Discussion 8 Q1 and 9 Q2 Governance
ITS 833 – INFORMATION GOVERNANCE
Chapter 9
Information Governance and Records
and Information Management Functions
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CHAPTER GOALS AND OBJECTIVES
Understand records management and its impact on information governance
What is Electronic Records Management (ERM?)
Why is records management challenging?
Benefits of ERM
Inventorying E-Records
Understanding Retention Scheduling
Discussing Email Retention
Legal requirements and compliance research
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Records Management and Information Governance
According to Smallwood (2014) “records management is a key impact area of information governance” (p. 147).
International Organization for Standardization (IS) defines records as “information created, received, and maintained as evidence and information by an organization or person, in pursuance of legal obligation or in the transaction of business” (p. 147).
Records and information (RIM) extends beyond records management
Electronic records management (ERM) now the forefront of business issues supporting business process automation and electronic document growth.
Classification
Taxonomy
Retention
Disposition
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Electronic Records Management
According to Smallwood (2014), ERM is “the organization, management, control, monitoring, and auditing of formal business records that exist in electronic form” (p. 148).
Important to note: Automated ERM solutions also track paper and other physical records.
E-records management – more critical to modern business due to increased legislation on compliance and volumes of information and growing in electronic format
ERM adheres to the same principles as paper records management
E-records are subject to evolving IT making them difficult to read/obsolete
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Electronic Records Management Business Rationale
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Smallwood (2014) discussed that several factors form the business rationale for ERM:
Facilitating compliance
Ensuring records are backed up in the event of a disaster
Information Governance support
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The Challenge of Records Management
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Lack of defined policies
Increasing regulations
Managing multiple retention schedules
Compliance cost and lack of human resources
Security concerns
Dependence on IT
Volumes of documents
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Benefits of ERM
Improvements for enforcing IG over business documents & records
Accurate searching capability
Productivity of knowledge workers
Reduced legal consequences/risk compliance issues
Improved security
More effective decision-making based on improved search capability
Also review several additional intangible benefits (Smallwood, 2014, p. 153)
e.g. preservation of corporate memory
improved professionalism
improved decision-making
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Inventorying E-Records
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Electronic records inventorying is more challenging than physical records inventory
US National Archives and Records Administration (NARA) suggests electronic records are inventoried by information system rather than record series
Knowledge workers are the best resource for:
Gathering accurate inventory data
Developing workable file plans
Maintaining records declaration, retention, and disposition process
Records inventorying steps per NARA:
Define inventory goals
Define inventory scope
Seek and obtain executive management support/sponsor
Identify information to be collected
Identify WHO will conduct inventory
Understand where the files are located (geographically)
Complete the inventory
Confirm results
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E-discovery planning
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E-Discovery Reference model = a planning tool that details e-discovery process steps
7 steps of the E-Discovery Process, according to Smallwood (2014):
1. Create and retain ESI – includes enforcing and monitoring compliance
2. Selection process to identify relevant ESI
3. Deduplication and cleansing of ESI – serves to reduce cost
4. Review filtered ESI for privilege
5. Produce native format ESI
6. Clawback ESI
7. Present at trial
Guidelines for E-Discovery Planning:
Implement an IG program
Inventory the business ESI
Develop a detailed records retention policy including ancillary retention schedules that includes email and significant ESI areas
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Challenges - E-Records Inventory
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Due to their electronic state, e-records present unique challenges over paper of microfilmed records:
One cannot flip or browse through records without online searching
May be distributed across multiple servers rather than physically located in one location
Similarities of metadata
Multiple copies may exist – difficult to identify the original
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Understanding Retention Schedules
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According to Smallwood (2014), a records retention schedule “defines the length of time that records are to be kept and considers legal, regulatory, operational, and historical requirements” (p. 170).
Retention schedules are needed towards uniformity in the retention & disposition process.
A records retention schedule consists of:
Title of the series
Descriptions of the records series
Office responsible
Disposal decision
Timing of disposal
Event(s) that triggers the disposal action
Date the schedule was fully executed
Legal citations
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EMAIL RETENTION
Several theories exist on appropriate email retention schedules.
When no laws or regulations that govern retention and deletion of electronic business records exist, organizations may determine their individual retention and deletion schedules (recommended at least as long as paper records).
Most common email retention is 7 years, however timelines vary –
may be as little as 90 days, 6 months, or 1 year.
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Common Principles of Retention Schedules
Retention Schedule needs to include all records, regardless of media type or location
Schedules need to meet all legal and regulatory requirements
Retention schedules require a ‘proactive’ rather than ‘reactive’ approach
Monitoring and periodic review of the retention schedule
Continuous improvement process based on evolving legislation and regulatory requirements
Records scheduling and classification are linked
Categorize similar file series for retention
Preservation of historical records
Records retention should align with user business needs, records, value, and compliance requirements
Proper retention schedule planning and controlling
Executive management approval and sign-off of process
Documentation of scheduling requirements and process
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Legal Requirements
Legal requirements TRUMP ALL OTHERS regarding retention schedules!
Legal research is required BEFORE determining and adopting retention schedules
Record retention requirements may be found:
Citation services
FILELAW (Canadian records database)
Code of Federal Regulations (CFR) – annual update
Electronic Code of Federal Regulations (e-CFR) - daily update
Periodic auditing to ensure compliance with retention policies
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The End
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