The Top Ten Issues in Records Management Today

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The Top Ten Issues in Records Management Today

• Presented to the
• North Jersey Chapter
• ARMA International
• By
• David O. Stephens, CRM, FAI
• September 15, 2010

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Issue 1 - The growing role of RM as a significant
issue in organizational management

• Let your Eminence give
• orders throughout each and
• every province that a
• building be erected in which
• to store the records . . . So
• that they may remain
• uncorrupted and may be
• found quickly by those
• requiring them . . .
• The Emperor Justinian
• Roman Empire, 6th century A.D.

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Recordkeeping is in transition . . . and so is
RM!

• When I started in RM in 1972, the discipline was
  about exercising direct custody over physical
  records in file rooms and records centers our
  only technology was microfilm.
• Now, the discipline has transitioned to one
  concerned largely with policy planning, systems
  development and compliance monitoring across
  all media types!

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Issue 2 RMs role in the transition to the
(nearly) paperless office

• For decades, the term paperless office was
  greeted with ridicule in the RM community.
• Even today, some Luddites still cling
  tenaciously and irrationally to the notion
  that paper will be with us forever that the
  long-awaited but hitherto unrealized paperless
  office is and will remain a myth.

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Consider the analogy of the horse and buggy at
the dawn of the Automotive Age

• To argue the case for paper-based recordkeeping
  today is akin to extolling the virtues of the
  horse and buggy . . . . when, in Dearborn,
  Michigan, a guy named Henry Ford was just
  starting to mass-produce what was undeniably a
  better mousetrap the Model T the Tin Lizzie
  that changed America and the world!!!
• With every year that passes, paper files are
  (correctly) regarded as archaic, particularly by
  the younger generation of office workers who
  grew up with technology, not file cabinets!

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Paper records A long, slow decline

• Today, no sophisticated organization runs off
  paper it runs off system-based information
  content!
• With every year that passes, paper records are
  relegated to the status of casual printouts.
• So, even today, we still have quite a lot of
  paper, but its rapidly declining as a
  significant factor in organizational
  recordkeeping.

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Yes, paper records are going the way of the horse
and buggy!

• Although its early demise has been wrongly
  predicted, paper is (sooner rather than later) on
  the way out just like the horse and buggy!
• The technology to de-paper business offices has
  been invented during the past 30 years and is
  just now beginning to make a significant impact.
• It will take another decade or even a little
  longer to come to fruition. But it will
  happen!!!

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RMs must facilitate the transition to the
(nearly) paperless office!

• Example The Bank of America is one of the
  worlds largest consumers of paper!
• Under its new Enterprise Digital Records Policy
  mandate, the goal is to convert to digital format
  all legacy paper applications, for which a viable
  business case can be made, by 2013!
• This is, of course, a daunting challenge to cite
  just one example, the Bank sends monthly
  statements to 50 of all U.S. households!
• Key enabling legislation E-commerce, digital
  signature and electronic transactions acts.

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Issue 3 RMs role in regulatory compliance and
litigation risk reduction

• While this issue is more compelling for business
  corporations than for governmental entities, this
  remains the key driver for RM as practiced in
  the U.S.
• This is why records retention remains the
  mainstay of professional practice!

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Demonstrating compliance in recordkeeping Three
key principles

• That the organization is conducting its business
  with honesty and integrity, and in a manner
  consistent with the public interest as well as
  its own.
• That the organizations records are properly
  maintained and preserved, in case they may be
  needed as evidence in government investigations,
  litigation, audits or other legal proceedings.
• That the organization is in full compliance with
  all applicable laws and regulations, in letter,
  spirit and good faith.

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In the eyes of the law, its not the medium that
matters, its the integrity of the content!

• In general, the law doesnt care what medium
  content has been recorded on.
• Rather, the key issue is whether the content is
  trustworthy that is, it has not be falsified in
  pursuit of some malicious purpose!
• The goal To pass the tests of reasonableness and
  good faith!

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Electronic records Five key principles for
demonstrating legal sufficiency

1. Store and preserve them in a manner and format
   that provides reasonable assurance that they will
   be retrievable, usable and printable throughout
   the duration of their authorized retention
   periods.
2. The format should allow for validation, audits,
   reporting, and disclosure
3. Store and preserve them in a manner that
   reasonably safeguards them from loss,
   unauthorized alteration or destruction.
4. At such time in the life cycle when a record has
   been finalized and thus possesses the
   characteristics of an officially retained record,
   the record should be retained in a format that
   does not alter its contents.
5. Maintain complete documentation to demonstrate
   that the records were created in the normal
   course of business by accurate and reliable
   processes and that internal controls are in place
   to safeguard them from unauthorized modification
   or deletion.

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In litigation, its not the records you no longer
retain that cause the most problems, its those
that remain

• An organizations attorneys can more easily
  defend the absence of documents that have been
  systematically destroyed under an established
  retention policy than they can defend the
  information content of existing records.
• In other words, if you no longer have a record,
  you just need a good reason why that record was
  destroyed.
• Thus, from a litigation risk avoidance
  perspective, the goal should be to retain only
  those records needed to conduct business and
  comply with the law.

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The best strategy for mitigating e-discovery and
litigation risks . . .

• . . . retain only whats needed to operate the
  business, comply with the law, and meet
  reasonable needs to retain history!
• All other records should be regarded as
  redundant!
• They should be systematically discarded under
  approved retention policies that can be defended
  as compliant and reasonable!

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Issue 4 RMs role in enhancing the
accessibility of information content

• Miss Lemon, secretary to Hercule Poirot
• Her real passion in life was the perfection of a
  filing system beside which all other filing
  systems should sink into oblivion. She dreamed
  of such a system at night.
• Source Agatha Christie, How Does Your Garden
  Grow, 1931.

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The value of information is directly
proportionate to its accessibility

• An organization may possess a single kernel of
  information upon which its entire future rests,
  but if those who seek it cannot find it, the
  golden nugget is worthless.

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Google . . . The search engine that changed the
world

• User experience with Googles public search
  engine, which has demonstrated the power of
  search to find needed information on the
  Internet, has greatly raised the bar of
  expectations.
• Why cant I find information in my organization
  like I can find information on the Web using
  Google?
• The rising tide of expectations is causing
  companies to rethink search technology and its
  role in overall content management.
• Source Matthew Brown, Enterprise Search
  Platforms, Cambridge, MA Forrester, 2006.

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In response to any (properly formulated) search
query, one of five things can happen

• The system delivers all the documents /
  information requested and no others.
• The system delivers all the documents desired, as
  well as others deemed not relevant.
• The system delivers some of the requested
  documents, but not all.
• The system delivers some documents, none,
  however, are deemed relevant.
• The system delivers no documents at all and some
  are known to exist that are relevant to the
  query.
• It is the task of RM to ensure that No. 1 occurs
  consistently across the enterprise!

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Your best chance of finding the needle in the
haystack

• In large and complex unstructured content
  environments, the best chance of consistent
  precise and timely retrieval results from a
  combination of
• A good and well implemented document taxonomy
  schema, combined with . . .
• A robust full-text search engine!

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Issue 5 Getting to (nearly) perfect in records
retention

• Sadly, most records retention programs are not
  organized around success and are under-managed.
• Most have no long-term management plan or
  strategy for achieving success.
• So, just like every self-fulfilling prophesy,
  success in retention remains elusive!

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Best practice in enterprise RM requires the
systematic application of rules, tools and
implementation strategies in five recordkeeping
environments

• 1. Active paper records at departmental
  workstations
• 2. Inactive paper records in storage facilities
• 3. Personal working papers kept in desks,
  credenzas and bookcases
• 4. Structured database applications managed by IT
• 5. Unstructured electronic records (email and
  others), controlled by their creators

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A top RM goal No more unmanaged storage closets
paper or digital!

• Regardless of whether they used for the storage
  of paper or electronic records, every storage
  repository must be managed such that the content
  is fully accessible, readily retrievable, and
  safe and secure.
• Moreover, the lifecycle of the content in all
  repositories must be properly managed under
  approved retention rules.
• This basic principle should be enshrined in
  organizational policy!

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Getting to perfect in retention Three key
principles

• You must have a workable strategy for modifying
  employee behavioral tendencies for indefinite
  retention. Mandated records purge days are
  strongly recommended.
• Any strategy that over-relies on user
  classification of content into retention
  buckets has a high probability of failure.
• Compliance monitoring is key Success in
  enterprise retention requires a police and a
  jail!

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Rome wasnt built in a day (and neither will
perfection in records retention!)

• Organizations should establish a 5-year goal of
  applying retention rules in all 5 recordkeeping
  environments.
• Poorly managed warehouse storage and IT-managed
  system applications will require multi-year
  commitments.

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Issue 6 The role of electronic records
retention in improved data lifecycle management

• What happens to computer data as it ages?
• Does the value of data increase or decrease as
  time passes?
• Do storage management requirements change as data
  ages through its lifecycle?
• In the world of paper, these are questions that
  records managers have addressed for decades!
• But not in the world of IT, where retention has
  not been widely practiced.

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Is there a viable business case for applying
retention rules to electronic records?

• With media capacity increasing at 60 per year
  and the cost-per-megabyte declining at 35 per
  year, it is often assumed that there is no viable
  business case for electronic records retention.
• But . . . this view neglects the explosive growth
  of data and increases in the total cost of data
  ownership!

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Bringing retention functionality to structured
database applications

• In most organizations, the large majority of
  databases and other IT-managed applications lack
  the requisite functionality to execute retention
  rules.
• The solution
• A new policy that requires that IT work with the
  data owners and RM staff to incorporate such
  functionality at the time of the next technology
  upgrade.
• Since technology upgrade cycles average 5 years,
  at the end of this time period, most applications
  can be made retention-capable / compliant.
• Of course, the policy must also require that new
  applications must incorporate retention
  functionality at the time of initial design /
  deployment.

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Issue 7 Email Still the biggest RM challenge!

• Even today, 15 years after it came into common
  office usage, email is still the biggest RM
  challenge for most organizations.
• For many, the only email solutions they have in
  place are mailbox capacity limits and archiving
  messages to PST files stored on local hard
  drives.
• This is not best but worst practice!!!

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Consider the analogy of the postal mail you
receive at home . . .

• When you go home tonight, youll get your mail
  out of your mailbox.
• There will be bills, magazines, and junk mail.
• Youll discard the junk mail, put the magazines
  on the coffee table or night stand, and put the
  bills in the pending file for payment.
• But you wont put any mail back in the mailbox!
• Well, thats exactly whats happening in many
  email environments!

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The email environment should be restricted to
current communications only!

• Many e-mail users retain hundreds, even
  thousands, of e-mails, in their messaging
  environment. This is not best but worst
  practice!
• A top records management priority is to ensure
  that the messaging system is not morphed from an
  e-post office into an unmanaged archive!

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Traditional RM orthodoxy A receipt for failure!

• For years, RMs said that the way to manage
  retention was to hold the users responsible for
  classifying it by matching message content to the
  proper records series in the retention schedule
  and then saving the messages in a repository
  where the retention rules could be satisfied.
• But, asking users to classify 30 to 60 or more
  e-mails per day in accordance with a taxonomy and
  save them to an ERMS or ECM solution is not
  practical aint gonna happen!!!

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Retention rule No. 1 Email of transitory
(short-term) value

• Typically defined as any messages requiring
  retention for 90 days or less.
• Employees are empowered (indeed they should be
  required by organizational mandate!) to delete
  email of transitory value daily.
• Guidance is given as to what constitutes email of
  this type.
• This requires 10 to 15 minutes per day.
• For most employees, the volume of such messages
  is 20 to 60 percent of the total.

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Retention rule No. 2 Email of routine
business value

• A standard or default retention period for
  email of routine business value is established
  by policy.
• It is effectuated by automatically transferring,
  without user involvement or decision-making, all
  e-mail remaining in employees mailboxes when the
  messages have aged 90 days to a dedicated email
  archival repository, where they will remain for
  the duration of the approved retention period.
• When the messages have aged to the duration of
  the retention period, they will be purged, again
  without user intervention or decision-making.
• To operationalize this strategy, youll need an
  email archiving tool (software solution).

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Retention rule No. 3 Email of long-term
retention value

• Defined as messages requiring retention longer
  than the retention period for email of routine
  business value), based on their content as
  compared to the rules in the organizations
  retention schedule.
• These messages must be saved in a separate
  repository that can satisfy their retention
  period
• Printed and filed in paper format.
• Saved to another software application (ERMS, ECM,
  or other solution).
• Many employees wont have any emails of this
  value in most organizations the total volume of
  such messages will range between 5 to 10 percent
  of all messages.

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Lets summarize these three email retention rules
. . .

1. Email of Transitory Value Destroy daily by
   users
2. Email of Routine Business Value Subject to
   standard, approved default retention rule (3 to
   7 years) and implemented automatically in
   archiving software
3. Email of Extended-term Retention Value Users
   responsible for retaining as scheduled in
   approved retention repository

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Issue 8 Cleaning out the digital closets
Records retention and unstructured content

• Lets take a brief look at the biggest forms of
  digital closets in todays organizations
  SharePoint sites and fileshares on network
  drives.
• Apart from email, PSTs and local hard drives,
  these are the biggest RM challenges today where
  unstructured content is concerned.

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SharePoint The de facto standard for enterprise
collaboration

• Just like our closets at home, content tends to
  be saved, indiscriminately, without regard to its
  retention status.
• Further, site owners / administrators often
  neglect to manage retention of inactive sites.
• While the software possesses the functionality
  for the automatic identification and clean-up
  of unused sites, this, too, is often neglected.
• Basic policy principal
• Site content should be retained for a
  predetermined period of time after the site is
  declared inactive.

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Retention rules for SharePoint site content

• The default? retention rule
• Date of site inactive status 3 to 7 years, as
  selected by the site owner and approved by RM, at
  which point all content will be purged /
  destroyed.
• Exceptions can be granted i.e. sites can be
  designated for permanent preservation for
  historical purposes.
• Finally, users should be empowered to delete
  duplicates, drafts and working papers saved to
  the site at any time.

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Issue 9 The significance of the new software
solutions

• Today, for the first time ever, the goal of total
  life cycle management, through a retention
  methodology supported by computer software, is
  within reach!
• This is the holy grail of RM!
• At present, a total of 52 software solutions have
  been certified under DoD 5015.2!
• More good news Retention functionality is
  increasingly being built into native software
  applications!

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For the first time, large computer companies get
into the RM business

• For decades, records management was perceived as
  tangential to the larger enterprise information
  management agenda because large computer
  companies werent in the records management
  business.
• But, in the last five years, things have changed
  
• In 2002 IBM acquired Tarian Software and
  announced plans to integrate records management
  capabilities across its entire software
  portfolio.
• In 2006, IBM enhanced its position in the market
  by its acquisition of FileNet.
• In 2003 EMC acquired Documentum and launched an
  Information Lifecycle Management business.
• In 2006, Oracle acquired Stellent.
• These and other developments have the potential
  to elevate records management to another level of
  legitimacy as an information management
  initiative of enterprise strategic significance.

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Issue 10 The role of RM in preserving the
digital record

• Our IT department tells me they can support data
  retention requirements up to 5 years with
  certainty. From 5 to 10 years, with a little bit
  of luck. After 10 years, there are no
  guarantees!
• Source Edie Allen, Records Manager (retired)
  Battelle Memorial Labs

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Why digital preservation?

• If an organization creates a record in electronic
  format in, say, the year 2006, and this record
  will need to be digitally processed and read many
  years later, how, exactly, can this requirement
  be supported in a technology environment in which
  the only constant is rapid change?

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Digital preservation Eight best / recommended
practices

• 1. Records selection
• 2. Storage media selection
• 3. Data migration
• 4. Standardize file formats
• 5. Media recopying
• 6. Metadata management
• 7. Systems documentation
• 8. Media storage and maintenance

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Can the nations digital archives be preserved
for posterity?

• In the Age of Paper, the U.S. National Archives
  (established by President Roosevelt in 1934) went
  from nowhere to world leadership in 15 years!
• With paper we could do it, but can this feat be
  replicated in the Digital Age at any level of
  government?
• This remains an open question!

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And finally, the thought for the day . . .

• We have two ends
• With a common link
• With one we sit
• With the other we think
• Success depends on which we use
• Heads we win
• Tails we lose!
• Source Anonymous