E-Records Management E-Records Management for e-Mail for e-Mail

Jane Connerton, CRMJane Connerton, CRMProcter & GambleProcter & Gamble

May, 2011May, 2011

UpfrontUpfront

This is more of a business problem This is more of a business problem and NOT just an IT problem. and NOT just an IT problem.

There are no magic systems that will There are no magic systems that will solve all your issues, automating solve all your issues, automating garbage is just expensive garbage.garbage is just expensive garbage.

At the end of the day, it’s more about At the end of the day, it’s more about about business processes and about business processes and partnering, not just technical partnering, not just technical solutionssolutions

E-Records at P&GE-Records at P&G

From over 6,000 systems to 3,800 – From over 6,000 systems to 3,800 – Success!Success!

Centralized control in a decentralized Centralized control in a decentralized environmentenvironment E-Records Guidelines E-Records Guidelines Controlled Self Assessments (and live Controlled Self Assessments (and live

audits)audits) Handful of corporate standard softwareHandful of corporate standard software

E-mail system – Outlook ExchangeE-mail system – Outlook Exchange Authoring Softwares – MS OfficeAuthoring Softwares – MS Office

Getting RM into ITGetting RM into IT

For every MAJOR system launch or For every MAJOR system launch or upgrade, there is an interventionupgrade, there is an intervention

For others, follow the e-Records For others, follow the e-Records guidelinesguidelines Consult as requestedConsult as requested

E-Records GuidelineE-Records Guideline Retention Times

Does the system have the Does the system have the ability to apply retention times ability to apply retention times listed in the RRS? Sec. VI. 1. & listed in the RRS? Sec. VI. 1. & 2.2.

Has a process/trigger been Has a process/trigger been developed for notifying, at developed for notifying, at least yearly, which e-records least yearly, which e-records have reached their disposal have reached their disposal date? Sec. VI. 3.date? Sec. VI. 3.

Does the system have the Does the system have the ability or process to suspend ability or process to suspend the disposal date of e-records? the disposal date of e-records? Sec. VI. 4.Sec. VI. 4.

Does the system have the Does the system have the ability or process to recalculate ability or process to recalculate the disposal date of e-records? the disposal date of e-records? Sec. VI. 5.Sec. VI. 5.

Date Format Is the date format Is the date format

documented and documented and the year includes the year includes four digits? Sec. VII. four digits? Sec. VII. 1.1.

Does the date Does the date format meet ISO format meet ISO 8061? Sec. VII. 2.8061? Sec. VII. 2.

E-Records Guidelines (2)E-Records Guidelines (2) Preservation & Migra

tion Preservation plan been to ensure Preservation plan been to ensure

that the e-record’s meta-data, that the e-record’s meta-data, content, context and structure is content, context and structure is maintained throughout its retention maintained throughout its retention time?time?

Process to periodically review the Process to periodically review the readability/usability of e-records on readability/usability of e-records on alternate media ?alternate media ?

Consideration been given to the Consideration been given to the migration of e-records to microfilm migration of e-records to microfilm based on cost of volume, use and based on cost of volume, use and length of retention time? length of retention time?

Web site, has it been rated as a High, Web site, has it been rated as a High, Medium or Low risk site regarding Medium or Low risk site regarding the ability to recreate the web site or the ability to recreate the web site or track its changes? track its changes?

Audit trail capture at a minimum, the Audit trail capture at a minimum, the date, time, person and action taken? date, time, person and action taken?

Have legal or regulatory guidelines Have legal or regulatory guidelines been considered for future search been considered for future search and retrieval capabilities? and retrieval capabilities?

E-Record Disposal Has a process been Has a process been

developed or tool developed or tool selected to dispose of selected to dispose of e-records in a way e-records in a way that they cannot be that they cannot be reconstructed? reconstructed?

Does the system’s Does the system’s audit trail capture the audit trail capture the disposal of e-records disposal of e-records and retain sufficient and retain sufficient meta-data?  meta-data?  

E-Records Guidelines (3)E-Records Guidelines (3)

Electronic Signatures Does the process of Does the process of

creating an electronic creating an electronic signature ensure the signature ensure the authenticity of the authenticity of the signer and the integrity signer and the integrity of the signature? of the signature? Section X.Section X.

Has additional Has additional regulatory compliance regulatory compliance controls been controls been addressed? Section X.addressed? Section X.

  

E-Mail (and other e-Records)E-Mail (and other e-Records)

Now More in GeneralNow More in General

Today’s EnvironmentToday’s Environment

The economyThe economy Cut costsCut costs Add to revenueAdd to revenue

Legal GuidelinesLegal Guidelines The courts are starting to understand The courts are starting to understand

electronic records and expect an electronic records and expect an organization to have its act togetherorganization to have its act together

E-mail is a big target, with lots of E-mail is a big target, with lots of volumevolume

DifferentPerspectivesDifferentPerspectives

Information Technology

Management

End User

Records Management

The IT PerspectiveThe IT Perspective

It’s just dataIt’s just data We don’t own itWe don’t own it There’s a big cost hereThere’s a big cost here Just give us the number of years to Just give us the number of years to

keep this stuff – why is this so hard?keep this stuff – why is this so hard?

The Perspective of The Perspective of ManagementManagement

If it doesn’t add value, we don’t need If it doesn’t add value, we don’t need itit

Don’t add cost or complicate mattersDon’t add cost or complicate matters What is the minimum that we need to What is the minimum that we need to

do?do?

But, don’t do anything that will get us But, don’t do anything that will get us put in handcuffs – because we don’t put in handcuffs – because we don’t look good in horizontal stripeslook good in horizontal stripes

The User PerspectiveThe User Perspective

It’s mine!It’s mine! I know what I have to keepI know what I have to keep I’ll decide what to do with itI’ll decide what to do with it How much can it cost? My home e-mail How much can it cost? My home e-mail

is free. is free. I have real work to do, not this filing stuffI have real work to do, not this filing stuff If it costs so much, I’ll just burn a CDIf it costs so much, I’ll just burn a CD Can’t I just save it all to my desktop?Can’t I just save it all to my desktop?

The Records Management The Records Management PerspectivePerspective

It is A RECORD!It is A RECORD! ““Recorded informationRecorded information, regardless of , regardless of

medium or characteristics, that has medium or characteristics, that has been created or received by the been created or received by the company, and is deemed necessary for company, and is deemed necessary for its business purposes”.its business purposes”.

We have legal, regulatory, audit and We have legal, regulatory, audit and tax issues to considertax issues to consider

We have to be consistentWe have to be consistent

What does the Law Say?What does the Law Say?

E-mail is subject to same status as paperE-mail is subject to same status as paper E-mail is subject to discovery and public E-mail is subject to discovery and public

accessaccess E-mail is not just the message, but E-mail is not just the message, but

attachments, and metadataattachments, and metadata The entire e-mail system and back-up tapes The entire e-mail system and back-up tapes

are subject to discoveryare subject to discovery Depending on laws, employees do not have Depending on laws, employees do not have

a right to privacy if using an employers e-a right to privacy if using an employers e-mail system. mail system.

So where to start? So where to start?

Who Are You?Who Are You? Industry, Culture, EnvironmentIndustry, Culture, Environment

Gov’t Agency – very clear what is business, Gov’t Agency – very clear what is business, need to make things publically available?need to make things publically available?

Company that makes things and is a big Company that makes things and is a big target for litigation?target for litigation?

Company that is information intensive and Company that is information intensive and needs better control of records overall?needs better control of records overall?

Company where innovation, creativity and Company where innovation, creativity and “free thought” are encouraged?“free thought” are encouraged?

Unique Email StrategyUnique Email Strategy

Each organizations e-mail strategy will Each organizations e-mail strategy will reflect it’s own culture and the legal reflect it’s own culture and the legal and regulatory environment in which it and regulatory environment in which it operates.operates.

Need to understand you organizations:Need to understand you organizations: Risks (and risk tolerance)Risks (and risk tolerance) What e-mail is REALLY being used forWhat e-mail is REALLY being used for How the business uses or could use e-mail How the business uses or could use e-mail

as a tool. (and if people are rule followers)as a tool. (and if people are rule followers)

Low Hanging FruitLow Hanging Fruit

E-mailE-mail How much personal e-mail is being maintained in How much personal e-mail is being maintained in

your infrastructure?your infrastructure? How much old, unnecessary and obsolete e-mail is How much old, unnecessary and obsolete e-mail is

being maintained?being maintained? How are attachments being handled?How are attachments being handled? How are back-ups handled (philosophy and time)How are back-ups handled (philosophy and time)

Savings: Savings: reduced server storage, backup reduced server storage, backup requirements, reduced bandwidth needs, tape costs requirements, reduced bandwidth needs, tape costs and IT labor costs.and IT labor costs. IT will embrace you if you can help them deliver IT will embrace you if you can help them deliver

cost savings cost savings

Procedural Changes before Procedural Changes before TechnologyTechnology

These also may require BUSINESS These also may require BUSINESS TRANSFORMATIONTRANSFORMATION View e-mail as a delivery mechanism, not a View e-mail as a delivery mechanism, not a

storage repositorystorage repository If it’s predominantly used to distribute If it’s predominantly used to distribute

attachments, have people post the attachments, have people post the attachment in a central repository and just attachment in a central repository and just share a link in the e-mailshare a link in the e-mail

Centralized vs DecentralizedCentralized vs Decentralized Mailbox size and/or default retention timesMailbox size and/or default retention times

Possible SolutionsPossible Solutions

K.I.S. – use tools within your e-mail systemK.I.S. – use tools within your e-mail system Big Bucket theoryBig Bucket theory

Everyone has 10-15 buckets to store email Everyone has 10-15 buckets to store email based on content. based on content.

They can make folders under the big They can make folders under the big bucketsbuckets

The buckets take care of retention The buckets take care of retention timetime

TRAVEL (1 yr)TRAVEL (1 yr)

ItinerariesItineraries

Expense report submissionsExpense report submissions

Possible SolutionsPossible Solutions

Move Records to where Records are Move Records to where Records are MaintainedMaintained If it’s key to the business, make it an If it’s key to the business, make it an

official record in the managed systemofficial record in the managed system Use e-mail to point to it or make it easy Use e-mail to point to it or make it easy

to declare it into the system (whole e-to declare it into the system (whole e-mail or just attachment)mail or just attachment)

Only keep transient (short term) records Only keep transient (short term) records in e-mail and force a short time (30/60 in e-mail and force a short time (30/60 days)days)

Possible SolutionsPossible Solutions

Empower the people – let them Empower the people – let them decide what they need to do decide what they need to do businessbusiness No retention time in e-mailNo retention time in e-mail There is a size limit!!!There is a size limit!!!

Do you let them keep NSF’s/PST’s?Do you let them keep NSF’s/PST’s? Balance enabling the business with Balance enabling the business with

controlling informationcontrolling information

At the End of the Day...At the End of the Day...

It’s all about creating valueIt’s all about creating value Everyone receives something that is Everyone receives something that is

equal to or greater than what is expectedequal to or greater than what is expected IT: Cost savings, reduction in infrastructure IT: Cost savings, reduction in infrastructure

needs, improved service levelsneeds, improved service levels Management: Cost savings, reduced legal Management: Cost savings, reduced legal

exposureexposure Records: Better management of e-RecordsRecords: Better management of e-Records End User: Better access to information, End User: Better access to information,

sharing of information, peace of mindsharing of information, peace of mind

Thank You!Thank You!