Implementing Automated Retention at the European

Central Bank

Maria Luisa Di Biagio Beatriz García Garrido

A Bit of Background

European Central Bank

1998 – Frankfurt am Main (Germany)

2002 – Introduction of the €uro

A knowledge organization

At the heart of the Eurosystem and the Single Supervisory Mechanism

Information is key to prepare decisions and perform our assigned

tasks

Who We Are, What We Do

Our goals: • Ensure the systematic and efficient creation, management and retrieval of information

throughout its lifecycle • Support collaboration and efficient access to timely and relevant information • Ensure compliance with legal, accountability, and transparency rules • Safeguard our institutional memory

Information Management Services

Library Archives IM Solutions IM Policies & RM

DARWIN: Our EDRMS Since 2007 For the users

Document creation and management

Collaboration with other

users

Knowledge pool

For the institution

Institutional memory

Accountability &

transparency

Legal compliance

Some numbers

+ 18000 users (ECB and counterparts across Europe)

+ 8 million documents

~300 workflows

~300 communities

~500 blogs

Why Retention? To keep only what we need

• As defined in the ECB Filing and Retention Plan

• And in order to…

– Ensure the information that needs to be kept is identified and retained to serve current and future business needs and for historical reasons

– Allow compliance with legal/regulatory requirements (e.g. data protection)

– Ensure an effective management of information and minimise the cost of retrieval and preservation

Automating Retention: Overview

2010 - Pilot 2012

Dedicated task force

2013 Preparation and

Planning

2015 Retention

implementation

2010 – Pilot Aim • Find out the effort of designing the retention schedules • Understand how to apply them to the relevant information • Test the process of managing the information throughout it’s lifecycle

Results • Each retention schedule consisted of a very complex set of different stages • There were a lot of schedules to be created • Assigning the schedules to the information was going to be lengthy as the

classification was done at a very deep level • Executing the disposition processes was going to require far more resources

than anticipated

2012 – Task Force

Complexity of the ECB Filing and Retention Plan

Lack of optimisation of the technical solution

Step back and focus on the final goal

Retention plan

Design

System

Old Retention Plan Code Classes Scope notes Series Records lifecycle

Active stage Semi-active stage Inactive stage

1.1 Definition of the ECB’s institutional framework

1.1.1 Policy

framework

Involves policy issues relevant to the

ECB’s institutional framework.

Includes, inter alia, the regime for ECB

legal acts, statutes, mission

statements, appointments of Board

members and authority to sign. This

and any other official documentation

representing the basis of the ECB

accountability shall be filed as

separate series

Master files (kept in SEC) -

Signed original legal documents

to be preserved on paper

5 years T P

Local copies or convenience files

(kept in BAs others than SEC) 5 years T

D after

relevant master

file has been

transferred

Administrative files; notifications;

transmission letters 3 years D

Appointment of Board members 5 years T + 15 years D

Stages reflect paper moves

One classification but 4 retention schedules

Simplify Stages and Actions

- Reduce stages - Appraisal after 15 years

(20 years and Permanent)

- Reduce Permanent

No. Years Transfer No.

Years Destroy No. Years Destroy

No. Years Transfer No.

Years Permanent

No. Years Transfer No.

Years Appraisal

Permanent

Reduce Retention Periods

In addition 1 and 2 years for data protection

Class. Code Series Format Retention Trigger Point Retention

Period

1.1

1.1.1.1Master files (kept in SE/SEC) - Signed original legal documents to be preserved on paper

Physical Permanent

1.1.1.2Convenience files (kept in BAs others than SE/SEC)

DigitalE - Date of termination of the activity

5 years (D/SA)

1.1.1.3Administrative files; notifications; transmission letters

DigitalE - Date of termination of the activity

5 years (D)

1.1.1.4 Appointment of Board members Digital E - End of contract period 20 years (D)

1.1.1.5 Official signatories Digital E - Repeal date 5 years (D)

1

Definition of the ECB’s institutional framework

1.1.1 Involves policy issues relevant to the ECB’s institutional framework. Includes, inter alia, the regime for ECB legal acts, statutes, mission statements, appointments of Board members and authority to sign. This and any other official documentation representing the basis of the ECB accountability shall be filed as separate series

Covers corporate governance subjects, such as the ECB legal and organisational structures, decision-making body appointments, headquarters agreement and other issues of general interest to the whole ECB

Policy framework

Establishment of the ECB / Eurosystem / ESCB - Corporate governance

New Retention Plan

Trigger: Event-based or Time-based

Authoritative format: Physical or Digital

4th level with only one retention period

Automating Retention: Overview

2010 – Pilot 2012

Dedicated task force

2013 Preparation and

Planning

2015 Retention

implementation

5 Focus Areas Retention approach

Business processes

Roles & responsibilities

Implementation strategy

Communication

Retention Approach • Records management classification

(retention plan series and retention schedules) is applied to folders in workspaces

• The system automatically performs retention activities

• Reports for final disposition of records are created for approval by the business areas

• Evidence of final disposition is kept permanently

Use

r-dr

iven

• Ongoing, no end date • Declaration of individual

records as trigger • Document based retention • Automatic declaration 2

years after last editing action

Time-based activities

• Clear start & end date • Declaration of folders as

trigger • Folder based retention • Manual declaration

Event-based activities

Auto

mat

ed

Retention Trigger

Business Processes

Definition of 18 retention processes

Process description

Stakeholders & systems

Clear responsibilities

Process Example

Roles & Responsibilities

Project Board

• IM management and staff assigned to project

• Discuss and approve project related decisions

Project Manager

• Oversee implementation and track progress

• Ensure consistency

Implementation Teams

• 1 records manager

• 1 archivist • 2 nominated staff

from each business unit

(Senior) Management in Business Areas

• Approve retention periods on workspaces

• Approve final disposition of records

Implementation Strategy

Pilot with 2 business areas

Jan 2015 – 1st group of

business areas

Gradual implementation

in groups of business areas

End 2016 –implementation

completed

Implementation Phases

Explain implementation process Present roles & responsibilities Agree timeline

Present proposal of retention periods to be assigned on folders Discuss & agree on final retention set-up

Approve retention periods to be assigned on folders

Adjust folder structures & retention plan Assign approved retention periods on folders

Communicate to end users in business area Activate retention functionalities Carry out final disposition of records

Kick-off meeting Preparation Approval Implementation Activation

Communication

Executive Board • Approval of retention

plan • Validation of

approach for future reviews

IM Advisory Group • Feedback during

preparation • Information on

implementation progress

(Senior) Management • Presentations prior

to start of implementation

End Users • Kick-off

meetings • Go-live

Lessons Learned Generous time allocation is needed • Analysis of folder structures leading to retention proposal is time

consuming and requires maximum accuracy

Iterative approach • Retention plan may need adjustments • Review of folder structures is often needed

Adaptability and flexibility • System upgrades may involve changes to the functionality • Unexpected technical issues may delay process

Winning Factors •To raise awareness on importance of retention •To ensure end users’ engagement and availability during

implementation

Management involvement

•Project manager overviewing whole implementation process •Archivists ensuring consistency of retention periods across

business areas (e.g., retention of common activities)

Centralised control during implementation

•9 years after EDRMS introduction •Enforcement of standard approach for common activities (e.g.,

administration)

Improvement of folder structures

Simplification of approval process for final disposition •Yearly approval of retention periods on folders replacing approval of detailed lists of records

Implement process for use of “holds” •Use of holds for litigation and few other defined processes

Monitoring tools & reports •Ensure timely closure of event-triggered folders •Check correctness of retention periods on workspaces

Training framework on retention management •IM staff •End users with IM responsibilities

New ECB banking supervision tasks •Update of retention plan •High amount of documents and data •More regulated environment

What Is Planned

Future Challenges

Preservation of records with long term retention •Project started

What about other content? •Non captured emails, social media, other systems …

Can Big Data Analytics help in streamlining retention processes? • Identify patterns in the use of documents …

Conclusions

Implementing automated retention is a complex task

Integration of policy, systems, people & processes is essential

Flexibility and readiness to adjust to changing requirements are at the basis of a successful implementation

Communication & management buy-in are key factors

• Beatriz García Garrido Information Management Expert Email: Beatriz.Garcia@ecb.europa.eu

• Maria Luisa Di Biagio Information Management Expert Email: MariaLuisa.DiBiagio@ecb.europa.eu