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Cohasset Associates, Inc. NOTES 7.1 2012 Managing Electronic Records Conference Retention & ESI Retention & ESI Paths to Success Paths to Success Part Two May 7, 2012 1 Carol Stainbrook & Christine M. Burns Applying Retention to ESI Using Semi-Automated & Automated Tools Devise a Plan Based on Reasonableness Exploit Capabilities of Your Tools Creation Date E D © 2012 Event Date Versioning Retention Strategy for Different System Types Be Responsible & Avoid Paralysis May 7, 2012 2 Retention & ESI Retention & ESI Paths to Success Paths to Success © 2012 Think Strategically Learn Capabilities Act Reasonably May 7, 2012 3

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

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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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Page 1: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.12012 Managing Electronic Records Conference

Retention & ESIRetention & ESIPaths to SuccessPaths to Success

Part Two

May 7, 2012 1

Carol Stainbrook & Christine M. Burns

Applying Retention to ESI Using Semi-Automated & Automated Tools

Devise a Plan Based on ReasonablenessExploit Capabilities of Your Tools

Creation DateE D

© 2012

Event DateVersioning

Retention Strategy for Different System TypesBe Responsible & Avoid Paralysis

May 7, 2012 2

Retention & ESI Retention & ESI Paths to SuccessPaths to Success

© 2012

Think StrategicallyLearn Capabilities Act Reasonably

May 7, 2012 3

Page 2: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.22012 Managing Electronic Records Conference

All Information is Not Equal

Official Business Record

Core Support

Information that Matters

© 2012 May 7, 2012 4

Core Support

Internal Non-Regulated Info

Drafts, Duplications, Transient Information & Non-Records

Information that Clutters

Compilation of Metrics for Large Clients

Network Storage Growth Rate = 60%

© 2012

2012 2013 2014 2015 2016 2017 2018

May 7, 2012 5

Centralized controlProbably not Web2.0IT driven

Decentralized controlProbably Web2.0Friendly user-driven

© 2012

IT drivenCorporate developmentControlled structureTransactionalExecuteInformation backbone

Friendly, user driven Peer collaborationCollaborative structureEngagingConnect & collaborate Social backbone & oh, by the way, it contains “R”ecords, “r”ecords & information

May 7, 2012 6

Page 3: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.32012 Managing Electronic Records Conference

Understand Capabilities of Your Tools

Examples of Metadata Used for Triggers

Date Closed

Date Created

Date Declared

Examples of Actions

Archive

Destroy

Examples of Aggregations

Category

Folder

© 2012 May 7, 2012 7

Date Declared

Date Last Accessed

Date Last Modified

Date Last Retrieved

Major/Minor Version Status

Status

Workflow Trigger

Export

Transfer

Inactive

Review

Record

Document Sets

Volume

Wrapped in Workflow

Understand Capabilities of Your Tools

Metadata Period Take Action

Metadata Period Take Action

Then

Then

© 2012 May 7, 2012 8

Metadata Period Take Action

Metadata Period Take Action

Then

Then

Annual Aggregation or “Cut Off”

Understand Capabilities of Your Tools

Metadata Period Take Action

Metadata Period Take Action

Then

Then

© 2012 May 7, 2012 9

Metadata Period Take Action

Metadata Period Take Action

Then

Then

Page 4: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.42012 Managing Electronic Records Conference

Act Reasonably

Minimize manual entry of metadataCapture through workflow, etc.

For retention management, rely on existing metadata when practical

© 2012

existing metadata, when practicalSimplify SecurityProactively apply HoldsStreamline disposition

Replace “Review & Approve” with “Notify”

May 7, 2012 10

Official Business Record

Core Support

Information that Matters

Act Reasonably

Be Precise

Be Careful

© 2012 May 7, 2012 11

Core Support

Internal Non-Regulated Info

Drafts, Duplications, Transient Information & Non-Records

Information that Clutters

Focus on Delete

Delete ASAP!

Retention & ESI Retention & ESI Paths to SuccessPaths to Success

© 2012

Exploit Capabilities of Your Tools

May 7, 2012 12

Page 5: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.52012 Managing Electronic Records Conference

Consider Alternatives Before Using “Conditional”

Change “Until Tax Audit” or “Exam” to:

XX Years = Typical Tax Settlement

© 2012

Retention Periods:Accounting

Tax Settlement /Exam Cycle

Use Records Holds for Exceptions

May 7, 2012 13

Create Date 10 Years DeleteThen

© 2012 May 7, 2012 14

Annual Aggregation or “Cut Off”

Create Date 10 Years DeleteThen

© 2012 May 7, 2012 15

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Cohasset Associates, Inc.

NOTES

7.62012 Managing Electronic Records Conference

Annual Aggregation or “Cut Off”

Create Date 2 Years ArchiveThen

Archive Date 8 Years “To Be Then

© 2012 May 7, 2012 16

Archive Date 8 Years Deleted”

“To Be Deleted” 30 Days Delete

Then

Then

Annual Aggregation or “Cut Off”

Create Date 2 Years ArchiveThen

Archive Date 8 Years “To Be Then

Create Date 9 Months Delete DraftsThen

© 2012 May 7, 2012 17

Archive Date 8 Years Deleted”

“To Be Deleted” 30 Days Delete

Then

Then

Annual Aggregation or “Cut Off”

Create Date 2 Years ArchiveThen

Date Last Modified 6 Months Delete DraftsThen

A hi D t 8 Y

© 2012 May 7, 2012 18

Archive Date 8 Years“To Be

Deleted”Fixed Date 12/31/2015

Then

“To Be Deleted” 30 Days DeleteThen

Page 7: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.72012 Managing Electronic Records Conference

Consider Alternatives Before Using “Conditional”

Separate Projects by Metadata, Libraries, Folders...

Change “Project Completion” to:

© 2012

Retention Periods:Projects

Completion to:

Last Action for Specific Project’s Library or Folder

May 7, 2012 19

“Case Files”

Characteristics of a “Case File”

Accumulates records and information over timeInformation is “put

We think in terms of “folders” holding “Case Files”But, what is a “folder”?

“Folder”

© 2012

together” either logically or physicallyNearly always requires an “event-based” retention period

FolderLibraryMetadata

May 7, 2012 20

Event Date 2 Years ArchiveThen

Archive Date 8 Years “To Be Deleted”Then

Enter Event Data

Manual or Automatically Fed by an Upstream System

© 2012 May 7, 2012 21

Deleted

“To Be Deleted” 30 Days DeleteThen

Page 8: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.82012 Managing Electronic Records Conference

Last Content Modify Date 2 Years ArchiveThen

Archive Date 8 Years “To Be Deleted”Then

© 2012 May 7, 2012 22

Deleted

“To Be Deleted” 30 Days DeleteThen

Consider Alternatives Before Using “Conditional”

Longest Employment Period?

Change “Termination” to:

© 2012

RetentionPeriods:Payroll

Termination to:

50 Years (Longest Employment + 7-10 Year Period)

May 7, 2012 23

Eliminate the Event Date

Termination of Employment+ 10 YearsLongest employment period is 40 YearsImplement retention as “50 Years”

© 2012 May 7, 2012 24

Create Date 2 Years ArchiveThen

Archive Date 48 Years “To Be Deleted”

“To Be Deleted” 30 Days Delete

Then

Then

Page 9: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.92012 Managing Electronic Records Conference

Consider Alternatives Before Using “Conditional”

Establish 3-Year P&P Review Process

Change “Until Updated” to:

© 2012

RetentionPeriods:P&Ps

Updated to:

10 Years (3-Year Review + 7 Year Period)

May 7, 2012 25

Eliminate the Event Date

Obsolescence + 7 YearsEstablish 3 year review cycleImplement retention as “10 Years”

Ki k Off

© 2012 May 7, 2012 26

Create Date 3 Years + 6 Months ArchiveThen

Archive Date 48 Years “To Be Deleted”

“To Be Deleted” 30 Days Delete

Then

Then

Create Date 3 Years Kick-Off Review WF

Then

Use Versions to Manage Event

Obsolescence + 7 YearsEstablish 3 year review cycleImplement retention as “10 Years”

© 2012 May 7, 2012 27

Date Declared 3 Years Kick-Off Review WF

Then

Date Declared 7 Years Delete Prior Versions

Then

Date Last Modified 6 Months Auto Declare &

Delete DraftsThen

Page 10: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.102012 Managing Electronic Records Conference

Consider Alternatives Before Using “Conditional”RetentionPeriods:

Official Business Record

Information

© 2012

Information that Clutters

May 7, 2012 28

Record

Core Support

Internal Non-Regulated Info

Drafts, Duplications, Transient Information & Non-Records

that Matters

Information that Clutters

Focus on Delete

Delete ASAP!

Non-Regulated Internal Operating Information with Event-based Retention

ExamplesMaximum of X Years after [Event]While Useful for Internal Operations

Collaborate with usersA t i i i f ti d t t ti

© 2012

Accept imprecision of creation-date retentionCreatively use existing metadata

Date Last ViewedStatus or “user rating” of information Set a maximum period, using a date field that is always populated

May 7, 2012 29

Retention & ESI Retention & ESI Paths to Paths to SuccessSuccess

© 2012

Collapse Retention Periods

30May 7, 2012

Page 11: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.112012 Managing Electronic Records Conference

Option 1: Select the Longest Retention Period

Brand Management

Product Marketing (10 Years)

Corporate

© 2012 31May 7, 2012

Collaboration Site

10 Years

Management & Outreach

(5 Years)

Granting(7 Years)

Option 2: Select a FewRetention Periods

<1 Year

3 Years (General)

7 Years

© 2012

E-Mail Archive

3 & 7 Years

<1 Year (Transitory)

7 Years (Regulated)

E-Mail > 7 Years:Other Repository

32May 7, 2012

Option 2: Select a FewRetention Periods

Max+7 Years (Financial Planning)

7 Years (General Accounting)

Disposition+7 Years (Assets, Investments, Obligations)

© 2012

Enterprise Application

7 Years,Disp+7 Years &

Permanent

2 Years (Internal Controls) Permanent (GAAP Annual Statements)

33May 7, 2012

Page 12: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.122012 Managing Electronic Records Conference

Retention & ESI Retention & ESI Paths to SuccessPaths to Success

© 2012

Be Responsible & Avoid Paralysis

May 7, 2012 34

RM ToolsTechnology High

© 2012 May 7, 2012 35

Manual Labor Low

Resource Requirements

Controls & Results

Does your organization use fully automated, semi-automated or completely manual processes when deleting info that is stored in:

D k FilNetwork Files

Voice MailEmail Archives

EmailPaper

The 2011/2012 ESI Survey Says….

© 2012

Social NetworkingData in the Cloud

App DataEDM/ECM/ImagingCollaborative Tools

Mobile DevicesDesktop Files Completely Manual

Semi-Automated

Fully Automated

May 7, 2012 36

Page 13: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.132012 Managing Electronic Records Conference

How effectively are retention schedules applied and eligible information destroyed when stored in:

D k FilNetwork Files

Voice MailEmail Archives

EmailPaper

Marginal

The 2011 ERM Survey Says….

© 2012

Social NetworkingData in the Cloud

App DataEDM/ECM/ImagingCollaborative Tools

Mobile DevicesDesktop Files Fair

Good

Great

Excellent

May 7, 2012 37

Combination of both charts on the deletion of eligible information, when stored in:

Desktop FilesNetwork Files

Voice MailEmail Archives

EmailPaper

Completely Manual

Semi-Automated

Fully Automated

The 2011/2012 ESI Survey Says….

© 2012

0% 20% 40% 60% 80% 100%

Social NetworkingData in the Cloud

App DataEDM/ECM/ImagingCollaborative Tools

Mobile DevicesDesktop Files

Marginal

Fair

Good

Great

Excellent

May 7, 2012 38

Start a Continuous Improvement Program for Records Management

Define a continuous improvement processChip away at the barriersDo what is reasonableDo not become paralyzed by the fear of imperfection

Records management is:A compliance programA risk mitigation programA series of processes

Records management is not a project

© 2012

pDoing nothing is not an option

Consider resources and prioritize retention implementation

New or replacement systemsRegulated or long-term recordkeeping systems

Loop back and improve processes using new resources, as they are available

projectProjects may be undertaken, but the program is not merely a series of projects

Records management cannot be cost-justified considering storage, alone

39May 7, 2012

Page 14: M12S07 - Retention & ESI - Paths to Success - Part Two

Cohasset Associates, Inc.

NOTES

7.142012 Managing Electronic Records Conference

Achieve the Right Mix of Great and Good Enough

Understand organizational barriersEngage stakeholdersFocus on risk and valueCh h f h

© 2012

Choose a path for the journeyCommit to the journey

40May 7, 2012

Q & A

© 2012 May 7, 2012 41

Retention & ESIRetention & ESIPaths to SuccessPaths to Success

Part Two

May 7, 2012 42

Carol Stainbrook & Christine M. Burns