In today’s business climate, companies of varying sizes across all industries are exposed to multiple risks if they don’t have a trusted solution for managing their email, other types of electronic messaging, documents, images and any critical form of electronically stored information (ESI).
Having a central archival repository, whether physical or logical, on-premise or remote where all key enterprise information is stored securely and is easily accessible to individuals and departmental systems (based on your organization’s and industry’s policies and best practices) is the cornerstone Information Management (IM) solution that will drive efficiencies throughout the enterprise when that archived information needs to be accessed for any business reason. This is especially true for ediscovery activities.
Whether a firm has 20 or 20,000 employee mailboxes, following a logical flow of steps or best practices before you begin your vendor selection will dramatically improve the likelihood of a fruitful implementation.
10 Steps to Avoid Marginal Results
The following recommendations are drawn from the experiences of information management professionals who have successfully implemented enterprise wide archiving solutions and achieved much greater results than organizations who have primarily deployed point solutions and are stuck in react mode. In one case, a large financial services firm reduced its average time for completing an ESI ediscovery request from more than 100 hours to just 1 hour.
1 - Recognize/Identify Problems
Review your present situation. Are your existing solutions for coping with the growth of documents, email, messaging and other ESI sustainable? Are you risking fines, negative legal judgments or loss of intellectual property and limited access to critical customer information? Is there a way to enforce policy? Compliance, ediscovery preparedness, improved records, storage and mailbox management are all good motivations.
2 - Find Champions, Build Consensus
If you determine your current path is not sustainable or want to dramatically improve your content access and discovery speeds, build a consensus from key departments including Compliance, IT, Legal, Lines of Business and the Records Management Department (RDM) - if you have one. Action items to pursue include drafting an executive presentation to get top down buy-in and advocating for the creation of a cross functional team to drive the corporate IM agenda, develop a plan and monitor it’s progress and results.
3 - Set Goals: Save Time, Money and Comply
Your cross functional team needs to determine what goals are necessary and achievable. Does your firm want to reduce the time and cost to complete discoveries or internal investigations? How about complying with various rules and regulations such as SEC, FRCP, GLBA or HIPAA? Building an on-premise central archive or having access to a cloud enabled archive for all essential enterprise ESI should significantly boost response times for each discovery activity or content access request while providing a compliance enabled environment. Determine which approach is best suited for your unique organizational requirements based on internal expertise, existing technology infrastructure, the size of your firm and preferred expense structure (CAPEX vs. OPEX)
4 - Presentation for Executive Buy-in
Based on a compilation of existing facts, figures and projected costs for the next several years, the potential for stiff penalties for non-compliance and the anticipated increase in ediscovery, regulatory and other information access activities, the cross-functional team, presents to the CEO and other top management to get their support and buy in. Who takes ownership of the presentation at this point depends on your organizational structure. The CIO or head of IT is often the lead at this point.
5 - Create Cross-Functional Team
Often lead by Compliance, IT and Legal with the backing of all top management, a cross functional team is created including all major stake holders from key business units. If a RMD exists, they will take the lead in managing the process. Some firms have designated a Chief Information Management Officer (CIMO) or equivalent to drive the corporate vision and oversee this process, a position that is outside of Legal or IT. The make up and leadership of your team will depend on the size and culture of each individual entity.
6 – Do Research, Develop a Plan
Once a team is formed, establish an enterprise-wide records management or information governance committee responsible for setting direction and developing policy. Review all applicable regulations and records requirements for your industry and research what other similar organizations are doing. You will likely find that,
- Many organizations have elected to use backup/restore technology
- Few firms have centralized archiving solutions in place
- Few entities have a clearly articulated Strategic IM roadmap
- Many have attempted to address email retention purely through policies
- Most entities do manual categorization or leave it up to business units
However, organizations deploying best information management practices have transcended these marginal IM practices concluding, among other things, that centralized auto-categorization is critical as too much time is wasted by individual business units doing their own work and policies need to be applied centrally and automatically as well.
7 - Redefine Policies and Requirements, Create Budgets, Know your Scope
The IM team needs to document their organizations entire policy covering all records, regardless of media including paper and ESI. The team needs to provide training for employees, overcome organizational issues such as rifts between Legal and IT and manage user expectations. It is critical to define the scope of the archiving implementation including budgeting in order to yield the highest ROI. Having an IM roadmap in place is invaluable.
8 - Set Technology Direction (In-house vs. hosted) Auto-Classification
The team needs to determine whether an in-house, on-premise or hybrid solution is their best choice based on their unique requirements. Firms who have opted upfront for auto-classification and centrally developing a taxonomy typically achieve the best results. However, engaging key business units in the process and getting their approval is also critical.
9 - Find a True Partner, Vet Vendors and their References
After developing a short list, distributing an RFP, interviewing vendors and their customers, chose a vendor that shares your “vision” that maps to your view of how the solution should be designed and implemented.
One of the companies interviewed for this piece said they were surprised to hear that many vendor references said their implementations took 6 months or more to go live. “That was a red flag for us”. This firm went live in less than 90 days and had over 200 million object archived in less than a year.
10 - Manage the Process, Test and Measure Results
Create scorecards for how many emails, messages and other ESI your firm has captured and a technology map for where it all resides. One organization instituted a “synthetic messaging” program to assure all forms of messaging were being captured. Keep track of and refine on-going training and employee education. As the archiving solution matures, give more responsibility to units for discovery tasks. Support ongoing defensibility.
Given the present state of affairs, a most critical archiving solution attribute today is defensibility which can be variously described as the ability to,
- Demonstrate appropriate, achievable, consistent policies for ESI
- Demonstrate repeatable processes supporting a firm’s need to comply
- Offer predictability to support compliance with retention policies
- Produce ESI in a timely fashion for litigation requests
Bottom Line
While requirements and, ultimately, choices made will vary by industry and company several points are universal:
- The CEO and Senior Management team can remove significant obstacles.
- A strong partnership between Legal, Compliance , Information Technology and Records Management departments is crucial.
- Involving the business units up-front in the development of the Corporate Record Retention Schedule speeds acceptance and adoption of the program.
- Having a well thought out and articulated Strategic Information Management (SIM) plan allows an organization to determine its, most pressing needs, direction and terms of engagement with solution providers and software vendors.
- Information Management is a journey with distinct obstacles to overcome and milestones that can be achieved with the proper plan in place. A well thought out information archiving strategy and action plan can dramatically improve the results for implementing an archiving solution and provide downstream benefits for Compliance, Legal, IT and departments as well as providing ongoing added value to lines of business who will have much more timely access to organizational information.
For more information on enterprise information archive solution vendor selection click here.
User Action
Organizations looking to more fully benefit from implementing information archiving solutions to lower risks and costs, speed the ediscovery process and provide vastly improved access to data and content first and foremost must have CEO support for the creation of a cross-functional team to identify organizational IM challenges and needs. In addition, organizations must create a SIM plan, centralize classification, policy management and training while thoroughly vetting vendors and service providers in order to significantly move forward on the IM journey.