e-Records for Compliance Presented by: Bruce Miller The role of electronic recordkeeping in a...
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Transcript of e-Records for Compliance Presented by: Bruce Miller The role of electronic recordkeeping in a...
e-Records for Compliance
Presented by:
Bruce Miller
The role of electronic recordkeeping in a compliance setting
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations
CSFB BankerQuattrone Resigns Star During Tech Boom Now Facing Investigations of Document HandlingBrooke A. Masters--Washington Post Staff WriterMarch 5, 2003; Page E1 Frank P. Quattrone, the Credit Suisse First Boston Corp. banker who became a star during the Internet boom, quit today in the face allegations that he destroyed documents to obstruct an investigation. New York state Attorney General Eliot L. Spitzer and U.S. Attorney James B. Comey of the Southern District of New York are expected to complete their investigations of Quattrone within weeks, sources familiar with the probes said. Both are looking at…
CSFB BankerQuattrone Resigns Star During Tech Boom Now Facing Investigations of Document HandlingBrooke A. Masters--Washington Post Staff WriterMarch 5, 2003; Page E1 Frank P. Quattrone, the Credit Suisse First Boston Corp. banker who became a star during the Internet boom, quit today in the face allegations that he destroyed documents to obstruct an investigation. New York state Attorney General Eliot L. Spitzer and U.S. Attorney James B. Comey of the Southern District of New York are expected to complete their investigations of Quattrone within weeks, sources familiar with the probes said. Both are looking at…
Think Records Management is Just “Nice to Have?”
…Think Again !!!
E-Mails Reveal Shuttle ConcernsNASA Engineers In Va. Fretted About InactionR. Jeffrey Smith--Washington Post Staff WriterFebruary 22, 2003; Page A1 NASA engineers at the Langley Research Center in Virginia expressed frustration during and shortly after the space shuttle Columbia's disastrous flight that the space agency failed to investigate thoroughly whether it had been seriously damaged by debris during launch, according to a series of internal e-mails disclosed yesterday. In one e-mail sent three days before the shuttle disintegrated on Feb. 1 as it hit the atmosphere, a Langley…
E-Mails Reveal Shuttle ConcernsNASA Engineers In Va. Fretted About InactionR. Jeffrey Smith--Washington Post Staff WriterFebruary 22, 2003; Page A1 NASA engineers at the Langley Research Center in Virginia expressed frustration during and shortly after the space shuttle Columbia's disastrous flight that the space agency failed to investigate thoroughly whether it had been seriously damaged by debris during launch, according to a series of internal e-mails disclosed yesterday. In one e-mail sent three days before the shuttle disintegrated on Feb. 1 as it hit the atmosphere, a Langley…
Credit Suisse Puts Banker On Leave E-Mail Suggests He Was Aware of ProbesBrooke A. Masters--Washington Post Staff WriterFebruary 4, 2003; Page E1 Credit Suisse First Boston Corp. put star investment banker Frank Quattrone on administrative leave yesterday after discovering e-mails that suggest he knew about ongoing criminal and regulatory probes when he and a subordinate advised employees to "clean up those files," sources familiar with the matter said. The U.S. attorney's office in Manhattan opened a probe into the e-mails after receiving copies of the information from CSFB on Friday…
Credit Suisse Puts Banker On Leave E-Mail Suggests He Was Aware of ProbesBrooke A. Masters--Washington Post Staff WriterFebruary 4, 2003; Page E1 Credit Suisse First Boston Corp. put star investment banker Frank Quattrone on administrative leave yesterday after discovering e-mails that suggest he knew about ongoing criminal and regulatory probes when he and a subordinate advised employees to "clean up those files," sources familiar with the matter said. The U.S. attorney's office in Manhattan opened a probe into the e-mails after receiving copies of the information from CSFB on Friday…E-Mail Evidence Allowed in J.P. Morgan Case Official's Messages May Bolster Claim That Company Helped Enron Hide DebtPeter Behr--Washington Post Staff WriterDecember 24, 2002; Page E2 A federal judge ruled yesterday that e-mails from a J.P. Morgan Chase & Co. official referring to "disguised loans" may be entered as evidence in a civil trial, supporting allegations that the company helped Enron Corp. conceal its growing debt before its collapse. U.S. District Judge Jed S. Rakoff had initially kept the memos by Chase Vice Chairman Donald Layton to others within the financial giant away from the jury, saying their impact could be…
E-Mail Evidence Allowed in J.P. Morgan Case Official's Messages May Bolster Claim That Company Helped Enron Hide DebtPeter Behr--Washington Post Staff WriterDecember 24, 2002; Page E2 A federal judge ruled yesterday that e-mails from a J.P. Morgan Chase & Co. official referring to "disguised loans" may be entered as evidence in a civil trial, supporting allegations that the company helped Enron Corp. conceal its growing debt before its collapse. U.S. District Judge Jed S. Rakoff had initially kept the memos by Chase Vice Chairman Donald Layton to others within the financial giant away from the jury, saying their impact could be…
5 Firms To Pay for E-Mail Lapses $1.65 Million Fines, Promises to ImproveBen White--Washington Post Staff WriterDecember 4, 2002; Page E1 Five Wall Street firms agreed today to pay $1.65 million each to settle allegations that they failed to properly save e-mail. The fines, levied by the Securities and Exchange Commission and the securities industry's two self-regulatory bodies, the New York Stock Exchange and NASD, are separate from the much larger amounts a dozen Wall Street firms are expected to pay as part of a proposed "global settlement" to end several conflict-of-interest investigations…
5 Firms To Pay for E-Mail Lapses $1.65 Million Fines, Promises to ImproveBen White--Washington Post Staff WriterDecember 4, 2002; Page E1 Five Wall Street firms agreed today to pay $1.65 million each to settle allegations that they failed to properly save e-mail. The fines, levied by the Securities and Exchange Commission and the securities industry's two self-regulatory bodies, the New York Stock Exchange and NASD, are separate from the much larger amounts a dozen Wall Street firms are expected to pay as part of a proposed "global settlement" to end several conflict-of-interest investigations…
INS Under Pile of Backlogged Paper Agency Reveals It Shuffled 2 Million Documents to Warehouse in the MidwestChristopher Newton--Associated PressAugust 3, 2002; Page A8 More than 2 million documents filed by foreigners, from change-of-address forms to requests for benefits, have been piling up for years and only now are being reviewed by the government, senior U.S. officials said yesterday. Immigrant advocates said that means some foreigners deported secretly after Sept. 11 might have been in compliance with laws they were expelled for breaking. The government has not revealed previously the extent to which…
INS Under Pile of Backlogged Paper Agency Reveals It Shuffled 2 Million Documents to Warehouse in the MidwestChristopher Newton--Associated PressAugust 3, 2002; Page A8 More than 2 million documents filed by foreigners, from change-of-address forms to requests for benefits, have been piling up for years and only now are being reviewed by the government, senior U.S. officials said yesterday. Immigrant advocates said that means some foreigners deported secretly after Sept. 11 might have been in compliance with laws they were expelled for breaking. The government has not revealed previously the extent to which…
Lawmakers Ask Stewart For More DocumentsBen White--Washington Post Staff WriterAugust 7, 2002; Page E1 A congressional committee today requested more documents regarding the sale of ImClone Systems Inc. stock by high-profile media company owner Martha Stewart. Rep. W.J. "Billy" Tauzin (R-La.), chairman of the House Energy and Commerce Committee, chastised Stewart and her attorneys in a sharply worded letter for not moving fast enough to explain why she sold her ImClone shares Dec. 27, the day before the company announced that the Food and Drug Administration had refused an…
Lawmakers Ask Stewart For More DocumentsBen White--Washington Post Staff WriterAugust 7, 2002; Page E1 A congressional committee today requested more documents regarding the sale of ImClone Systems Inc. stock by high-profile media company owner Martha Stewart. Rep. W.J. "Billy" Tauzin (R-La.), chairman of the House Energy and Commerce Committee, chastised Stewart and her attorneys in a sharply worded letter for not moving fast enough to explain why she sold her ImClone shares Dec. 27, the day before the company announced that the Food and Drug Administration had refused an…Federal Court
Subpoenas United Way Financial DataCharity Asked for Documents Dating to 1997Peter Whoriskey--Washington Post Staff WriterJuly 17, 2002; Page B1 FBI agents delivered a subpoena yesterday to the United Way of the National Capital Area, requesting the charity's financial records, board membership lists and other documents. The grand jury subpoena was delivered to Norman O. Taylor, chief executive of the group, and called for documents dating to 1997, according to Irving Kator, the attorney for the charity. The federal inquiry follows a year of allegations of financial mismanagement at the…
Federal Court Subpoenas United Way Financial DataCharity Asked for Documents Dating to 1997Peter Whoriskey--Washington Post Staff WriterJuly 17, 2002; Page B1 FBI agents delivered a subpoena yesterday to the United Way of the National Capital Area, requesting the charity's financial records, board membership lists and other documents. The grand jury subpoena was delivered to Norman O. Taylor, chief executive of the group, and called for documents dating to 1997, according to Irving Kator, the attorney for the charity. The federal inquiry follows a year of allegations of financial mismanagement at the…
Getting in Trouble Without e-Records Who Incident Consequence Cost
GM Tax return Audit Unexpected tax hit $M’s
MicrosoftEmail About Netscape Strategy
Loss of AntiTrust Suit $100M’s
Anderson &Enron Document Shredding SEC Litigation Bankruptcy
US Defense Gulf War Syndrome Litigation $1B
Enron’s Law Firm SEC Charge Replaced all hard drives $800K
FordTire Replacement Program
Loss of Reputation, reduced profit
$500K
Exxon/Mobil MergingDocument deletion dis-allowed for 18 months
$M’s
1. To stay out of legal trouble• Risk of Litigation/Embarrassment– Enron, Microsoft, DoD
2. To Prove Compliance with regulations– SEC, EPA, Privacy, HIPAA, etc.
3. Because they are forced to• Government Mandates• USA (DoD), Canada (RDIMS), UK (PRO), Australia (VERS),
EU (MoREQ) have mandated e-Records
4. To Save $$$• Downstream Cost Avoidance– Cost of litigation (discovery), cost of major mistakes
Why Businesses need e-Records
e-Records as a Contribution to Market Requirements
USA(5015.2)
United Kingdom(PRO)
Australia(VERS)
e-Recordse-Records
e-Records
•Doc Search•GUI
Regulatory Compliance
Financial Svc(SEC)
Pharma(21 CFR 11)
HeathCare(HIPAA)
e-Records
e-Records
e-Records
•WORM Storage•Surveillance•Duplication•Email Capture•Search/Retrieve
•Privacy•Digital Rights•Security
•Privacy•Digital Rights•Security
Mandated Govt. Standards
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations
RecordKeeping for Compliance
• Avg. Acquisition size Approaching 10,000 users– Ability to scale up = key!
• Significant Buyer Skepticism– Many failed pilots.– Poor user acceptance.– Deployment capability = key!
• IT Managers, not Records Managers, = Buyer– Records people in support role only.
What You Need to Know About the Market
• Solutions Must Scale Up– Average implementation size approaching 10,000 users
and up– Requires advanced, web-based technology
• e-Records for ALL Business Processes– Users do not want a desktop application for e-records– Need a way to records-enable all the business processes
• Market is Lacking RM Understanding and Skills– Buyers and Sellers Do not know RM and its
implications– Shortage of Recordkeeping Skills
Major Market Trends
62
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations
RecordKeeping for Compliance
A Strategic View of the Emerging Compliance Marketplace
1. Compliance has several forms and meanings
2. A mix of technologies is required for solutions
3. Two “foundation” technologies are common to all compliance
requirements
4. Technology must be accompanied by tremendous industry
knowledge
5. The technology must “snap to” a proper business framework
A Prescription for Compliance
EvaluateRegulations
RiskAssessment
EstablishFramework
Foundation•Setup
•Capture•Classify
•Pilot•Metrics•Monitor
•Optimize
Snap-InCompliance
Get Ready
Foundation
Compliance
The Major Regulations Affecting Many Enterprises
Major Regulations Intent Applicability
SEC/NASD Prevent Securities Fraud All financial institutions and companies regulated by the SEC
Sarbanes Oxley Ensure Accountability for Public Firms
All Public Companies trading on a US Exchange
HIPAA Privacy/Accountability for Healthcare Providers/Insurers
HealthCare providers/insurers. Human and veterinarian
US DoD 5015.2 Electronic Recordkeeping US Government, particularly DoD
21CFR 11 Approval Accountability Pharma manufacturers and regulators, related parties
Many additional smaller, contributing regulations
What you do determines which Regulations Apply
SEC/NASD Sarbanes Oxley
SEC/NASD+
SarbanesOxley
TradingIn
Securities
A PublicCompany
A Public Company (Sarbanes Oxley applies) trading in Securities (SEC/NASD applies)
Translating Requirements to TechnologyExample SEC/NASD Requirements
Requirement Met By
Capture all correspondence (unmodified) [17a-4(f)(3)(v)] Capture in/out Email before reaching user(s)
Store in Non-rewritable, non-erasable format [17a-4(f)(2)(ii)(A)] WORM storage of all email, all documents
Verify automatically recording quality and accuracy [17a-4(f)(2)(ii)(B)] Validated storage to magnetic, worm.
Duplicate data and index storage[17a-4(f)(3)(iii)] Mirrored or duplicate storage servers
Enforce Retention Periods on all stored data and indexes[17a-4(f)(3)(iv)(c)]
Structured Records management
Search/Retrieve all stored data and indexes[17a-4(f)(2)(ii)(D)] High-performance search/retrieval
The Functionality/Capabilities RequiredEight Distinct Technologies
• Records Management (e-records)– Controlled, process-driven Document Retention and Destruction
• Content Management– Document Storage, high-performance search/retrieval, Version Management
• Storage Management– Duplicate/triplicate, non-erasable, disaster recovery– Contextual metadata (index data)
• BI/CPM– Business Intelligence/Corporate Performance Monitoring– Identify and report on key financial performance indicators
• Supervision– Monitor/review/intercept trading correspondence (email/IM/other)
• Email/IM Capture & Management– Intercept email/IM, store & review/retrieve
• Collaboration– Sharing, production of audit review documents– Audit process controls
• Digital Rights Management/Privacy– Digital Signatures/Authorization– Access/Rights Management
Translating Requirements to Technology
5015.2 SEC/NASD 21CFR11 HIPAA Sarbanes/Oxley
e-Rec
ords
Content M
anag
emen
t
Stora
ge M
anag
emen
t
BI/CPM
Supervi
sion
Emai
l/IM
Man
agem
ent
Collabora
tion
Rights
Man
agem
ent
To Deliver Solutions Against these Requirements, Vendors Must;
• Deliver the appropriate mix of technologies required to meet the requirements
• Carefully and thoughtfully integrate the various technologies into a seamless solution
• Incorporate strong knowledge of the particular industry’s requirements into the solution
• The solution must be “snapped to” a business’s internal framework of policies and processes that reflect the requirements
Two Foundation Technologies
ECM
e-Records
Supervisionof
Trading
Non-ErasableData Duplication
Email/IM Collection
BusinessPerformance Management
Audit Processes& Controls
DocumentCollaboration
Tools
Sarbanes Oxley
Rights ManagementRights Management
E-Records
SEC/NASD
US DoD 5015.2
21CFR11HIPAA
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations
RecordKeeping for Compliance
Records Management – A Fresh Approach
Retention/Disposition Scheduling
Structured File Plan
Records Management
Regulations
Laws
Policies
Corporate Information
Retention&
DispositionDecisions
63
• An e-Record is:– E-mail– Anything at the desktop
• Deleting the right document at the right time (Retention and Disposition).
– Destroy according to law/policy
• e-Records puts the organization in control of the destruction.
• Consists of (3) new capabilities:– Declare– Classify– Apply Life Cycle
The Solution – e-records
e-Records(3) Objectives
1. Declare (User)• Put a document under e-Records management control
2. Classify (User)• Assign a retention rule to the document• Automatic or Manual Classification
3. Apply LifeCycle (Records Administrator)• Apply LifeCycle rules to a declared document• Destroy or Transfer (out) a record
Recordkeeping for End Users
• Declare Electronic/Non-Electronic documents
• Classify during Declaration
Effort
RewardThe
5-second
Rule
???
Classifying a Document
Safety
Inspections
Incidents
Finance
Budgets
Audits
Travel
Requests
Reports
File Plan
Retention Rule 2
Retention Rule 4
Retention Rule 5
Retention Rule 6
Retention Rule 7
Retention Rule 1
Retention Rule 3
Retention Rule 8
Retention Rule 9
Retention Rule 10
Retention Rule 11
Retention Rule 12
Retention Schedule
Doc. 1
Doc. 2
Doc. 3
Doc. 4
Doc. 5
Doc. 6
Rule 1
Rule 3
Rule 1
Rule 5
Rule 8
Rule 8
Classification
US DoD 5015.2 Why pay attention to it?
• No credible alternative.
• 5015.2 forms a meaningful foundation.– The “minimum bar”.
• Ongoing upgrade/development.– ARMA International ERMC.
• Vendors are $$$ bound to it.– Required for most sales.
5015.2-Certified Products CACI's HighView Records Manager v4.1.1 with IBM
Corporation's Records Manager v4.1.1 IBM Corporation's IBM DB2 Records Manager v4.1.1 CEXEC eRecords Enabler V2.0 by CEXEC, Inc. Open Text Corporation's Livelink Records Management
v2.9 FileNet Corporation's FileNet Records Manager v3.0 Stellent, Inc.'s Stellent Records Management v7.1 Accutrac Software, Inc.'s Accutrac XE v2.0 TOWER Software's TRIM Context v5.2 with Microsoft
Corporation's Microsoft SharePoint Portal Server 2003 IBM Corporation's IBM DB2 Records Manager v4.1 Meridio, Inc.'s Meridio v4.2 Meridio, Inc.'s Meridio v4.2 with Microsoft Corporation's
MS SharePoint Portal Server v2.0 Documentum's Documentum Records Manager v4.1 with
MS SharePoint Portal Server 2003 Documentum's Documentum Records Manager v4.1 Documentum's Documentum Records Manager v4.1 with
EMC Corporation's with EMC Centera v2.2 (SP2) Documentum's Documentum Records Manager v4.1 with
ApplicationXtender v5.2 TOWER Software's TRIM Context v5.2 Microsoft Corporation's MS Windows SharePoint Services
2003 with MDY Advanced Technologies, Inc.'s FileSurf 7.5 (SR3)
MDY Advanced Technologies, Inc.'s FileSurf v7.5 (SR3) ZyLAB Technologies BV's ZyIMAGE Records Management
Module v1.0 Objective Corporation Ltd's Objective 7 Stellent, Inc.'s Stellent Records Management v7.0 Zasio Enterprises, Inc.'s Versatile Enterprise v6 Open Text Corporation's Livelink Records Management
v2.7 Feith Systems and Software, Inc.'s Feith Document
Database v7 IBM Corporation's IBM DB2 Records Manager Enabler for
Content Manager v8.2 Optika Inc.'s Acorde Enterprise v4.0
MDY Advanced Technologies, Inc.'s FileSurf v7.50 with NetApp NearStore and NetApp Filer, Decru DataFort, and Documentum
Hyland Software, Inc.'s OnBase Records and Information Management Module v1.0
IBM Corporation's IBM DB2 Records Manager v3.1 LaserFiche's LaserFiche Records Management Edition
v7 MDY Advanced Technologies, Inc.'s FileSurf v7.50 with
Network Appliance, Inc.'s NetApp NearStore and NetApp Filer, Decru Inc.'s DataFort, and KVS, Inc.'s Enterprise Vault v4.0
MDY Advanced Technologies, Inc.'s FileSurf v7.50 with Network Appliance, Inc.'s NetApp NearStore and NetApp Filer and Decru Inc.'s DataFort
Hummingbird, LTD's Hummingbird Enterprise v5.1.1 Integic Corporation's e.POWER Activator v6.3 with
Hummingbird, LTD's Hummingbird Enterprise v5.1.1 MDY Advanced Technologies, Inc.'s FileSurf v7.5 with
KVS, Inc.'s Enterprise Vault v4.0 and EMC Corporation's EMC Centera v2.0
MDY Advanced Technologies, Inc.'s FileSurf v7.5 with KVS, Inc.'s Enterprise Vault v4.0
Cimage NovaSoft, Inc.'s e3-RM 5.0 Vignette Corporation's Vignette Records and Document
Server v4.1 (formerly Seraph v4.1) Documentum's Documentum Records Manager v3.1
with Hummingbird WebTop DM v5.0 IBM Corporation's IBM DB2 Records Manager v2.1.1 TOWER Software's TRIM Context v5.2 170 Systems, Inc.'s 170 MarkView v4 Relativity's Relativity Records Manager (R2M) v3.0 Open Text Corporation's Livelink Records Management
v2.5 for Solaris File Surf v7.50 by MDY Advanced Technologies, Inc.
with iManage MailSite v 6.5 (DMS) by iManage, Inc.
As of Feb. 15 2004
US DoD 5015.2 Standard
• Approved Nov. 1997 for all DND agencies.
• NARA endorsement for US civilian government.
• Vendor Certification Program– Registry of certified products .
• Two certification categories.– RMA products.
– “Product Pairs”.• EDMS with certified RMA products.
http://jitc.fhu.disa.mil/recmgt
Enterprise e-Records
e-Records Server
Metadata
App 1
Declare/ClassifyApp 2
Declare/ClassifyApp 3
Declare/ClassifyApp 5
Declare/Classify
App 6
Declare/ClassifyApp 4
Declare/Classify
File Plan
Retention ScheduleRecords Processes
RecordsAdministration
REPOSITORY REPOSITORY REPOSITORY REPOSITORY REPOSITORY REPOSITORY
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations
RecordKeeping for Compliance
Declaration and Classification
• It’s all that matters!• Declaration
– Getting enough documents declared– Getting them declared at the right time
• Classification– Getting it right
• You’ve got to achieve both• This is what you have to get good at!!!!
You Have to Account for;
To Outwit Your Users
User Attitudes Business Software
Technical PlatformPolicies/Procedures
Declaration – AutomaticWorkFlow
Create Order
Finalize Order
Approval Level 1 Approval Level 2
Place Order
Declare a Record!
“Monitored” Folders
Finance
Safety
Administration
Legal
Declare!
Declare!
~~~~~~~~~
~~~~~~~~~
~~~~~~~~~
~~~~~~~~~
DeclareDocuments
in TheseFolders
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations
RecordKeeping for Compliance
Content Based Auto-Classify
• Software that “reads” a document, reduces to core concept– Uses Neural Net software technology
• Compares document concept to Subject File– Finds the best match– Builds a taxonomy on the target subject
• Self-Learning– Accuracy rises with more attempts
The Challenges of Content-Based Auto-Classification
• High Effort, Low Yield– Takes 10-20 documents to train each subject/activity– Extraordinary setup effort
• Accuracy still only 70%? (under ideal circumstances)
– Works well in well-defined, predictable situations
• Don’t Relate Searching to Classification– Classification is different from searching
• Required for Success– Cost embedded within e-records technology– Easier taxonomy construction– Faster, smarter classification
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it
Work8. Conclusions/Recommendations
RecordKeeping for Compliance
Declaring Electronic RecordsUser Reluctance
• It’s “my” document• This is “too much work”• Let “Admin” do it!
Declare that Document!
“Declaring a document is an unnatural act”
Three “Secrets”of Successful Implementation
1. Success is determined by software implementation, not the software itself
– No matter what the features, users will resist
2. Different apps, platforms, attitudes present different challenges
– A solution that works in one circumstance will not work in another
3. RecordKeeping must be part of the business culture
– Will fail without supporting policies, processes
82
What Implementation is Really All About
81
Declare the Records
Classify Them (correctly)
Apply Disposition to Them
We have to get the records (under our control)
We need to make sure they are (properly) classified
Now we can apply our retention rules to them
Translating to Real Terms
81
Declare the Records
Classify Them (correctly)
Apply Disposition to Them
How are we going to get 10,000 users to do this, reliably and consistently?
How do me make sure classification accuracy rate > 95%?
This cannot be done unless the bottom two layers happen!
This is what we have to achieve!
A 3-Stage Approach to e-Records Success
1.Establish corporate policies based on the regulations that effect you
2.Translate these policies into specific business procedures
3.Apply the technologies to automate and control the business procedures
Technology
Business Procedures
Corporate Policy
Mandates / RegulationsMandates / Regulations
e-Records Implementation Methodology
10. Enterprise Roll-Out
9. Initial Technology Pilot8. Implement RM Technology
7. Map Business Processes6. Implementation Plan/Strategy
5. Strengthen RM Foundation
4. Enshrine Policies3. Corporate Policies
2. Corporate Awareness1. Supporting Structure
Stage 1 - Policies
Stage 2 –Procedures
Stage 3 - Technology
• Users Don’t Want Another Piece of Software for Recordkeeping.
– Perceived as Administration.– More work, no return.
• Recordkeeping Must be Part of Everyday Work Processes.
– No “separate” effort for recordkeeping.• Build e-Records Into the Business Software.
– Declare a record and classify while writing, approving, and sending documents.
Make e-Records DisappearWhy so Important?
1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations
RecordKeeping for Compliance