M12S07 - Retention & ESI - Paths to Success - Part Two
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M12S07 - Retention & ESI - Paths to Success - Part Two

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From MER Conference 2012 ...

From MER Conference 2012

Speakers: Christine Burns and Carol Stainbrook

This session explains "why" your organization's technology selections impact "how" the updated retention schedules described in part one of this two-part session can be applied to electronically stored information (ESI). Learn reasonable and actionable approaches for embedding retention policies into e-mail, file shares and enterprise applications.

This session will address:

- Why "perfection" is often impractical, when it comes to applying retention policy to ESI and some reasonable alternatives to perfection.
- How the technologies for email, file shares, and other ESI affect the implementation of retention policies.
- When it may be necessary to choose different retention strategies for different technologies such e-mail, file shares and enterprise applications.
- Considerations for applying retention policy to data in enterprise applications.
- Criteria to help prioritize where to begin when applying retention policy.

In this session you will learn how to tailor your organization's approach to retention schedules so they are reasonable, actionable and result in the orderly destruction of eligible information, given your organization's technology selections.

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  • 1. Cohasset Associates, Inc. NOTES Retention & ESI Paths to Success Part Two Carol Stainbrook & Christine M. Burns May 7, 2012 1 Applying Retention to ESI Using Semi-Automated & Automated Tools Devise a Plan Based on Reasonableness Exploit Capabilities of Your Tools Creation Date Event Date E D Versioning Retention Strategy for Different System Types Be Responsible & Avoid Paralysis © 2012 May 7, 2012 2 Retention & ESI Paths to Success Think Strategically Learn Capabilities Act Reasonably © 2012 May 7, 2012 32012 Managing Electronic Records Conference 7.1
  • 2. Cohasset Associates, Inc. NOTES All Information is Not Equal Official Business Record Information that Matters Core Support Internal Non-Regulated Info Information that Clutters Drafts, Duplications, Transient Information & Non-Records © 2012 May 7, 2012 4 Compilation of Metrics for Large Clients Network Storage Growth Rate = 60% 2012 2013 2014 2015 2016 2017 2018 © 2012 May 7, 2012 5 Centralized control Decentralized control Probably not Web2.0 Probably Web2.0 IT driven Friendly, user-driven Friendly user driven Corporate development Peer collaboration Collaborative structure Controlled structure Engaging Transactional Connect & collaborate Execute Social backbone & oh, by the Information backbone way, it contains “R”ecords, “r”ecords & information © 2012 May 7, 2012 62012 Managing Electronic Records Conference 7.2
  • 3. Cohasset Associates, Inc. NOTES Understand Capabilities of Your Tools Examples of Metadata Examples of Examples of Used for Triggers Aggregations Actions Date Closed Category Archive Date Created Folder Destroy Date Declared Date Last Accessed Record Export Date Last Modified Document Sets Transfer Date Last Retrieved Volume Inactive Major/Minor Version Status Review Status Workflow Trigger Wrapped in Workflow © 2012 May 7, 2012 7 Understand Capabilities of Your Tools Metadata Period Then Take Action Metadata Period Then Take Action Metadata Period Then Take Action Metadata Period Then Take Action © 2012 May 7, 2012 8 Understand Capabilities of Your Tools Metadata Period Then Take Action Annual Aggregation or “Cut Off” Metadata Period Then Take Action Metadata Period Then Take Action Metadata Period Then Take Action © 2012 May 7, 2012 92012 Managing Electronic Records Conference 7.3
  • 4. Cohasset Associates, Inc. NOTES Act Reasonably Minimize manual entry of metadata Capture through workflow, etc. For retention management, rely on existing metadata, when practical metadata Simplify Security Proactively apply Holds Streamline disposition Replace “Review & Approve” with “Notify” © 2012 May 7, 2012 10 Act Reasonably Official Be Precise Business Record Information that Matters Core Support Be Careful Internal Focus on Non-Regulated Info Delete Information that Clutters Drafts, Duplications, Transient Information & Non-Records Delete ASAP! © 2012 May 7, 2012 11 Retention & ESI Paths to Success Exploit Capabilities of Your Tools © 2012 May 7, 2012 122012 Managing Electronic Records Conference 7.4
  • 5. Cohasset Associates, Inc. NOTES Consider Change “Until Tax Audit” or “Exam” Alternatives to: Before Using XX Years = Typical “Conditional” Tax Settlement Retention /Exam Cycle Periods: Accounting Use Records Holds for Exceptions © 2012 May 7, 2012 13 Create Date 10 Years Then Delete © 2012 May 7, 2012 14 Create Date 10 Years Then Delete Annual Aggregation or “Cut Off” © 2012 May 7, 2012 152012 Managing Electronic Records Conference 7.5
  • 6. Cohasset Associates, Inc. NOTES Create Date 2 Years Then Archive Annual Aggregation or “Cut Off” “To Be Archive Date 8 Years Then Deleted” “To Be 30 Days Then Delete Deleted” © 2012 May 7, 2012 16 Create Date 9 Months Then Delete Drafts Create Date 2 Years Then Archive Annual Aggregation or “Cut Off” “To Be Archive Date 8 Years Then Deleted” “To Be 30 Days Then Delete Deleted” © 2012 May 7, 2012 17 Date Last 6 Months Then Delete Drafts Modified Create Date 2 Years Then Archive Annual Aggregation or “Cut Off” Archive Date A hi D t 8Y Years “To Be Then Deleted” Fixed Date 12/31/2015 “To Be 30 Days Then Delete Deleted” © 2012 May 7, 2012 182012 Managing Electronic Records Conference 7.6
  • 7. Cohasset Associates, Inc. NOTES Separate Projects by Consider Metadata, Librarie Alternatives s, Folders... Before Using Change “Project “Conditional” Completion Completion” to: Retention Periods: Last Action for Projects Specific Project’s Library or Folder © 2012 May 7, 2012 19 “Case Files” Characteristics of a “Case We think in terms of File” “folders” holding “Case Accumulates records and Files” information over time But, what is a “folder”? Information is “put “Folder” Folder together” either logically or physically Library Nearly always requires an Metadata “event-based” retention period © 2012 May 7, 2012 20 Enter Event Manual or Automatically Data Fed by an Upstream System Event Date 2 Years Then Archive “To Be Archive Date 8 Years Then Deleted Deleted” “To Be 30 Days Then Delete Deleted” © 2012 May 7, 2012 212012 Managing Electronic Records Conference 7.7
  • 8. Cohasset Associates, Inc. NOTES Last Content 2 Years Then Archive Modify Date “To Be Archive Date 8 Years Then Deleted Deleted” “To Be 30 Days Then Delete Deleted” © 2012 May 7, 2012 22 Longest Consider Employment Period? Alternatives Before Using Change “Conditional” “Termination” to: Termination Retention Periods: 50 Years (Longest Payroll Employment + 7- 10 Year Period) © 2012 May 7, 2012 23 Eliminate the Event Date Termination of Employment+ 10 Years Longest employment period is 40 Years Implement retention as “50 Years” Create Date 2 Years Then Archive “To Be Archive Date 48 Years Then Deleted” “To Be 30 Days Then Delete Deleted” © 2012 May 7, 2012 242012 Managing Electronic Records Conference 7.8
  • 9. Cohasset Associates, Inc. NOTES Establish 3-Year Consider P&P Review Process Alternatives Before Using Change “Until “Conditional” Updated Updated” to: Retention Periods: 10 Years (3-Year P&Ps Review + 7 Year Period) © 2012 May 7, 2012 25 Eliminate the Event Date Obsolescence + 7 Years Establish 3 year review cycle Implement retention as “10 Years” Kick-Off Ki k Off Create Date 3 Years Then Review WF 3 Years + Create Date Then Archive 6 Months “To Be Archive Date 48 Years Then Deleted” “To Be 30 Days Then Delete Deleted” © 2012 May 7, 2012 26 Use Versions to Manage Event Obsolescence + 7 Years Establish 3 year review cycle Implement retention as “10 Years” Date Last Auto Declare & 6 Months Then Modified Delete Drafts Kick-Off Date Declared 3 Years Then Review WF Delete Prior Date Declared 7 Years Then Versions © 2012 May 7, 2012 272012 Managing Electronic Records Conference 7.9
  • 10. Cohasset Associates, Inc. NOTES Consider Alternatives Before Using “Conditional” Retention Official Periods: Business Record Information Information that Matters Core Support that Clutters Focus on Internal Delete Non-Regulated Info Information Delete Drafts, Duplications, Transient that Clutters ASAP! Information & Non-Records © 2012 May 7, 2012 28 Non-Regulated Internal Operating Information with Event-based Retention Examples Maximum of X Years after [Event] While Useful for Internal Operations Collaborate with users Accept imprecision of creation-date retention A ti i i f ti d t t ti Creatively use existing metadata Date Last Viewed Status or “user rating” of information Set a maximum period, using a date field that is always populated © 2012 May 7, 2012 29 Retention & ESI Paths to Success Collapse Retention Periods © 2012 May 7, 2012 302012 Managing Electronic Records Conference 7.10
  • 11. Cohasset Associates, Inc. NOTES Option 1: Select the Longest Retention Period Product Marketing (10 Years) Brand Corporate Management Granting & Outreach (7 Years) (5 Years) Collaboration Site 10 Years © 2012 May 7, 2012 31 Option 2: Select a Few Retention Periods 3 Years (General) <1 Year 7 Years (Transitory) (Regulated) E-Mail Archive E-Mail > 7 Years: 3 & 7 Years Other Repository © 2012 May 7, 2012 32 Option 2: Select a Few Retention Periods 7 Years (General Accounting) Disposition+7 Years Max+7 Years (Financial Planning) (Assets, Investments, Obligations) Enterprise Application Permanent (GAAP Annual 2 Years (Internal Controls) 7 Years, Statements) Disp+7 Years & Permanent © 2012 May 7, 2012 332012 Managing Electronic Records Conference 7.11
  • 12. Cohasset Associates, Inc. NOTES Retention & ESI Paths to Success Be Responsible & Avoid Paralysis © 2012 May 7, 2012 34 RM Tools Technology High Manual Labor Low Resource Controls & Requirements Results © 2012 May 7, 2012 35 The 2011/2012 ESI Survey Says…. Does your organization use fully automated, semi-automated or completely manual processes when deleting info that is stored in: Paper Email Email Archives Voice Mail Network Files Desktop Fil D k Files Completely Manual Mobile Devices Semi-Automated Collaborative Tools Fully Automated EDM/ECM/Imaging App Data Data in the Cloud Social Networking © 2012 May 7, 2012 362012 Managing Electronic Records Conference 7.12
  • 13. Cohasset Associates, Inc. NOTES The 2011 ERM Survey Says…. How effectively are retention schedules applied and eligible information destroyed when stored in: Paper Email Email Archives Voice Mail Network Files Marginal Desktop Fil D k Files Fair Mobile Devices Good Collaborative Tools Great EDM/ECM/Imaging Excellent App Data Data in the Cloud Social Networking © 2012 May 7, 2012 37 The 2011/2012 ESI Survey Says…. Combination of both charts on the deletion of eligible information, when stored in: Paper Completely Manual Email Semi-Automated Email Archives Fully Automated Voice Mail Network Files Desktop Files Marginal Mobile Devices Fair Collaborative Tools Good EDM/ECM/Imaging Great App Data Excellent Data in the Cloud Social Networking 0% 20% 40% 60% 80% 100% © 2012 May 7, 2012 38 Start a Continuous Improvement Program for Records Management Define a continuous improvement Records management is: process A compliance program Chip away at the barriers A risk mitigation program Do what is reasonable A series of processes Do not become paralyzed by the Records management is not a fear of imperfection p project Doing nothing is not an option Projects may be Consider resources and prioritize undertaken, but the program retention implementation is not merely a series of New or replacement systems projects Regulated or long-term recordkeeping systems Records management cannot Loop back and improve processes be cost-justified considering using new resources, as they are storage, alone available © 2012 May 7, 2012 392012 Managing Electronic Records Conference 7.13
  • 14. Cohasset Associates, Inc. NOTES Achieve the Right Mix of Great and Good Enough Understand organizational barriers Engage stakeholders Focus on risk and value Choose a path f the Ch h for h journey Commit to the journey © 2012 May 7, 2012 40 Q&A © 2012 May 7, 2012 41 Retention & ESI Paths to Success Part Two Carol Stainbrook & Christine M. Burns May 7, 2012 422012 Managing Electronic Records Conference 7.14