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Technology, As Ever, Isn't the Answer

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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**

When they realised technology alone was never going to be the answer it was too late….

So, the enforcement regulator has just arrived in your offices with a warrant and will not leave until they have the information they are looking for…  

Your immediate thoughts may be to summon the Head of IT. However, it is unlikely they will be able to locate all of the Records required. It is common for Records to be retained on different media and in a number of locations such as:-

•    email
•    shared drives
•    systems databases
•    external vendor systems storage
•    microfilm
•    Microfiche
•    hard copy kept on the premises
•    hard copy stored with a professional vendor offsite

The result of failing to identify/provide the Records when required is likely to be:-

•    reputational risk – the risk of damage to your organisation as a result of negative publicity
•    a fine
•    imprisonment
•    a fine and imprisonment

From the above, we can see it is of paramount importance to have a defined (and implemented) Records Management Policy and framework. The requirements of such a Policy and framework will be driven by the laws of the jurisdictions you trade in. The requirements will also be impacted by Regulators body such as:-

•    Financial Services Authority (United Kingdom) – FSA
•    Securities and Exchange Commission (US) – SEC
•    Civil Aviation Authority (UK) – CAA
•    Food and Drug Administration (US) – FDA

Regulatory bodies often have the authority to impose significant fines.

We can see from the above that there is a need for someone to have an organisation wide remit to develop and implement Policy (in collaboration with Legal, Compliance and Tax). This should be a short high-level document supported with advice in terms of Retention Requirements (Retention Periods and, where necessary, specific media types). This programme must have high level sponsorship to succeed.

Some form of inventory should be built across the organisation to ensure there is an understanding of where all the Firm’s Records are retained. This will include, in most cases, a number of legacy systems and records. An important part of this task is to talk to as wide an audience as you can. Pockets of information can be found throughout the organisation.

Once such an inventory has been completed you can start work on determining the most appropriate infrastructure to maintain (and make available) these Records. ECM technologies are great, but proceed cautiously ensuring a detailed cost benefit determination is taken at each step. Bear in mind it is likely that, for some Records, an investment in technology may not be appropriate.  
 

Comments

Submitted by Bob Larrivee April 29, 2010 - 9:58 AM

This article rings all too true! Technology is useful as a tools but one of the most important elements I have found and is often discussed in sessions and classes I conduct world wide is the need for tighter controls over records of all types yet there are many instances when an organization overlooks the fact that a record is a record regardless of format. This means physical and electronic combined and as you point out, the electronic can reside most any place in the enterprise.

Defining, documenting and training on policy is vital to an organization with regard to what constitutes a record and also how long we must keep them. Another aspect to this is procedural governance as well as records governance. Not only does the organization need a policy specific to the records it keeps there should also be governance over the processes associated with the declaration, management and disposition of these same records. If the technology is in place and we ask the user community to actively participate in records management practices, we also have to train them on how this is done.

I liken some of this to the time, and I will now date myself, when word processing hit the scene and we were now able to write our own documents rather than leverage the typing pool or rely on our assistants to perform this function. It changed the way we worked as technology in the records management space has also done.

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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