Global Program Management

Dawn Davis, SVP

Global Records Management

Bank of America Profile

• 282,000 Employees• Clients in 150 Countries

– 98% of US Fortune 500– 84% of Global Fortune 500

• 53 million consumer and small business relationships • 6,100+ retail banking offices & nearly 18,500 ATMs• Online banking with 6.63 million active users• $1.5 trillion Community Development Lending & Investing goal over

10 years (largest ever set by a financial institution)• #1 or #2 in a variety of financial services offerings• $200 million in philanthropic investments in 2009

– Unprecedented $2 billion, 10-year goal for philanthropic giving began in 2009

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Main goal:  Manage the lifecycle of records including the systematic disposition approval in accordance with retention schedule & preservation notices

Bank of America Global Records Management Profile

• Legal entities in 43 countries with 6,800 citations involving records storage requirements• Large inventory

– Develop and manage a global policy and the retention schedule. – Ensure compliance with legal, statutory, regulatory, and business requirements for the access and

storage of corporate records. – Partner with Legal to standardize identification and application of Legal Preservation Notices on

all items in offsite storage. – Develop, implement and govern all program enhancements through the Records Management

Governance Board. – Ensure the immediate availability of vital information.– Monitor and control the service, the volume and cost of record storage and handling. – Manage approved contracted suppliers for hard copy storage, and secured destruction services. – Manage data mapping, chain of custody, and transition of legacy records into end-state

environment. – Manage life-cycle of cartons in storage including all activity and ultimate systematic destruction. – Enable associates to better manage their records by providing centralized resources, intuitive

technology tools and required education. – Consult LOBs on best-in-class record management practices.

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Challenges

• Multiple audiences, records, data sources, languages, locations to manage– Company size and scale– Vendor selection/capabilities globally – Different regulations in each jurisdiction that are constantly changing

(ex: Cross Border Data Regulations)– Growing volume of data (electronic and paper)– Managing and migrating inherited inventory– Defining global infrastructure and identifying records custodians– Communicating to & educating associate population– Complicated technology environment

• Financial Services Regulations– Banking– Lending– Insurance

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– Investments– Securities– Accounting

Global Records Strategy

• Objective: Centrally manage global records

Step 1: Planning: Sponsorship, Resources, Timelines

Step 2: Establish Standard Records Policy and Retention Schedule

Step 3: Implement Global Records Policy

Step 4: Prioritize launch of Global Retention Schedule

Step 5: Implement Global Retention Schedule

Step 6: Improve, Control, and Monitor

• A compliance program, not a project.

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Global Retention Program Best Practices

• Centralize Global Records Management functions• Secure executive sponsorship and build governance structure• Specialize your Records Management Team• Engage the experts• Make friends: find your internal stakeholders• Build a user-friendly retention schedule

– Legal, industry and business requirements– Consider risk/reward balance– Drive out a global taxonomy

• Focus on the end to end lifecycle to identify compliance risks• Use risk identification tools to error-proof processes and technology• Communicate and train

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Global Retention Program Best Practices

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Make it easy to do the right thing.