classification tools for legacy “clean-up”
Provide employee training and awareness
Apply retention to e-mail
– Use archive (on premises or in cloud)
•
•
•
•
Move off active email server
Enhance search capabilities for early case assessment, FOIA, etc.
De-dupe
Terminate use of PST and NSF files
– Filter and classify
• Identify non-record formats
• Use role-based classification
– Leverage Active Directory
– Accommodate filers and pilers
• Use auto-classification
– Destroy
• Calculate destruction eligibility of archived e-mail
80% of responsive data for discovery is email
Archive
Long Term Storage Considerations
Electronic Signatures in Global and National
Commerce Act (‘E-SIGN’ Act)
• In place since 2000
• Has a host of rules related to retention
– Must be an accurate representation of the record
– Remains accessible to all persons entitled to access it
– In a form that is capable of being accurately reproduced.
Uniform Electronic Transactions Act (“UETA”)
• In place since 1999
• Adopted by 47 states
Long Term Storage Considerations (cont)
– E-Sign excludes several significant categories of
transactions/records;
• Laws governing wills, codicils, or testamentary trusts
• Laws governing adoption, divorce, or other matters of family
law
• Cancellations of utility services, health or life insurance
benefits
• Recall notices on a product that effects health or safety
• Notices regarding evictions, foreclosures, repossessions, etc.
• Court proceedings documents
Additional Decision Considerations
Paper is a very cost effective media for long term storage
• Format remains universally accessible and readable.
• Long term storage of paper is far cheaper that digitizing.
• Can be quickly digitized if the need arises.
• Can be digitized (imaged) on demand if records periodically become active
Vital records are typically retained in paper and microfilm versus
electronic
When planning for Long Term archival storage of electronic records,
consider:
• Accuracy and integrity of the e-version
• Future accessibility particularly as it pertains to discovery and regulation.
• The impact of technological change
IMPLEMENTATION FAILURE
THE most common cause for a failed program, and undoubtedly the biggest barrier
to making sound Long Term Storage Decisions
– Failure typically traced to:
• Lack of a permanent steering committee
• Lack of a dedicated RIM management person or team
• Lack of senior management commitment
• Lack of accountability + audit
• Lack of maintenance and continuous improvement
INFORMATION
MANAGEMENT
Questions & Answers