The Challenges (And Rewards) of Records Management in an International Setting

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Keywords: Records Management, compliance, strategy, People

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 **Views expressed in this blog are my personal views and not those of my employer. Any reference to any living person or organisation, past or present, is entirely co-incidental**

Many of us work in a Global or, at least, a multinational organisation. This inevitably make life more interesting but also raises a number of challenges. The following is a selection of some of those challenges and how they can be addressed. Of course, there is no “one size fits all” solution. Each Records Management Team and organisation will have difference ideas and, sometimes, constraints.

People
It is fairly obvious to say that winning our colleagues around is key to successful Records Management implementation and/or maintenance. These are some of the key areas to consider – failure to do so could significantly reduce the chances of success – and you achieving your objectives!

  • Language – your company may require use of a certain language for all business communications/meetings. However, it may improve acceptance if some degree of translations into local languages is available
  • Custom and practice – bear in mind when communicating that local customs and practices may lead to a different interpretation of your actions – particularly if training is involved. Some physical signs/mannerisms which are acceptable in your country may be insulting in another country
  • Understand local market conditions and services available – it is no use adopting a Global Minimum Standard in the most developed and sophisticated country and attempting to impose these standards in less developed countries.

Rules – Local/Global/Regional
Consider how Laws and Regulations in one or some countries may affect your Records Management (retention) requirements in others. Some governments may consider that their Laws/Regulations have a global reach. You should also ensure that appropriate weight is given to local research. The following are some of the key Agencies for Firms based in or having operations in some key jurisdictions:-  

  • Commodity Futures Trading Commission (CFTC) - US
  • Food and Drug Administration (FDA) - US
  • Securities and Exchange Commission (SEC) - US
  • Financial Services Authority (FSA) - UK
  • Civil Aviation Agency (CAA) - UK
  • Japanese Financial Services Authority (JFSA) - Japan

Knowing your environment
To state the obvious - to make an informed decision you have to know what you have and where you wish to go. You need to understand the environment you are working in, especially regarding the technology infrastructure. By this I mean both your internal infrastructure and the wider geographical infrastructure. For example, can you be certain of communication systems/power availability on a 24/7/365 basis as most of us are used too (and take for granted)? What are the local views in complying with "Head Office" Policies? 

Your environment will, almost certainly, include “legacy” Records and systems - take care to review these and ensure Records are retained on appropriate media (not back up tapes). Also ensure you still have the ability to read this media...(sounds obvious but... ;-))

These are just some of the aspects some more to follow in a later blog. In the meantime, please please provide some feedback and details of your experiences - for the benefit of all.

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Comments

John Drew

The Challenges and Rewards of RM in an International Setting

With regard to your comment on ability to read the media, I think it is equally, if not more important to select the appropriate format in which records are to be stored. I have become a keen supporter of the PDF/A format, as the best format for long-term preservation of records. It removes reliance on proprietary software formats or hardware, so the records can be viewed 50 or more years into the future.

This approach will need careful planning for dealing with legacy records, as well as day-forward records. It also needs a vendor selection process for the PDF/A conversion / compression tool.

For more information go to http://www.pdfa.org/doku.php or AIIM website.

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Roger Poole

John Drew's comment...

John - you raise an important point which must be considered by the business and technology but one which is often ignored. I think it is fair to say (and I appreciate this is a sweeping generalisation!) that many large corporates rely on vendors constantly updating and continuing to support their systems. The Vendors are happy with this as it guarantees them a constant stream of revenue and some, do (or have in the past) deliberately build their systems so that images/files are stored in a proprietary format. I would suggest that software/hardware support is something that we should all consider - for any system/s
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John Drew

The Challenges and Rewards of RM in an International Setting

.....as is evident Roger, with each release of Microsoft Office, in which the format changes say from .doc to .docx - and the two are incompatible.
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John Phillips

Special Asia/Pacific Issues?

Other than the "Japanese Financial Services Authority (JFSA) - Japan" - what additional issues, standards, or organizations affect the Asia/Pacific Region?
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Roger S

HK/Chaina Archiving Law

Hong Kong still does not have any Archiving Law, though has Public Records (Access) Rules (1996) and Electronic Transactions Ordinance (Chapter 553). Government Records Services oversees the management of public records. China on the other hand has implemented The Archives Law of the People’s Republic of China (enacted in 1987 (amended in 1996)) and Municipal governments in China enact their own related archives laws. On the Financial Services front Hong Kong Inland Revenue Department stipulates that the business records be kept for 7 years under the Section 51C of the Inland Revenue Ordinance as well as Hong Kong Monetary Authority's Guideline on Prevention of Money Laundering under section 7(3) of the Banking Ordinance sets out in detail the standards and procedures expected of authorised institutions in their customer identification, record keeping and reporting procedures to combat money laundering. Insurance Authority regulates the Insurance Industry on its record keeping and there is also The Office of the Privacy Commissioner for Personal Data (PCPD)which oversee the enforcement of the Personal Data (Privacy) Ordinance (Cap. 486).
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This post and comment(s) reflect the personal perspectives of community members, and not necessarily those of their employers or of AIIM International