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NURS OUTLOOK 64 (20r6) 352-366
NURSING
OUTLOOK
-www.nursingoutlook.org
A proposed model of person-, family-, and
culture-centered nursing care
Maichou Lor, MS, RN*, Natasha Crooks, BSN, RN, Audrey
Tluczek, PhD, RN, FAAN
ARTICLE INFO
Article history:
Received 28 May 2015
Revised 6 January 2016
Accepted 28 February 2016
Available online 8 March 2016
Keywords:
Concept analysis

Cultural competency
Family centered
Patient centered
Person centered
University of Wisconsin-Madison, School of Nursing, Madison,
WI
ABSTRACT
Background: For decades person-, patient-, family-centered, and
culturally
competent care models have been evolving and conceptualized
in the literature
as separate. To our knowledge, there has not been a systematic
approach to
comparing all four of these conceptual models of care.
Purpose: To explicate and compare four conceptual care models:
person-, patient-,
family-centered, and culturally competent care.
Methods: A comparative concept analysis informed by Rogers'
evolutionary
concept analysis was used to compare 32 nursing research on
person-, patient-,
family-centered care, and culturally-competent care published
between 2009
and 2013.
Results: Collective results of analyses of 32 nursing research
articles found 12
attributes: collaborative relationship, effective communication,
respectful
care, holistic perspective, individualized care, inter -professional
coordination,
self-awareness, empowerment, family as unit of care,
interpersonal relation-
ships, cultural knowledge, and cultural skills. Antecedents

included: lack of
empirical evidence, poor patient outcomes, implementation
problems,
knowledge deficits, patient/parent emotional distress, poor
patient-provider
relationships, and health disparities. Consequences included:
improved
health-related outcomes, increased satisfaction, enhanced
patient/family-
provider relationships, reduced hospitalization, improved
quality of life,
improved quality of parent-child relationships, increased trust,
enrollment in
research, insights about biases, and appreciation for cultural
differences. So-
cial justice, advocated by scholars and national organizations,
was absent
from all studies.
Conclusions: Findings informed the proposed blended
conceptual care framework
that embraces the attributes of each care model and includes
social justice.
Cite this article: Lor, M., Crooks, N., & Tluczek, A. (2016,
AUGUST). A proposed model of person-, family-,
and culture-centered nursing care. Nursing Outlook, 64(4), 352-
366. http://dx.doi.org!10.1016/
j.outlook.2016.02.006.
A clear understanding and articulation of concepts is
essential to advance nursing knowledge and to effec-
tively communicate within nursing research, educa-
tion, and practice as well as across disciplines, (Bonis,
2013). Over the past few decades, four conceptualiza-
tions of health care delivery have emerged that reflect
a shift in the health care delivery paradigm from a

paternalistic, disease-focused perspective to care
* ~,;;;~~~onding author: Maichou Lor, School of Nursing,
U~iversity of Wisconsin, Signe Skott Cooper Hall, 701
Highland Ave., Madison,
address: [email protected] (M. Lor).
nt matter © 2016 EI' . sevIer Inc. All nghts reserved.
<4U"'OK.LU16.02.0()6
NURS OUTLOOK 64 (20r6) 352 366 353
models that focuses on the needs, preferences, and
cultural values of the constituents of health care:
person-centered, patient-centered, family-centered,
and culturally competent care. Application of these
four conceptual care models tends to vary based on the
patient population or the environment in which care is
delivered. The term "patient centered" is typically used
in regard to recipients of services in tertiary care set-
tings (Morgan & Yoder, 2012), whereas "person
centered" is used in reference to nursing home resi-
dents (Brooker, 2007). "Family-centered" care is
generally preferred in interventions for pediatric pop-
ulations (American Academy of Pediatrics, 2012).
"Culturally competent" care is a term that calls for
customizing care for patient populations that share
one or more demographic characteristics, usually race,
ethnicity, language, or country of origin (Office of
Minority Health, U.S. Department of Health and
Human Services, 2015).
Many professional organizations and government
agencies advocate for institutional implementation

of these conceptual care models (American Academy
of Pediatrics, 2012; American Association of Colleges
of Nursing, 2008; American Nurses Association,
2015; Bloom, 2002; Chao, Anderson, & Hernandez,
2009; The Joint Commission, 2010). These concep-
tual care models are also recommended for inclusion
in undergraduate and graduate nursing curricula
(American Association of Colleges of Nursing, 2008;
American Nurses Association, 2015). Therefore, the
purpose of this article was to (a) describe the histor-
ical separate evolution of these four conceptual care
models, (b) report results of a concept analysis that
offers conceptual clarity about the use of each model
in current empirical nursing literature, (c) compare
models to identify conceptual similarities and dif-
ferences, and (d) discuss implications for blending
the models.
Historical Evolution of Models
Table 1 provides an overview of the historical evolution
of the four models. In summary, multiple disciplines
have contributed to the parallel evolution of each of
these four conceptual care models. Although the
models share several attributes, for example, unique-
ness of the "patient," importance of patient-provider
relationship, and emphasis on individualized care,
they remain mutually exclusive within the research
literature. In addition, person-, patient-, or family-
centered care models do not address power, privilege,
historical oppression, or cross-cultural patient-nurse
relationships. To our knowledge, there has been no
systematic approach to comparing these four care
models as conceptualized by nurse researchers.
Therefore, we conducted a comparative concept anal-
ysis to explicate the current state of these concepts

within nursing research and explore how similar or
different the models might be.
Methods
InclusionlExclusion Criteria and Data Sources
Table 2 details the search criteria, search terms, data-
bases, and article selection for each concept. Our
search included articles published by nursing re-
searchers, documented by authorship, reporting pri-
mary data, and published between 2009 and 2013. We
chose this time frame because previous concept ana-
lyses had been completed before 2009. We chose arti -
cles with nurse authors because our aim was to
explicate how the four conceptual care models have
been conceptualized in nursing science. The most
common reason for exclusion was that nurses were
not authors.
Analytic Procedures
The research team was comprised of content and
methodology experts. We followed the procedures of
Rodgers (2000) in the conduct of a separate concept
analysis for each of the four conceptual care models,
beginning with person-centered care, followed
sequentially by patient-centered care, family-centered
care, and culturally competent care. We selected con-
cepts significant to nursing, that is, four conceptual
care models, and performed database searches using
specific inclusion and exclusion criteria. Each
researcher independently identified the surrogate
terms, antecedents, attributes, and consequences in
each article. The team met weekly to discuss the codes
and reach group consensus about results. During our

analysis, we found that in the family-centered and
cultural competency articles, researchers identified
barriers to implementing care models. Therefore, we
added "barriers" as a category. Findings were entered
into matrices. We modified and refined codes and
matrices as new findings emerged from the analysis.
On completion of the analysis of the four conceptual
care models, we compared the results across the
models to identify distinguishing and overlapping
characteristics as recommended by Haase, Leidy,
Coward, Britt, and Penn (2000). Finally, we assimi-
lated the findings into a proposed blended model that
also included social justice.
Results
Sample Characteristics
Our sample consisted of 32 articles published from
2009 to 2013. Most of the 10 person-centered care
studies originated in Europe. The rest were from the
United States and Australia. Most of the patient-
centered care studies were performed in the United
States. Only one study of patient-centered care was
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so
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performed in Israel. Half of the family-centered care
studies were conducted in European countries; the rest
were from the United States, Canada, several African
countries, and Australia. Most culturally competent
care studies originated in the United States, one study

was from Spain, and one was from South Africa.
Study Designs
Most study designs were qualitative, particularly in the
family-centered care research (Bolster & Manias, 2010;
Coyne, O'Neill, Murphy, Costello, & O'Shea, 2011;
Coyne, 2013; Ho, 2009; Jomfeldt, Rask, Brunt, &
Svedberg, 2012; McLauglin et al., 2013; Mitchell,
Chaboyer, Burmeister, & Foster, 2009; Roets,
Rowe-Rowe, & Nel, 2012; Staniszewska et al., 2012;
Trajkovski, Schmied, Vickers, & Jackson, 2012). Three
researchers in patient-centered and culturally compe-
tent care used a mix of qualitative and quantitative
methods (Collins-McNeil et al., 2012; Haigh &
Ormandy, 2011; Walton, 2011). Studies across all con-
cepts involved quasiexperimental designs (Ailinger,
Martyn, Lasus, & Lima Garcia, 2010; Dudas et al.,
2013; Ekman et aI., 2012; Mitchell et al., 2009). Re-
searchers of person- and family-centered care used
cross-sectional designs (Edvardsson, Petersson,
Sjogren, Lindkvist, & Sandman, 2013; McCormack
et al., 2010; Sjogren, Lindkvist, Sandman, Zingmark, &
Edvardsson, 2012; Soury-Lavergne et al., 2011; Wil-
liams, Boyle, Herman, Coleman, & Hummert, 2012).
Surrogate Terms and Attributes
Surrogate terms are words considered synonymously
for the concept (Tofthagen & Fagerstrom, 2010). The
surrogate terms identified for the four concepts are
listed in Table 3. The term "family centered" was uni-
versally applied to that concept of family-centered
care, whereas the terms used to describe culturally
competent care were quite varied.

Attributes define or characterize the concept under
study (Tofthagen & Fagerstrom, 2010). The following 12
attributes were found across all four concepts. Table 3
lists the attributes by conceptual care model.
Collaborative relationship was the central attribute
endorsed by all four models of care. Such relationships
consisted of individual health care providers and
interprofessional care teams working in partnership
with the identified patient and his/her family in plan-
ning and implementing their care (Glass, Moss, & Ogle,
2012). Collaborative relationships are achieved by
providing patients/families "honest information"
about the patients' condition and related care (Mitchell
et al., 2009). In pediatric settings, collaboration also
meant including parents in their children's care
(Mitchell et al., 2009; Staniszewska et al., 2012;
Trajkovski et al., 2012). These relationships also
required nurturing partnerships with key community
stakeholders (Walton, 2011). Ekman et al. (2012)
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described three phases of partnerships: initiating,
working, and safeguarding.
Effective communication was described as a contin-
uous process involving verbal or nonverbal exchanges
of information between all health care providers and
patients (Coyne et al., 2011; McLaughlin, Melby, &
Coates, 2013). Ho (2009) suggested that effective
communication requires reflective listening with a
sense of empathy, recognizing, and understanding
nonverbal cues of communication, such as eye contact,
gestures, and facial expressions and feelings. Kelley
(2011) described effective communication as requiring
clinicians to establish trust with patients, actively
listen, use simple language, adopt an unhurried
demeanor, and assess the patient's beliefs, fears, tone
of voice, and style of speech. Kelley (2011) suggested
that matching the provider race and gender to that of
the patient improves communication. In addition,
written materials need to be understandable to those
with low literacy levels, visually appealing, and un-
cluttered (Ho, 2009).
Respectful care was characterized as being responsive

to and accepting of the person's beliefs and values,
acting in a caring, sympathetic manner (McCormack
et al., 2010), and being polite and affirming (Williams
et al., 2012). Respectful interactions with patients and
their families were characterized as sensitive and
compassionate (Staniszewska et al., 2012). Respectful
care required being open-minded about patient or
family beliefs, values, or practices that are different
from one's own (Hawala-Druy & Hill, 2012; Kelley,
2011).
A holistic perspective referred to planning and deliv-
ering care based on knowledge of the multiple facets of
the person and their family (Kennedy, 2012;
McLaughlin et al., 2013; Roets et al., 2012; Trajkovski
et al., 2012). These facets include social, cultural, psy-
chological, and spiritual as well as physical needs. A
holistic perspective also involved recognizing the in-
dividual's wishes and attending to individual stressors
(Roets et al., 2012; Trajkovski et al., 2012).
Individualized care consisted of tailoring care plans
and care delivery to the needs and wishes of patients
and/or their families. Such care included providing
psychosocial support to the family and physical care to
the patient (Mitchell et al., 2009; Staniszewska et al.,
2012). In pediatric settings, individualized care
required "getting to know" parents and their prefer-
ences (Bolster & Manias, 2010; Trajkovski et al., 2012)
and involving parents in their children's physical care,
for example, bathing and combing hair (Mitchell et al.,
2009; Staniszewska et al., 2012). In residential settings
for the elderly, it involved residents taking part in
normative activities, for example, making coffee, tak-
ing outdoor walks, playing games, or attending reli-
gious services (Edvardsson et al., 2013). Coyne et al.

(2011) described "negotiated care" that involved an
iterative exchange of information between families
and nurses to reach mutually agreeable goals and
related care. This process required nurses to remain
358 NURS OUTLOOK 64 (20r6) 352-366
flexible and nonjudgmental. Individualized care was
associated with patients having a sense of well-being
and trust; "responsive care" was associated with pa-
tients having trust in nurses (Radwin, Cabral, & Wilkes,
2009).
Interprofessional coordination required mUltiple disci -
plines to work together as a synergistic team and to
comprehensively address patient and family needs
(Coyne et aI., 2011). Bolster and Manias (2010) noted
that effective communication among team members is
critical for optimal teamwork.
Self-awareness required self-reflection to gain an
understanding of one's own assumptions and become
open to beliefs and values different than one's own
(Abdelhadi & Drach-Zahavy, 2012; Bolster & Manias,
2010; Coleman & Medvene, 2013; Edvardsson et aI.,
2013; Hawala-Druy & Hill, 2012; Walton, 2011). In
describing self-awareness, Hawala-Druy and Hill
(2012) recommended that nurses also gain an under-
standing of how intersecting patient identities and
institutionalized social injustices contribute to health
inequities.
Empowerment of patients and families was accom-
plished by providing patients or their caregivers

important health information and encouraging them
to participate in the patient's care, for example, medi-
cation administration, to assure that they had acquired
the competence and confidence to successfully
perform the task at home (Bolster & Manias, 2010).
Empowerment was also associated with assuring ac-
cess to care, providing adequate health information,
and involving patients, families, and communities in
care (Coyne, 2013; Coyne et aI., 2011; Soury-Lavergne
et aI., 2011; Walton, 2011).
Viewing the family as a unit of care meant considering
the psychosocial needs of the entire family and the
identified patient. This attribute was especially
important in pediatric or culturally diverse populations
(Ailinger et aI., 2010; Anderson & Friedemann, 2010;
Coyne, 2013; Coyne et aI., 2011; McLaughlin et aI.,
2013; Roets et aI., 2012; Staniszewska et aI., 2012;
Trajkovski et aI., 2012).
Interpersonal relationship involved establishing trust,
listening to family life stories, and coming to know the
family within the social context of their lives beyond
the health care setting (Bolster & Manias, 2010;
Trajkovski et aI., 2012). Such relationships were said
to evolve over time with repeated contacts (Bolster &
Manias, 2010).
Cultural knowledge meant gaining an understanding
and appreciation for culturally specific beliefs and
health care practices as well as factors contributing to
cultural values (Ailinger et aI., 2010; Anderson &
Friedemann, 2010; Collins-McNeil et aI., 2012;
Hawala-Druy & Hill, 2012; Ho, 2009; Kelley, 2011;
~alton, 2011). An example was knowledge about reli-
gIous practices (Ho, 2009). Some authors also advo-

cate~ for considering multiple intersecting identities as
Important component of cultural knowledge
& Hill, 2012; Walton, 2011).
Cultural skills involved incorporating cultural
knowledge and self-awareness into clinical practice
(Walton, 2011). These skills require effective cross-
cultural communication and capacities for building
partnerships at the individual and community levels
(Walton, 2011).
As noted in Table 3, the concepts ofperson-, patient-,
and family-centered care as well as culturally compe-
tent care shared the attributes of collaborating in part-
nership with patient and/or family, communicating
effectively, and acting in a respectful and caring way.
Person-, patient-, and family-centered care included
viewing patients holistically, individualizing care, and
coordinating interprofessional care as attributes.
Person-centered, patient-centered, and culturally
competent care recognized developing self-awareness
as an attribute. Empowering patients, families, and/or
communities and viewing family as a unit of care were
attributes espoused by family-centered and culturally
competent care. Forming interpersonal relationships
was shared by person-centered, patient-centered, and
culturally competent care. Gaining cultural knowledge
and developing culturally congruent, responsive
behavioral skills were unique to culturally competent
care.
Antecedents
Antecedents are events or phenomena that have been
previously associated with the concept (Tofthagen &

Fagerstrom, 2010). In this analysis, antecedents
included factors researchers cited as a rationale for
conducting their studies.
Person- and Patient-Centered Care
The most common reasons for person- and patient-
centered care were poor patient health outcomes
(Ekman et aI., 2012; Edvardsson, Fetherstonhaugh, &
Nay, 2010; Edvardsson et aI., 2013; Glass et aI., 2012;
}omfeldt et aI., 2012; Williams et aI., 2012; Radwin
et aI., 2009; Dudas et aI., 2013) and paternalistic
patient-provider relationships (Coleman & Medvene,
2013; Jomfeldt et aI., 2012; Williams et aI., 2012;
Slatore et aI., 2012). Conditions that preceded and
prompted person- or patient-centered care studies
included lack of empirical support (Edvardsson et aI.,
2010; Bolster & Manias, 2010; Ekman et aI., 2012;
Haigh & Ormandy, 2011; Abdelhadi & Drach-Zahavy,
2012; McCormack et aI., 2010; McKeown, Clarke,
Ingleton, Ryan, & Repper, 2010). Other reasons for
initiating person-centered care included concerns
about quality of life (Edvardsson et aI., 2013), incon-
gruence between person-centered philosophy and
task-oriented patient care (Bolster & Manias, 2010),
nurse-patient interaction is not person-centered
based (Bolster & Manias, 2010; Coleman & Medvene,
2013), and need for more creative ways to embrace a
person-centered framework (McKeown, Clarke,
Ingleton, Ryan, & Repper, 2010). Other reasons for
• conducting studies of patient-centered care included
NURS OUTLOOK 64 (2016) 352-366 359

high cost of care services, for example, intensive care
services at the end of life (Radwin, Ananian, Cabral,
Keeley, & Currier, 2011), poor organization and de-
livery of care (Haigh & Ormandy, 2011), and inconsis-
tent findings of relationships between experience and
adverse nurse-sensitive events (Radwin et al., 2009).
Family-Centered Care
The three most common antecedents for family-
centered care research included (a) lack of empirical
evidence in particular settings (Coyne, 2013; Coyne
et al., 2011; Kennedy, 2012; McLaughlin et al., 2013;
Soury-Lavergne et al., 2011; Trajkovski et al., 2012), (b)
unmet psychological needs of family members
(McLaughlin et al., 2013; Mitchell et al., 2009; Roets
et al., 2012), and (c) professionals having difficulty
integrating family-centered care into practice (Coyne,
2013; Coyne et al., 2011; McLaughlin et al., 2013;
Mitchell et al., 2009; Staniszewsk et al., 2012;
Trajkovski et al., 2012). Other reasons for implement-
ing the study included the high incidence of emotional
distress associated with having loved ones requiring
intensive critical care (Roets et al., 2012; Soury-
Lavergne et al., 2011; Trajkovski et al., 2012), parent
reports of being marginalized during their children's
hospitalizations (Mitchell et al., 2009; Staniszewsk
et al., 2012), and controversies surrounding family-
witnessed resuscitation (McLaughlin et al., 2013).
Culturally Competent Care
The most common antecedents for culturally compe-
tent care research were (a) health disparities (Ailinger
et al., 2010; Anderson & Friedemann, 2010; Collins-
McNeil et al., 2012; Hawala-Druy & Hill, 2012; Kelley,
2011; Walton, 2011), (b) lack of empirical evidence
demonstrating the importance of culturally competent

care (Ailinger et al., 2010; Anderson & Friedemann,
2010; Walton, 2011), (c) insufficiency of culturally
competent education leading to potential bias or in-
justices in care (Hawala-Druy & Hill, 2012; Walton,
2011), (d) limited availability of interpreters or bilin-
gual nurses (Ailinger et al., 2010; Ho, 2009), and (e)
inadequate knowledge of diseases in minority pop-
ulations (Ailinger et al., 2010; Collins-McNeil et al.,
2012). The objectives of Healthy People 2020 and the
objectives of Institute of Medicine were mentioned as
antecedents (Ailinger et al., 2010; Hawala-Druy & Hill,
2012). Other antecedents included the growing need for
culturally competent education because of the
increasingly diverse and growing U.S. population
(Hawala-Druy & Hill, 2012) and the growing need for
family health education worldwide (Anderson &
Friedemann, 2010).
In summary, the literature on all four conceptual
care models identified lack of empirical evidence as an
antecedent. The person- and family-centered care re-
searchers noted poor patient outcomes or unmet needs
of patients as antecedents. Culturally competent and
family-centered care research was associated with
difficulty integrating care models and providers'
insufficient education about these concepts. Culturally
competent care researchers also mentioned the
growing need for family health education as an ante-
cedent, which is connected to family-centered care.
Patient's emotional distress was an antecedent unique
to the family-centered care literature. The quality of
patient-provider relationships was only mentioned as
an antecedent in person-centered research. Cultural
competency researchers frequently identified health
disparities and language barriers as antecedents that

were not mentioned in the studied involving the other
three care models.
Consequences
Consequences are what happen as a result of the
phenomena under study (Tofthagen & Fagerstrom,
2010). In this analysis, consequences were the find-
ings associated with the implementation of the care
model.
Person- and Patient-Centered Care
Person-centered interventions were associated with
improved health-related outcomes, for example, pa-
tient self-care, health goal attainment, and lifestyle
(Glass et al., 2012), and less ambiguity and uncertainty
in illness (Dudas et al., 2013). Person-centered care was
also associated with shorter hospital stays, improved
functionality, and reduced hospital readmission in pa-
tients (Ekman et al., 2012). One study reported residents
who reported higher person-centered scores had
significantly higher quality of life and cognitive scores
than those who had not (Edvardsson et al., 2013;
McKeown et al., 2010). Studies also revealed that
person-centered care increased communication, satis-
faction, and improved relationships between providers
and patients (Coleman & Medvene, 2013; Williams et al.,
2012; Jomfeldt et al., 2012). Of the five patient-centered
studies, only one study reported consequences
(Radwin et al., 2009). Radwin et al. (2009) reported that
patient-centered interventions were positively related
to subsequent desired health outcomes, defined as
sense of well-being. For example, responsiveness and
proficiency of nurses were positively related to patients'
trust in nurses, and individualization was positively
associated to subsequently authentic self-

representation, optimism, and a sense of well-being.
Family-Centered Care
Reports from family members and nurses showed that
family-centered care was associated with a high qual-
ity of care (Coyne, 2013; Coyne et al., 2011; Mitchell
et al., 2009). Several studies highlighted facilitators of
family-centered care. Kennedy (2012) noted that get-
ting to know the child/patient results in effective
communication, trust, informed decision-making, and
collaborative teamwork. In another study, neonatal
intensive care unit nurses reported that family-
centered care helps parents become confident and
competent caretakers which promotes bonding with
360 NURS OUTLOOK 64 (2016) 352-366
Societal Factors
-Community resources
-Social services
-Health insurance
-Public policy
-Social justice
Institutional Factors
-Philosophy
-Policies
-Staff education
-Staffing model
-Social justice
Figure 1 - Person-, family-, and culture-centered nursing care

model.
their sick newborns (Trajkovski et al., 2012). One study
showed that 24-hr family-friendly visitation policies
and family member participation in patient care ten-
ded to be more common in pediatric than those in adult
intensive care units (Soury-Lavergne et al., 2011). Staff
education and training in family-centered principles
and practices were associated with significantly greater
family satisfaction with care than a control group
(Mitchell et al., 2009). Acute intensive care settings
posed unique challenges to the delivery of family-
centered care. Roets et al. (2012) identified 15 specific
family stressors that need to be addressed in pediatric
intensive care units: child's medical procedures, child's
appearance, inadequate overwhelming conflicting in-
formation about child, role ambiguity, child's pain and
discomfort, medical equipment, fear for child's life,
sense of helplessness, changes in child's behavior,
physical and emotional separation from child, sudden,
unexpected changes or seriousness of child's condi-
tion, complexity of health care system, separation from
family, and support when a child in the unit dies.
Neonatal intensive care unit nurses expressed a need
for institutional guidelines in support of family-
centered care (Trajkovski et al., 2012). Emergency
nurses identified a need for more education to
competently address the emotional needs of families
during and after the resuscitation of a loved one
(McLaughlin et al., 2013).
Culturally Competent Care
~onsequences of culturally competent care included
mcreased enrollment of African Americans in studies
2011), improved medication adherence

et ~1" 2010), and increased acceptable and
mterventions in minority populations'
(CollinS-McNeil et al., 2012). Ho (2009) found that pre-
dominantly white health care providers and culturally
diverse patients differed in communication style,
beliefs, values, and cultural customs which can
contribute to cross-cultural misunderstanding. Stu-
dents who received education in cultural competence
developed increased self-awareness, open-minded-
ness, appreciation for cultural differences, problem-
solving skills, appreciation for the role of families in
holistic patient care, skills in interprofessional collab-
oration, and a repertoire of family interventions
(Anderson & Friedemann, 2010; Walton, 2011). Cultural
competence education helped students broaden their
perspectives, heightened their awareness of their own
culture, including biases and stereotypes, and
increased their appreciation of team collaboration and
mutual respect of professional roles (Hawala-Druy &
Hill, 2012).
In summary, collectively, results showed improved
health-related outcomes including self-management
and mental health, for example, reduction of stress,
patient and family satisfaction, and patient- and
family-provider relationships. Person-centered care
also reduced the length of patient hospitalizations or
readmissions and improved patient functioning and
quality of life. Family-centered care was believed to
improve the quality of care and parent-child re-
lationships. Culturally competent care implemented
with members of historically oppressed racial/ethnic
groups increased their trust of health researchers and
Willingness to participate in research. Cultural

competence education helped students gain insights
about their socially constructed biases and an appre-
ciation for cultural differences. This review also
amplified certain prerequisites for successful
NURS OUTLOOK 64 (2or6) 352-366 361
Table 4 - Intersecting Identities on Continuum of Privilege-
Disadvantage
Identity
Age
Sex
Gender
Sexual orientation
Race/ ethnicity
Historical factors
Abilities
Education
Language
Health literacy
Income
Religion/spirituality
Adult
Male
Privileged
Congruent gender
Heterosexual
White/European descent

Historical privilege
Abled body and mind
High
English
High
High
JudeO-Christian
implementation of these models. Most notable were
institutional support and staff education.
A Proposed Person-, Family-, and Culture-Centered
Nursing Care Model
Given our findings of favorable outcomes associated
with each conceptual care model, similar attributes
among the models, and the importance of the
nonoverlapping attributes, we assert that merging
these models into a blended care model that in-
corporates social justice could potentially (a) foster
scientific discourse and collaboration across spe-
cialties, for example, geriatrics and pediatrics, acute
and residential care, majority and underrepresented
populations; (b) exert a synergistic benefit on patient,
family, and community health outcomes; and (c) take
the guesswork out of which model to apply to which
patient population under which circumstances.
Although the literature reveals several blended care
models, for example, Tucker's patient-centered
culturally sensitive health care model (Tucker,
Marsiske, Rice, Jones, & Herman, 2011), there are no
known nursing care models that blend all four con-
ceptual models of care. Therefore, we propose a
blended nursing model of person-, family-, and
culture-centered care that could be universally applied

to all people across all settings. The following discus-
sion describes the components and philosophical un-
derpinning of this blended model.
As illustrated in Figure 1, the proposed model builds
on existing models of care to include the person
receiving care, their family, and their culture,
comprised on intersecting identities. We chose "per-
son" rather than "patient" to emphasize the person-
hood of those for whom we serve within health care
systems. The term "patient" is setting bound, tYEically
used in hospitals or clinics, whereas the goal of health
care is to address individual and family health care
needs across settings. The term "person" encompasses
all the unique attributes of a human being that
contribute to his/her personhood (McCormack, 2004).
Cassel (1982) describes the different facets of a person ,
Disadvantaged
Children and elderly
Female
Nonconforming or transgender
Lesbian/gaylbisexual/questioning (LGBQ)
Underrepresented groups
Historical trauma
Disability/cognitive impairment/mental illness
Low
Limited English proficiency or first language is not
English
Low
Low
Non-Western religions
as having a personal history, cultural background, so-

cial roles, interpersonal relationships, political views,
personal life, perceived future, and a transcendental or
spiritual self.
Individuals tend to live within social units that
they consider to be their family. Families are char-
acterized as interdependent social systems that serve
to meet the affective, sociocultural, economic,
developmental, and physical needs of members
(Friedman, Bowden, & Jones, 2003). We agree with
Wright and Leahey (2013) that "the family is who they
say they are" (p. 55). Families mayor may not include
biologically or legally related members, multiple
generations, or individuals who reside together. We
contend that, regardless of the age of the identified
patient, his/her family should be considered in the
assessment and intervention plan. Including the
family in care can help providers: (a) understand the
person's proximal social context, (b) enlist support in
meeting the patient's care needs, (c) gage the impact
of the patient's health on the family's functioning,
and (d) identify other family members in need of
services (Friedman et aI., 2003).
The concept of holistic perspective espoused by
person-, patient-, and family-centered care models
suggests that nurses need to consider various aspects
of a person's identity in assessment, care planning,
and care delivery. Therefore, the proposed blended
model draws from theories of intersectionality with
the supposition that mUltiple aspects of one's identi-
ties contribute to one's personal sense of culture
(Crenshaw, 1991; Davis, 2008; Hancock, 2007). Culture
reflects patterns of beliefs, values, behavior, knowl-
edge, and experience that are collectively held by a
particular group in response to the sociopolitical

context and passed from one generation to the next
(Hofstede, 1980; Lederach, 1995). Put simply, culture is
"a way of life" (Griswold, 2012; Long, 1997). Each in-
dividual's worldview is shaped by his/her affiliation
with various intersecting sociocultural groups and
internalized identities (Viruell-Fuentes, Miranda, &
Abdulrahim, 2012). Thus, individuals self-define the
meaning of culture.
362 NURS OUTLOOK 64 (2016) 352-366
Recent research (Bauer, 2014; Veenstra, 2013) has
documented relationships between intersecting iden-
tities and health outcomes. Intersectionality is defined
as coexisting identities, categories, and experiences
that include, but are not limited to race, gender, class,
and sexual orientation (Hancock, 2007). The interaction
of underrepresented identities has been associated
with limited access to care, health inequality, and
power differentials in patient-provider relationships
(Davis, 2008; Hancock, 2007). Determining which
identities are most salient to the person's health needs
to be performed in partnership with the patient and/or
family. These identities can fall anywhere along a
continuum of privilege-disadvantage that is grounded
in a social justice perspective illustrated in Table 4. Our
Western health care system is based on the beliefs,
values, and practices of the privileged majority culture
of the United States. Therefore, the more identities that
a person has at the disadvantaged end of the contin-
uum, the more nursing support and advocacy that
person and family will likely require within the health
care system and the community. Assessment of
individual and family needs relative to privilege-

disadvantage facilitates tailored interventions and so-
cially just care that can promote health equity. Nurses
need to assess the impact of these interesting identities
to optimize the quality of care.
Nurse and Interprofessional Team Attributes
The blended model incorporates the 12 attributes
identified in the concept analysis. These attributes are
essential to establishing and maintaining the core
attribute, collaborative relationships. In accordance
with the American Association of Colleges of Nursing
(2008) and the American Nurses Association Code of
Ethics (2015), we added social justice. Social justice is
based on the following principles: (a) the fair and
equitable access to and delivery of services, (b) recog-
nition and reduction of power differentials, (c) atten-
tion to social determinants of health, (d) creation of
institutions policies and procedures that promote
health equity, (e) protection of human rights, and (f)
support of human development and self-actualization
(Buettner-Schmidt & Lobo, 2011). We contend that so-
cial justice is a prerequisite for quality nursing care and
essential to advancing health equity. Socially just
public policies are critical to making health resources
equitably available to all communities. Institutional
policies that reflect a philosophy of social justice are
likely to support staffing models, practitioners' skills,
and programming that address health disparities. A
major deficit in person-, patient-, and family-centered
care models is the absence of social justice: There-
fore, we positioned social justice as an important
component of the proposed blended model at the so-
cietal, institutional, and individual levels. In so doing,
this model offers a framework for examining new and
innovative ways to incorporate social justice in nursing

science, education, and practice.
Collaborative Relationship
Within the blended model, attammg an accurate
diagnosis and prescribing appropriate treatment are
predicated on the premise that nurses nurture collab-
orative relationships based on mutual trust. Collabo-
rative relationships involve reciprocal interpersonal
connections among all parties (the provider, individ-
ual, and family) and are essential to successful imple-
mentation of person-, family-, and culture-centered
nursing care (PFCC). Nurses need to engage in a
continuous process of developing the attributes of
PFCC. The person and family must feel comfortable
communicating their concerns and preferences to
nurses who are sensitive to their needs. Nurses need to
partner with the person and their family in working
toward mutually shared health goals. This reciprocal
relationship is a continuous process of learning about
the person's intersecting identities. Such relationship
building can involve trial and error and not always
knowing what to say or what to do. Cross-cultural re-
lationships are not prescriptive; they are about getting
to know the person over time through open and honest
exchanges. This ongoing therapeutic relationship is
the channel through which centered care is adminis-
tered and desired health outcomes are attained.
Institutional Factors
Within this blended model, we acknowledge institu-
tional factors that are prerequisites for the capacity to
implement the person-, family-, and culture-centered
care. Several studies reviewed in this analysis pointed
to organizational support as essential to successful

implementation of person-centered, patient-centered,
family-centered, and culturally competent care. Such
support included adopting policies, procedures, and
staffing models that facilitate centered care; providing
formal training for entire teams of providers; and
designing physical facilities to accommodate a holistic
inclusive care model that meets the needs of identified
patients and their families (Abdelhadi & Drach-
Zahavy, 2012; Coyne et al., 2011). Nursing staff educa-
tion needs to include family theory, communication
skill building, and patient teaching methods (Coyne
et al., 2011). We advocate that institutional policies
and staff development initiatives reflect philosophies
that promote socially just care and attain health
equity.
Societal Factors
Societal factors can affect patients' and families' ca-
pacities to access, engage in, and follow through with
prescribed treatment, thus affecting health outcomes.
In the blended model of care, societal factors include
health insurance, public policy, social services, com-
munity resources, and transportation (Dixon, 2000;
Marmot & Wilkinson, 2005; World Health
Organization Commission on Social Determinants of
NURS OUTLOOK 64 (2016) 352-366 363
Health, 2008). When social and cultural environments
are altered for better or worse, disease rates also
change accordingly (Marmot & Wilkinson, 2005). Thus,
to promote socially just care and attain health equity
for all persons, health programs must incorporate

ecological approaches to individual and community
assessments and interventions.
Based on our concept analysis, several conditions
were found to impede implementation of several care
models. In one study, parents of hospitalized children
reported lack of clarity about their roles, whereas
nurses reported short staffing which precluded offer-
ing families choices. Thus, barriers to family-centered
care included poor nurse-parent communication and
staffing problems that led to over-reliance on parents
for children's care (Coyne, 2013; Coyne et aI., 2011). The
most commonly identified barrier to culturally
competent care was differences between patients' and
health care providers' cultural values and customs,
language, or communication styles (Ailinger et aI.,
2010; Ho, 2009). Other factors included mistrust of
research by minority populations due to historical
factors and socioeconomic conditions, for example,
transportation problems and patient work schedules
(Kelley, 2011). The most commonly identified barriers
to patient-centered care were related to organization
and delivery of care staffing levels, for example short
staff, disruptive duties including telephone calls and
multidisciplinary team meetings, communication
barriers, and poor layout of the ward (Haigh &
Ormandy, 2011).
Evaluation of the Proposed Model
The application of the proposed model to research,
education, and clinical practice warrants empirical
evaluation.
Research
Although empirical evidence continues to support the

efficacy of each conceptual care model analyzed in this
study, additional research is needed to validate the
proposed blended person-, family-, and culture-
centered nursing care framework. Specifically, in-
struments are needed to operationalize the constructs
of the proposed model in ways that will provide clarity
and consistency across studies and health disciplines.
Process research (e.g., video-taped observations of
patient-providers interactions) could help identify and
describe nursing activities in this care model that are
typically invisible (e.g., culturally respectful care). The
results of this comparative concept analysis revEFaled a
lack of nurse researchers and the use proximal health-
related outcomes that reflected subjective opinions of
patients, family members, or providers rather than
actual patient health outcomes. Therefore, future
nursing research needs to examine clinical outcomes
that resulted from the proposed care model.
Clinical
The proposed model is designed to be relevant to
various popUlations regardless of their age, racial!
ethnic/cultural background, health status, and care
environment. Quality improvement initiatives could be
developed to evaluate institutional readiness and
possible barriers to implementation of this care model.
For example, clinicians and researchers can
collaborate in the development of measures to assess
practitioners' knowledge of and attitudes toward
adopting evidence-based practices that involve deliv-
ering person-, family-, and culture-centered nursing
care. In addition, clinicians could also assess their or -
ganization's level of readiness (e.g., institutional re-
sources, staff attributes, and organizational climate) to
fully implement the proposed blended model.

Education
The proposed model could be incorporated into un-
dergraduate- and graduate-level curricula. This model
is currently being integrated into the concept-based
undergraduate programming in our school of nursing.
At the graduate level, the concepts and attributes of
this care model could easily lend themselves to
doctoral studies. For example, the first author of this
article is currently testing the relationship component
of this model among older adult Hmong as a part of her
doctoral study.
Limitations and Implications for Research
We acknowledge several limitations of our compara-
tive concept analysis. First, the number of the articles
reviewed was small, and there were only five articles
on patient-centered care. However, we summarized
seminal work published before 2009 in the Historical
Evolution of Models section. Second, some articles,
for example, family-centered care and cultural
competency care, focused on provider perceptions of
outcomes, rather than patient outcomes. Finally, we
acknowledge that there are other conceptual care
models not reviewed for this article. We limited our
focus to four conceptual models that seem to have
been most enduring over time.
Goals of Healthy People 2020 (Office of Disease
Prevention and Health Promotion, u.S. Department of
Health and Human Services, 2015) call for improve-
ment in the quality of health care, access to health
care, health-related quality of life, health communi-
cation, and achievement of health equity. The report
emphasizes the importance of addressing the social
determinants of health and modalities of social justice

to accomplish these goals. Although professional or-
ganizations and scholars advocate for social justice
within the context of health care, this concept is
noticeably absent from the research related to models
of health care delivery. Furthermore, there is no clear
evidence that these models actually advance health
equity. Additional nursing research is vital to clearly
364 NURS OUTLOOK 64 (2016) 352-366
operationalize the implementation of social justice at
multiple levels including, but not limited to social
policy, institutional procedures, and individual clinical
practices. It is of paramount importance that such
research evaluates the impact of existing and new care
models, for example, proposed blended models, on
population-based health equity.
Conclusion
Our findings showed that a very small portion of recent
person-centered, patient-centered, family-centered, or
culturally competent research was conducted by
nurses. Most of the outcomes measured were proximal
to the care delivery, for example, patient satisfaction,
rather than health outcomes per say or health equity.
Although person-centered, patient-centered, family-
centered, and culturally competent care are concep-
tualized in the research literature as distinctly different
models, this comparative concept analysis suggests
these models have evolved to become more alike than
different. However, social justice remains conspicu-
ously absent from the research on all four care models.
Therefore, we advocate for merging these care models

into a single-blended conceptual framework that in-
corporates social justice at the societal, institutional,
and individual levels. This framework can be univer-
sally applied to all recipients of health care across all
settings. Given that empirical evidence continues to
support the efficacy of each conceptual care model
analyzed, the proposed blended person-, family-, and
culture-centered framework holds promise for
improving health care outcomes and achieving health
equity. Additional research is needed to validate that
premise.
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For my sons
and the next generation of tech-savvy managers
vii
CONTENTS
PREFACE xv
ACKNOWLEDGMENTS xvii
PA RT O N E — Information Governance Concepts,
Defi nitions, and Principles 1p
C H A P T E R 1 The Onslaught of Big Data and the
Information Governance
Imperative 3
Defi ning Information Governance 5
IG Is Not a Project, But an Ongoing Program 7
Why IG Is Good Business 7
Failures in Information Governance 8
Form IG Policies, Then Apply Technology for Enforcement 10
Notes 12

C H A P T E R 2 Information Governance, IT Governance, Data
Governance: What’s the Difference? 15
Data Governance 15
IT Governance 17
Information Governance 20
Impact of a Successful IG Program 20
Summing Up the Differences 21
Notes 22
C H A P T E R 3 Information Governance Principles 25
Accountability Is Key 27
Generally Accepted Recordkeeping Principles® 27
Contributed by Charmaine Brooks, CRM
Assessment and Improvement Roadmap 34
Who Should Determine IG Policies? 35
Notes 38
PA RT T W O — Information Governance Risk Assessment
and Strategic Planning 41g g
C H A P T E R 4 Information Risk Planning and Management
43
Step 1: Survey and Determine Legal and Regulatory
Applicability

and Requirements 43
viii CONTENTS
Step 2: Specify IG Requirements to Achieve Compliance 46
Step 3: Create a Risk Profi le 46
Step 4: Perform Risk Analysis and Assessment 48
Step 5: Develop an Information Risk Mitigation Plan 49
Step 6: Develop Metrics and Measure Results 50
Step 7: Execute Your Risk Mitigation Plan 50
Step 8: Audit the Information Risk Mitigation Program 51
Notes 51
C H A P T E R 5 Strategic Planning and Best Practices for
Information Governance 53
Crucial Executive Sponsor Role 54
Evolving Role of the Executive Sponsor 55
Building Your IG Team 56
Assigning IG Team Roles and Responsibilities 56
Align Your IG Plan with Organizational Strategic Plans 57
Survey and Evaluate External Factors 58

Formulating the IG Strategic Plan 65
Notes 69
C H A P T E R 6 Information Governance Policy Development
71
A Brief Review of Generally Accepted Recordkeeping
Principles® 71
IG Reference Model 72
Best Practices Considerations 75
Standards Considerations 76
Benefi ts and Risks of Standards 76
Key Standards Relevant to IG Efforts 77
Major National and Regional ERM Standards 81
Making Your Best Practices and Standards Selections to Inform
Your IG Framework 87
Roles and Responsibilities 88
Program Communications and Training 89
Program Controls, Monitoring, Auditing and Enforcement 89
Notes 91
PA RT T H R E E — Information Governance Key
Impact Areas Based on the IG Reference Model 95p

C H A P T E R 7 Business Consideratio ns for a Successful IG
Program 97
By Barclay T. Blair
Changing Information Environment 97
CONTENTS ix
Calculating Information Costs 99
Big Data Opportunities and Challenges 100
Full Cost Accounting for Information 101
Calculating the Cost of Owning Unstructured Information 102
The Path to Information Value 105
Challenging the Culture 107
New Information Models 107
Future State: What Will the IG-Enabled Organization Look
Like? 110
Moving Forward 111
Notes 113
C H A P T E R 8 Information Governance and Legal Functions
115

By Robert Smallwood with Randy Kahn, Esq., and Barry
Murphy
Introduction to e-Discovery: The Revised 2006 Federal Rules of
Civil Procedure Changed Everything 115
Big Data Impact 117
More Details on the Revised FRCP Rules 117
Landmark E-Discovery Case: Zubulake v. UBS Warburg 119
E-Discovery Techniques 119
E-Discovery Reference Model 119
The Intersection of IG and E-Discovery 122
By Barry Murphy
Building on Legal Hold Programs to Launch Defensible
Disposition 125
By Barry Murphy
Destructive Retention of E-Mail 126
Newer Technologies That Can Assist in E-Discovery 126
Defensible Disposal: The Only Real Way To Manage Terabytes
and Petabytes 130
By Randy Kahn, Esq.
Retention Policies and Schedules 137
By Robert Smallwood, edited by Paula Lederman, MLS
Notes 144

C H A P T E R 9 Information Governance and Records and
Information Management Functions 147
Records Management Business Rationale 149
Why Is Records Management So Challenging? 150
Benefi ts of Electronic Records Management 152
Additional Intangible Benefi ts 153
Inventorying E-Records 154
Generally Accepted Recordkeeping Principles® 155
E-Records Inventory Challenges 155
x CONTENTS
Records Inventory Purposes 156
Records Inventorying Steps 157
Ensuring Adoption and Compliance of RM Policy 168
General Principles of a Retention Scheduling 169
Developing a Records Retention Schedule 170
Why Are Retention Schedules Needed? 171
What Records Do You Have to Schedule? Inventory and Classifi
cation 173

Rationale for Records Groupings 174
Records Series Identifi cation and Classifi cation 174
Retention of E-Mail Records 175
How Long Should You Keep Old E-Mails? 176
Destructive Retention of E-Mail 177
Legal Requirements and Compliance Research 178
Event-Based Retention Scheduling for Disposition of E-Records
179
Prerequisites for Event-Based Disposition 180
Final Disposition and Closure Criteria 181
Retaining Transitory Records 182
Implementation of the Retention Schedule and Disposal of
Records 182
Ongoing Maintenance of the Retention Schedule 183
Audit to Manage Compliance with the Retention Schedule 183
Notes 186
C H A P T E R 10 Information Governance and Information
Technology Functions 189
Data Governance 191
Steps to Governing Data Effectively 192

Data Governance Framework 193
Information Management 194
IT Governance 196
IG Best Practices for Database Security and Compliance 202
Tying It All Together 204
Notes 205
C H A P T E R 11 Information Governance and Privacy and
Security Functions 207
Cyberattacks Proliferate 207
Insider Threat: Malicious or Not 208
Privacy Laws 210
Defense in Depth 212
Controlling Access Using Identity Access Management 212
Enforcing IG: Protect Files with Rules and Permissions 213
CONTENTS xi
Challenge of Securing Confi dential E-Documents 213
Apply Better Technology for Better Enforcement in the
Extended Enterprise 215

E-Mail Encryption 217
Secure Communications Using Record-Free E-Mail 217
Digital Signatures 218
Document Encryption 219
Data Loss Prevention (DLP) Technology 220
Missing Piece: Information Rights Management (IRM) 222
Embedded Protection 226
Hybrid Approach: Combining DLP and IRM Technologies 227
Securing Trade Secrets after Layoffs and Terminations 228
Persistently Protecting Blueprints and CAD Documents 228
Securing Internal Price Lists 229
Approaches for Securing Data Once It Leaves the Organization
230
Document Labeling 231
Document Analytics 232
Confi dential Stream Messaging 233
Notes 236
PA RT F O U R — Information Governance for
Delivery Platforms 239y

C H A P T E R 12 Information Governance for E-Mail and
Instant Messaging 241
Employees Regularly Expose Organizations to E-Mail Risk 242
E-Mail Polices Should Be Realistic and Technology Agnostic
243
E-Record Retention: Fundamentally a Legal Issue 243
Preserve E-Mail Integrity and Admissibility with Automatic
Archiving 244
Instant Messaging 247
Best Practices for Business IM Use 247
Technology to Monitor IM 249
Tips for Safer IM 249
Notes 251
C H A P T E R 13 Information Governance for Social Media
253
By Patricia Franks, Ph.D, CRM, and Robert Smallwood
Types of Social Media in Web 2.0 253
Additional Social Media Categories 255
Social Media in the Enterprise 256
Key Ways Social Media Is Different from E-Mail and Instant

Messaging 257
Biggest Risks of Social Media 257
Legal Risks of Social Media Posts 259
xii CONTENTS
Tools to Archive Social Media 261
IG Considerations for Social Media 262
Key Social Media Policy Guidelines 263
Records Management and Litigation Considerations for Social
Media 264
Emerging Best Practices for Managing Social Media Records
267
Notes 269
C H A P T E R 14 Information Governance for Mobile Devices
271
Current Trends in Mobile Computing 273
Security Risks of Mobile Computing 274
Securing Mobile Data 274
Mobile Device Management 275
IG for Mobile Computing 276

Building Security into Mobile Applications 277
Best Practices to Secure Mobile Applications 280
Developing Mobile Device Policies 281
Notes 283
C H A P T E R 15 Information Governance for Cloud
Computing 285
By Monica Crocker CRM, PMP, CIP, and Robert Smallwood
Defi ning Cloud Computing 286
Key Characteristics of Cloud Computing 287
What Cloud Computing Really Means 288
Cloud Deployment Models 289
Security Threats with Cloud Computing 290
Benefi ts of the Cloud 298
Managing Documents and Records in the Cloud 299
IG Guidelines for Cloud Computing
Solution

s 300
Notes 301
C H A P T E R 16 SharePoint Information Governance 303
By Monica Crocker, CRM, PMP, CIP, edited by Robert
Smallwood
Process Change, People Change 304
Where to Begin the Planning Process 306
Policy Considerations 310
Roles and Responsibilities 311
Establish Processes 312
Training Plan 313
Communication Plan 313
Note 314

CONTENTS xiii
PA RT F I V E — Long-Term Program Issues 315g g
C H A P T E R 17 Long-Term Digital Preservation 317
By Charles M. Dollar and Lori J. Ashley
Defi ning Long-Term Digital Preservation 317
Key Factors in Long-Term Digital Preservation 318
Threats to Preserving Records 320
Digital Preservation Standards 321
PREMIS Preservation Metadata Standard 328
Recommended Open Standard Technology-Neutral Formats 329
Digital Preservation Requirements 333
Long-Term Digital Preservation Capability Maturity Model®

334
Scope of the Capability Maturity Model 336
Digital Preservation Capability Performance Metrics 341
Digital Preservation Strategies and Techniques 341
Evolving Marketplace 344
Looking Forward 344
Notes 346
C H A P T E R 18 Maintaining an Information Governance
Program
and Culture of Compliance 349
Monitoring and Accountability 349
Staffi ng Continuity Plan 350
Continuous Process Improvement 351
Why Continuous Improvement Is Needed 351

Notes 353
A P P E N D I X A Information Organization and Classifi
cation:
Taxonomies and Metadata 355
By Barb Blackburn, CRM, with Robert Smallwood; edited by
Seth Earley
Importance of Navigation and Classifi cation 357
When Is a New Taxonomy Needed? 358
Taxonomies Improve Search Results 358
Metadata and Taxonomy 359
Metadata Governance, Standards, and Strategies 360
Types of Metadata 362
Core Metadata Issues 363
International Metadata Standards and Guidance 364

Records Grouping Rationale 368
Business Classifi cation Scheme, File Plans, and Taxonomy 368
Classifi cation and Taxonomy 369
xiv CONTENTS
Prebuilt versus Custom Taxonomies 370
Thesaurus Use in Taxonomies 371
Taxonomy Types 371
Business Process Analysis 377
Taxonomy Testing: A Necessary Step 379
Taxonomy Maintenance 380
Social Tagging and Folksonomies 381

Notes 383
A P P E N D I X B Laws and Major Regulations Related to
Records Management 385
United States 385
Canada 387
By Ken Chasse, J.D., LL.M.
United Kingdom 389
Australia 391
Notes 394
A P P E N D I X C Laws and Major Regulations
Related to Privacy 397
United States 397
Major Privacy Laws Worldwide, by Country 398
Notes 400

GLOSSARY 401
ABOUT THE AUTHOR 417
ABOUT THE MAJOR CONTRIBUTORS 419
INDEX 421
xv
PREFACE
I
nformation governance (IG) has emerged as a key concern for
business executives
and managers in today’s environment of Big Data, increasing
information risks, co-
lossal leaks, and greater compliance and legal demands. But few
seem to have a clear
understanding of what IG is; that is, how you defi ne what it is
and is not, and how to
implement it. This book clarifi es and codifi es these defi

nitions and provides key in-
sights as to how to implement and gain value from IG programs.
Based on exhaustive
research, and with the contributions of a number of industry
pioneers and experts, this
book lays out IG as a complete discipline in and of itself for the
fi rst time.
IG is a super-discipline that includes components of several
key fi elds: law, records
management, information technology (IT), risk management,
privacy and security,
and business operations. This unique blend calls for a new breed
of information pro-
fessional who is competent across these established and quite
complex fi elds. Training
and education are key to IG success, and this book provides the
essential underpinning
for organizations to train a new generation of IG professionals.
Those who are practicing professionals in the component fi
elds of IG will fi nd
the book useful in expanding their knowledge from traditional fi
elds to the emerging
tenets of IG. Attorneys, records and compliance managers, risk

managers, IT manag-
ers, and security and privacy professionals will fi nd thi s book a
particularly valuable
resource.
The book strives to offer clear IG concepts, actionable
strategies, and proven best
practices in an understandable and digestible way; a concerted
effort was made to
simplify language and to offer examples. There are summaries
of key points through-
out and at the end of each chapter to help the reader retain
major points. The text
is organized into fi ve parts: (1) Information Governance
Concepts, Defi nitions, and
Principles; (2) IG Risk Assessment and Strategic Planning; (3)
IG Key Impact Areas;
(4) IG for Delivery Platforms; and (5) Long-Term Program
Issues. Also included are
appendices with detailed information on taxonomy and metadata
design and on re-
cords management and privacy legislation.
One thing that is sure is that the complex fi eld of IG is
evolving. It will continue

to change and solidify. But help is here: No other book offers
the kind of compre-
hensive coverage of IG contained within these pages.
Leveraging the critical advice
provided here will smooth your path to understanding and
implementing successful
IG programs.
Robert F. Smallwood
xvii
ACKNOWLEDGMENTS
I
would like to sincerely thank my colleagues for their support
and generous contribu-
tion of their expertise and time, which made this pioneering text
possible.

Many thanks to Lori Ashley, Barb Blackburn, Barclay Blair,
Charmaine Brooks,
Ken Chasse, Monica Crocker, Charles M. Dollar, Seth Earley,
Dr. Patricia Franks,
Randy Kahn, Paula Lederman, and Barry Murphy.
I am truly honored to include their work and owe them a great
debt of gratitude.
PA RT O N E
Information
Governance
Concepts,
Defi nitions, and
Principles
3

The Onslaught
of Big Data and
the Information
Governance Imperative
C H A P T E R 1
T
he value of information in business is rising, and business
leaders are more and
more viewing the ability to govern, manage, and harvest
information as critical
to success. Raw data is now being increasingly viewed as an
asset that can be
leveraged, just like fi nancial or human capital.1 Some have
called this new age of “Big
Data” the “industrial revolution of data.”
According to the research group Gartner, Inc., Big Data is defi
ned as “high-volume,
high-velocity and high-variety information assets that demand
cost-effective, inno-
vative forms of information processing for enhanced insight and

decision making.” 2
A practical defi nition should also include the idea that the
amount of data—both struc-
tured (in databases) and unstructured (e.g., e-mail, scanned
documents) is so mas-
sive that it cannot be processed using today’s database tools and
analytic software
techniques. 3
In today’s information overload era of Big Data—characterized
by massive growth
in business data volumes and velocity—the ability to distill key
insights from enor-
mous amounts of data is a major business differentiator and
source of sustainable com-
petitive advantage. In fact, a recent report by the World
Economic Forum stated that
data is a new asset class and personal data is “the new oil.” 4
And we are generating more
than we can manage effectively with current methods and tools.
The Big Data numbers are overwhelming: Estimates and
projections vary, but it
has been stated that 90 percent of the data existing worldwide
today was created in the

last two years 5 and that every two days more information is
generated than was from
the dawn of civilization until 2003. 6 This trend will
continue: The global market for
Big Data technology and services is projected to grow at a
compound annual rate of
27 percent through 2017, about six times faster than the general
information and com-
munications technology (ICT) market. 7
Many more comparisons and statistics are available, and all
demonstrate the
incredible and continued growth of data.
Certainly, there are new and emerging opportunities arising
from the accu-
mulation and analysis of all that data we are busy generating
and collecting. New
enterprises are springing up to capitalize on data mining and
business intelligence
opportunities. The U.S. federal government joined in,
announcing $200 million in
Big Data research programs in 2012.8

4 INFORMATION GOVERNANCE
Big Data values massive accumulation of data, whereas in
business, e-discovery
realities and potential legal liabilities dictate that data be culled
to only that
which has clear business value.
But established organizations, especially larger ones, are being
crushed by this
onslaught of Big Data: It is just too expensive to keep all the
information that is being
generated, and unneeded information is a sort of irrelevant
sludge for decision makers
to wade through. They have diffi culty knowing which
information is an accurate and
meaningful “wheat” and which is simply irrelevant “chaff.”
This means they do not
have the precise information they need to base good business
decisions upon.
And all that Big Data piling up has real costs: The burden of
massive stores of
information has increased storage management costs

dramatically, caused overloaded
systems to fail, and increased legal discovery costs. 9 Further,
the longer that data is
kept, the more likely that it will need to be migrated to newer
computing platforms,
driving up conversion costs; and legally, there is the risk that
somewhere in that
mountain of data an organization stores is a piece of
information that represents a
signifi cant legal liability.10
This is where the worlds of Big Data and business collide . For
Big Data proponents,
more data is always better, and there is no perceived downside
to accumulation of mas-
sive amounts of data. In the business world, though, the
realities of legal e-discovery
mean the opposite is true. 11 To reduce risk, liability, and
costs, it is critical for unneeded
information to be disposed of in a systematic, methodical, and
“legally defensible” (jus-
tifi able in legal proceedings) way, when it no longer has legal,
regulatory, or business
value. And there also is the high-value benefi t of basing
decisions on better, cleaner

data, which can come about only through rigid, enforced
information governance
(IG) policies that reduce information glut.
Organizations are struggling to reduce and right-size their
information footprint
by discarding superfl uous and redundant data, e-documents,
and information. But the
critical issue is devising policies, methods, and processes and
then deploying information technol-
ogy (IT) to sort through which information is valuable and
which no longer has business value
and can be discarded.
IT, IG, risk, compliance, and legal representatives in
organizations have a clear
sense that most of the information stored is unneeded, raises
costs, and poses risks.
According to a survey taken at a recent Compliance,
Governance and Oversight
Counsel summit, respondents estimated that approximately 25
percent of information
stored in organizations has real business value, while 5 percent
must be kept as busi-
ness records and about 1 percent is retained due to a litigation

hold. “This means that
The onslaught of Big Data necessitates that information
governance (IG) be
implemented to discard unneeded data in a legally defensible
way.
THE ONSLAUGHT OF BIG DATA AND THE INFORMATION
GOVERNANCE IMPERATIVE 5
[about] 69 percent of information in most companies has no
business, legal, or regulatory value.
Companies that are able to dispose of this data debris return
more profi t to sharehold-
ers, can leverage more of their IT budgets for strategic
investments, and can avoid
excess expense in legal and regulatory response” (emphasis
added). 12
With a smaller information footprint , organizations can more
easily fi nd what they tt
need and derive business value from it.13 They must eliminate
the data debris regularly

and consistently, and to do this, processes and systems must be
in place to cull valuable
information and discard the data debris daily. An IG program
sets the framework to
accomplish this.
The business environment has also underscored the need for
IG. According to
Ted Friedman at Gartner, “The recent global fi nancial crisis
has put information gov-
ernance in the spotlight. . . . [It] is a priority of IT and business
leaders as a result of
various pressures, including regulatory compliance mandates
and the urgent need for
improved decision-making.” 14
And IG mastery is critical for executives: Gartner predicts that
by 2016, one in fi ve chief
information offi cers in regulated industries will be fi red from
their jobs for failed IG initiatives. s 15
Defi ning Information Governance
IG is a sort of super discipline that has emerged as a result of
new and tightened legislation

governing businesses, external threats such as hacking and data
breaches, and the recog-
nition that multiple overlapping disciplines were needed to
address today’s information
management challenges in an increasingly regulated and
litigated business environment.16
IG is a subset of corporate governance, and includes key
concepts from re-
cords management, content management, IT and data
governance, information se-
curity, data privacy, risk management, litigation readiness,
regulatory compliance,
long-term digital preservation , and even business intelligence.
This also means
that it includes related technology and discipline subcategories,
such as document
management, enterprise search, knowledge management, and
business continuity/
disaster recovery.
Only about one quarter of information organizations are
managing has real
business value.

With a smaller information footprint, it is easier for
organizations to fi nd the
information they need and derive business value from it.
IG is a subset of corporate governance.
IG is a sort of superdiscipline that encompasses a variety
of key concepts from
a variety of related disciplines.
Practicing good IG is the essential foundation for building
legally defensible
disposition practices to discard unneeded information and to
secure confi dential in-
formation, which may include trade secrets, strategic plans,
price lists, blueprints, or
personally identifi able information (PII) subject to privacy
laws; it provides the basis
for consistent, reliable methods for managing data, e-
documents, and records.

Having trusted and reliable records, reports, data, and databases
enables managers
to make key decisions with confi dence.17 And accessing that
information and business
intelligence in a timely fashion can yield a long-term
sustainable competitive advan-
tage, creating more agile enterprises.
To do this, organizations must standardize and systematize
their handling of in-
formation. They must analyze and optimize how information is
accessed, controlled,
managed, shared, stored, preserved, and audited. They must
have complete, current,
and relevant policies, processes, and technologies to manage
and control information,
including who is able to access what information , and when,
to meet external legal
and regulatory demands and internal governance policy
requirements. In short, IG is
about information control and compliance.
IG is a subset of corporate governance, which has been around
as long as corpora-
tions have existed. IG is a rather new multidisciplinary fi eld

that is still being defi ned,
but has gained traction increasingly over the past decade. The
focus on IG comes not
only from compliance, legal, and records management
functionaries but also from ex-
ecutives who understand they are accountable for the
governance of information and
that theft or erosion of information assets has real costs and
consequences.
“Information governance” is an all-encompassing term for how
an organization
manages the totality of its information.
According to the Association of Records Managers and
Administrators
(ARMA), IG is “a strategic framework composed of standards,
processes, roles, and
metrics that hold organizations and individuals accountable to
create, organize, secure,
maintain, use, and dispose of information in ways that align
with and contribute to the
organization’s goals.”18
IG includes the set of policies, processes, and controls to

manage information in compliance
with external regulatory requirements and internal governance
frameworks . Specifi c policiess
apply to specifi c data and document types, records series, and
other business informa-
tion, such as e-mail and reports.
Stated differently, IG is “a quality-control discipline for
managing, using, improv-
ing, and protecting information.” 19
Practicing good IG is the essential foundation for building
legally defensible
disposition practices to discard unneeded information.
IG is “a strategic framework composed of standards,
processes, roles, and
metrics, that hold organizations and individuals accountable to
create, orga-
nize, secure, maintain, use, and dispose of information in ways

that align with
and contribute to the organization’s goals.” 20
Fleshing out the defi nition further: “Information governance is
policy-based man-
agement of information designed to lower costs, reduce risk,
and ensure compliance
with legal, regulatory standards, and/or corporate
governance.”21 IG necessarily in-
corporates not just policies but information technologies to
audit and enforce those
policies. The IG team must be cogniza nt of information
lifecycle issues and be able
to apply the proper retention and disposition policies, including
digital preservation
where records need to be maintained for long periods.
IG Is Not a Project, But an Ongoing Program
IG is an ongoing program , not a one-time project. IG provides
an umbrella to manage
and control information output and communications. Since
technologies change so
quickly, it is necessary to have overarching policies that can
manage the various IT

platforms that an organization may use.
Compare it to a workplace safety program; every time a new
location, team member,
piece of equipment, or toxic substance is acquired by the
organization, the workplace
safety program should dictate how that is handled. If it does
not, the workplace safety
policies/procedures/training that are part of the workplace
safety program need to be
updated. Regular reviews are conducted to ensure the program
is being followed and ad-
justments are made based on the fi ndings. The effort never
ends. s 22 The same is true for IG.
IG is not only a tactical program to meet regulatory,
compliance, and litigation
demands. It can be strategic , in that it is the necessary
underpinning for developing a c
management strategy that maximizes knowledge worker
productivity while minimiz-
ing risk and costs.
Why IG Is Good Business

IG is a tough sell. It can be diffi cult to make the business case
for IG, unless there has been
some major compliance sanction, fi ne, legal loss, or colossal
data breach. In fact, the largest
IG is how an organization maintains security, complies
with regulations, and
meets ethical standards when managing information.
IG is a multidisciplinary program that requires an ongoing
effort.
impediment to IG adoption is simply identifying its benefi ts
and costs, according to the Economist
Intelligence Unit. Sure, the enterprise needs better control over
its information, but how
much better? At what cost? What is the payback period and the
return on investment? 23
It is challenging to make the business case for IG, yet making
that case is funda-

mental to getting IG efforts off the ground.
Here are eight reasons why IG makes good business sense, from
IG thought
leader Barclay Blair:
1. We can’t keep everything forever. IG makes sense
because it enables organiza-
tions to get rid of unnecessary information in a defensible
manner. Organi-
zations need a sensible way to dispose of information in order
to reduce the
cost and complexity of the IT environment. Having unnecessary
informa-
tion around only makes it more diffi cult and expensive to
harness informa-
tion that has value.
2. We can’t throw everything away. IG makes sense because
organizations can’t
keep everything forever, nor can they throw everything away.
We need
information—the right information, in the right place, at the
right time.
Only IG provides the framework to make good decisions about

what infor-
mation to keep.
3. E-discovery. IG makes sense because it reduces the cost
and pain of discov-
ery. Proactively managing information reduces the volume of
information
exposed to e-discovery and simplifi es the task of fi nding and
producing
responsive information.
4. Your employees are screaming for it—just listen. IG
makes sense because it
helps knowledge workers separate “signal” from “noise” in their
informa-
tion fl ows. By helping organizations focus on the most valuable
informa-
tion, IG improves information delivery and improves
productivity.
5. It ain’t gonna get any easier. IG makes sense because
it is a proven way for
organizations to respond to new laws and technologies that
create new re-
quirements and challenges. The problem of IG will not get

easier over
time, so organizations should get started now.
6. The courts will come looking for IG. IG makes sense
because courts and regu-
lators will closely examine your IG program. Falling short can
lead to fi nes,
sanctions, loss of cases, and other outcomes that have negative
business and
fi nancial consequences.
7. Manage risk: IG is a big one. Organizations need to do
a better job of identi-
fying and managing risk. The risk of information management
failures is a
critical risk that IG helps to mitigate.
8. E-mail: Reason enough. IG makes sense because it helps
organizations take con-
trol of e-mail. Solving e-mail should be a top priority for every
organization. 24
Failures in Information Governance
The failure to implement and enforce IG can lead to

vulnerabilities that can have dire
consequences. The theft of confi dential U.S. National Security
Agency documents
by Edward Snowden in 2013 could have been prevented by
properly enforced IG.
Also, Ford Motor Company is reported to have suffered a loss
estimated at $50 to
$100 million as a result of the theft of confi dential documents
by one of its own em-
ployees. A former product engineer who had access to
thousands of trade secret docu-
ments and designs sold them to a competing Chinese car
manufacturer. A strong IG
program would have controlled and tracked access and
prevented the theft while pro-
tecting valuable intellectual property. 25
Law enforcement agencies have also suffered from poor IG. In
a rather frivolous

case in 2013 that highlighted the lack of policy enforcement for
the mobile environ-
ment, it was reported that U.S. agents from the Federal Bureau
of Investigation used
government-issued mobile phones to send explicit text messages
and nude photographs
to coworkers. The incidents did not have a serious impact but
did compromise the
agency and its integrity, and “adversely affected the daily
activities of several squads.” 26
Proper mobile communications policies were obviously not
developed and enforced.
IG is also about information security and privacy, and serious
thought must be
given when creating policies to safeguard personal, classifi ed
or confi dential informa-
tion. Schemes to compromise or steal information can be quite
deceptive and devious,
masked by standard operating procedures—if proper IG controls
and monitoring are
not in place. To wit: Granting remote access to confi dential
information assets for
key personnel is common. Granting medical leave is also
common. But a deceptive

and dishonest employee could feign a medical leave while
downloading volumes of
confi dential information assets for a competitor—and that is
exactly what happened at
Accenture, a global consulting fi rm. During a fraudulent
medical leave, an employee
was allowed access to Accenture’s Knowledge Exchange (KX),
a detailed knowledge
base containing previous proposals, expert reports, cost-
estimating guidelines, and
case studies. This activity could have been prevented by
monitoring and analytics that
would have shown an inordinate amount of downloads—
especially for an “ailing” em-
ployee. The employee then went to work for a direct competitor
and continued to
download the confi dential information from Accenture,
estimated to be as many as
1,000 critical documents. While the online access to KX was
secure, the use of the
electronic documents could have been restricted even after the
documents were down-r
loaded, if IG measures were in place and newer technologies
(such as information
rights management [IRM] software) were deployed to secure

them directly and main-
tain that security remotely. With IRM, software security
protections can be employed
to seal the e-documents and control their use—even after they
leave the organization.
More details on IRM technology and its capabilities is presented
later in this book.
Other recent high-profi le data and document leakage cases
revealing information
security weaknesses that could have been prevented by a robust
IG program include:
■ Huawei Technologies, the largest networking and mobile
communications
company in China, was sued by U.S.-based Motorola for
allegedly conspiring
to steal trade secrets through former Motorola employees.
Ford’s loss from stolen documents in a single case of
intellectual property (IP)
theft was estimated at $50 to $100 million.

■ MI6, the U.K. equivalent of the U.S. Central Intelligence
Agency, learned that
one of its agents in military intelligence attempted to sell confi
dential docu-
ments to the intelligence services of the Netherlands for £2
million GBP
($3 million USD).
And breaches of personal information revealing failures in
privacy protection
abound; here are just a few:
■ Health information of 1,600 cardiology patients at Texas
Children’s Hospital
was compromised when a doctor’s laptop was stolen. The
information includ-
ed personal and demographic information about the patients,
including their
names, dates of birth, diagnoses, and treatment histories. 27
■ U.K. medics lost the personal records of nearly 12,000
National Health Service
patients in just eight months. Also, a hospital worker was

suspended after it was
discovered he had sent a fi le containing pay-slip details for
every member of
staff to his home e-mail account. 28
■ Personal information about more than 600 patients of the
Fraser Health
Authority in British Columbia, Canada, was stored on a laptop
stolen from
Burnaby General Hospital.
■ In December 2013, Target stores in the U.S. reported that
as many as 110 million
customer records had been breached in a massive attack that
lasted weeks.
The list of breaches and IG failures could go on and on, more
than fi lling the
pages of this book. It is clear that it is occurring and that it will
continue. IG controls to
safeguard confi dential information assets and protect privacy
cannot rely solely on the trustwor-
thiness of employees and basic security measures. Up-to-date
IG policies and enforcement
efforts and newer technology sets are needed, with active,

consistent monitoring and
program adjustments to continue to improve.
Executives and senior managers can no longer avoid the issue,
as it is abundantly
clear that the threat is real and the costs of taking such
avoidable risks can be high. A
single security breach is an IG failure and can cost the entire
business. According to
Debra Logan of Gartner, “When organizations suffer high-profi
le data losses, espe-
cially involving violations of the privacy of citizens or
consumers, they suffer serious
reputational damage and often incur fi nes or other sanctions. IT
leaders will have to
take at least part of the blame for these incidents.” 29
Form IG Policies, Then Apply Technology for Enforcement
Typically, some policies governing the use and control of
information and records
may have been established for fi nancial and compliance
reports, and perhaps e-mail,
but they are often incomplete and out-of-date and have not been
adjusted for changes

in the business environment, such as new technology platforms
(e.g., Web 2.0, social
IG controls to safeguard confi dential information assets
and protect privacy can-
not rely solely on the trustworthiness of employees and basic
security measures.
media), changing laws (e.g., U.S. Federal Rules of Civil
Procedure 2006 changes), and
additional regulations.
Further adding to the challenge is the rapid proliferation of
mobile devices like
tablets, phablets, and smartphones used in business—
information can be more easily
lost or stolen—so IG efforts must be made to preserve and
protect the enterprise’s
information assets.

Proper IG requires that policies are fl exible enough not to
hinder the proper fl ow
of information in the heat of the business battle yet strict
enough to control and audit
for misuse, policy violations, or security breaches. This is a
continuous iterative policy-
making process that must be monitored and fi ne-tuned. Even
with the absolute best
efforts, some policies will miss the mark and need to be
reviewed and adjusted.
Getting started with IG awareness is the crucial fi rst step. It
may have popped up on an
executive’s radar at one point or another and an effort might
have been made, but many
organizations leave these policies on the shelf and do not revise
them on a regular basis.
IG is the necessary underpinning for a legally defensible
disposition program that
discards data debris and helps narrow the search for meaningful
information on which
to base business decisions. IG is also necessary to protect and
preserve critical infor-
mation assets. An IG strategy should aim to minimize exposure

to risk, at a reasonable
cost level, while maximizing productivity and improving the
quality of information
delivered to knowledge users.
But a reactive, tactical project approach is not the way to go
about it—haphazardly t
swatting at technological, legal, and regulatory fl ies. A
proactive, strategic program,
with a clear, accountable sponsor, an ongoing plan, and regular
review process, is the
only way to continuously adjust IG policies to keep them
current so that they best
serve the organization’s needs.
Some organizations have created formal governance bodies to
establish strat-
egies, policies, and procedures surrounding the distribution of
information inside
and outside the enterprise. These governance bodies, steering
committees, or teams
should include members from many different functional areas,
since proper IG ne-
cessitates input from a variety of stakeholders. Representatives
from IT, records man-

agement, corporate or agency archiving, risk management,
compliance, operations,
human resources, security, legal, fi nance, and perhaps
knowledge management are
typically a part of IG teams. Often these efforts are jump-started
and organized by
an executive sponsor who utilizes third-party consulting
resources that specialize in
IG efforts, especially considering the newness of IG and its
emerging best practices.
So in this era of ever-growing Big Data, leveraging IG policies
to focus on re-
taining the information that has real business value, while
discarding the majority of
information that has no value and carries associated increased
costs and risks, is criti-
cal to success for modern enterprises. This must be
accomplished in a systematic,
consistent, and legally defensible manner by implementing a
formal IG program.
Other crucial elements of an IG program are the steps taken to
secure confi dential
information by enforcing and monitoring policies using the
appropriate information

technologies.
Getting started with IG awareness is the crucial fi rst step.
CHAPTER SUMMARY: KEY POINTS
■ The onslaught of Big Data necessitates that IG be
implemented to discard
unneeded data in a legally defensible way.
■ Big Data values massive accumulation of data, whereas in
business, e-discovery
realities and potential legal liabilities dictate that data be culled
to only that
which has clear business value.
■ Only about one quarter of the information organizations are
managing has
real business value.
■ With a smaller information footprint, it is easier for

organizations to fi nd the
information they need and derive business value from it.
■ IG is a subset of corporate governance and encompasses the
policies and
leveraged technologies meant to manage what corporate
information is re-
tained, where, and for how long, and also how it is retained.
■ IG is a sort of super discipline that encompasses a variety
of key concepts
from a variety of related and overlapping discipli nes.
■ Practicing good IG is the essential foundation for building
legally defensible
disposition practices to discard unneeded information.
■ According to ARMA, IG is “a strategic framework
composed of standards,
processes, roles, and metrics that hold organizations and
individuals account-
able to create, organize, secure, maintain, use, and dispose of
information in
ways that align with and contribute to the organization’s goals.”
30

■ IG is how an organization maintains security, complies with
regulations and
laws, and meets ethical standards when managing information.
■ IG is a multidisciplinary program that requires an ongoing
effort and active
participation of a broad cross-section of functional groups and
stakeholders.
■ IG controls to safeguard confi dential information assets
and protect privacy
cannot rely solely on the trustworthiness of employees and basic
security
measures.
■ Getting started with IG awareness is the crucial fi rst step.
Notes
1. The Economist, “Data, Data Everywhere,” February 25,
2010, www.economist.com/node/15557443
2. Gartner, Inc., “IT Glossary: Big Data,”
www.gartner.com/it-glossary/big-data/ (accessed April 15,
2013).

3. Webopedia, “Big Data,”
www.webopedia.com/TERM/B/big_data.html (accessed April
15, 2013).
http://www.economist.com/node/15557443
http://www.gartner.com/it-glossary/big-data/
http://www.webopedia.com/TERM/B/big_data.html
4. World Economic Forum, “Personal Data:The Emergence of
a New Asset Class”(January 2011), http://
www3.weforum.org/docs/WEF_ITTC_PersonalDataNewAsset_R
eport_2011.pdf
5. Deidra Paknad, “Defensible Disposal: You Can’t Keep All
Your Data Forever,” July 17, 2012, www
.forbes.com/sites/ciocentral/2012/07/17/defensible-disposal-
you-cant-keep-all-your-data-forever/
6. Susan Karlin, “Earth’s Nervous System: Looking at
Humanity Through Big Data,” www.fastcocreate
.com/1681986/earth-s-nervous-system-looking-at-humanity-

through-big-data#1(accessed March 5,
2013).
7. IDC Press Release, December 18, ,2013,
http://www.idc.com/getdoc.jsp?containerId=prUS24542113
New IDC Worldwide Big Data Technology and Services
Forecast Shows Market Expected to Grow to
$32.4 Billion in 2017
8. Steve Lohr, “How Big Data Became So Big,” New York
Times, August 11, 2012, www.nytimes.
com/2012/08/12/business/how-big-data-became-so-big-
unboxed.html?_r=2&smid=tw-share&
9. Kahn Consulting, “Information Governance Brief,”
sponsored by IBM, www.delve.us/downloads/
Brief-Defensible-Disposal.pdf (accessed March 4, 2013).
10. Barclay T. Blair, “Girding for Battle,” Law Technology
News, October 1, 2012, www.law.com/jsp/lawtech-
nologynews/PubArticleLTN.jsp?id=12025 72459732&thepage=1
11. Ibid.
12. Paknad, “Defensible Disposal.”
13. Randolph A. Kahn,

https://twitter.com/InfoParkingLot/status/273791612172259329,
November 28, 2012.
14. Gartner Press Release, “Gartner Says Master Data
Management Is Critical to Achieving Effective
Information Governance,”
www.gartner.com/newsroom/id/1898914, January 19, 2012
15. Ibid.
16. Monica Crocker, e-mail to author, June 21, 2012.
17. Economist Intelligence Unit, “The Future of Information
Governance,” www.emc.com/leadership/
business-view/future-information-governance.htm (accessed
November 14, 2013).
18. ARMA International, Glossary of Records and Information
Management Terms , 4th ed., 2012, TR 22–2012.s
19. Arvind Krishna, “Three Steps to Trusting Your Data in
2011,” IT Business Edge , posted March 9, 2011,
www.itbusinessedge.com/guest-opinions/three-steps-trusting-
your-data-2011 . (accessed November
14, 2013).
Management Terms , 4th ed., 2012, TR 22–2012.s

21. Laura DuBoisand Vivian Tero, “Practical Information
Governance: Balancing Cost, Risk, and Pro-
ductivity,” IDC White Paper (August 2010),
www.emc.com/collateral/analyst-reports/idc-practical-
information-governance-ar.pdf
23. Barclay T. Blair, Making the Case for Information
Governance: Ten Reasons IG Makes Sense , ViaLumina
Ltd, 2010. Online at http://barclaytblair.com/making-the-case-
for-ig-ebook/ (accessed November 14,
2013).
24. Barclay T. Blair, “8 Reasons Why Information Governance
(IG) Makes Sense,” June 29, 2009, www.
digitallandfi ll.org/2009/06/8-reasons-why-information-
governance-ig-makes-sense.html
25. Peter Abatan, “Corporate and Industrial Espionage to Rise
in 2011,” Enterprise Digital Rights Man-
agement,
http://enterprisedrm.tumblr.com/post/2742811887/corporate-
espionage-to-rise-in-2011 .

(accessed November 14, 2013).
26. BBC News, “FBI Staff Disciplined for Sex Texts and Nude
Pictures,” February 22, 2013, www.bbc.
co.uk/news/world-us-canada-21546135
27. Todd Ackerman, “Laptop Theft Puts Texas Children’s
Patient Info at Risk,” Houston Chronicle , July 30, 2009, e
www.chron.com/news/houston-texas/article/Laptop-theft-puts-
Texas-Children-s-patient-info-1589473.
php . (accessed March 2, 2012).
28. Jonny Greatrex, “Bungling West Midlands Medics Lose
12,000 Private Patient Records,” Sunday Mer-
cury, September 5, 2010,
www.sundaymercury.net/news/sundaymercuryexclusives/2010/0
9/05/bun-
gling-west-midlands-medics-lose-12–000-private-patient-
records-66331–27203177/ (accessed March
2, 2012).
29. Gartner Press Release, “Gartner Says Master Data
Management Is Critical to Achieving Effective
Information Governance.”

Management Terms. s
http://www3.weforum.org/docs/WEF_ITTC_PersonalDataNewA
sset_Report_2011.pdf
http://www.fastcocreate.com/1681986/earth-s-nervous-system-
looking-at-humanity-through-big-data#1
http://www.idc.com/getdoc.jsp?containerId=prUS24542113
http://www.nytimes.com/2012/08/12/business/how-big-data-
became-so-big-unboxed.html?_r=2&smid=tw-share&
http://www.delve.us/downloads/Brief-Defensible-Disposal.pdf
http://www.law.com/jsp/lawtech-
nologynews/PubArticleLTN.jsp?id=1202572459732&thepage=1
https://twitter.com/InfoParkingLot/status/273791612172259329
http://www.gartner.com/newsroom/id/1898914
http://www.emc.com/leadership/business-view/future-
information-governance.htm
http://www.itbusinessedge.com/guest-opinions/three-steps-
trusting-your-data-2011

http://www.emc.com/collateral/analyst-reports/idc-practical-
http://barclaytblair.com/making-the-case-for-ig-ebook/
http://www.digitallandfill.org/2009/06/8-reasons-why-
information-governance-ig-makes-sense.html
http://enterprisedrm.tumblr.com/post/2742811887/corporate-
espionage-to-rise-in-2011
http://www.bbc.co.uk/news/world-us-canada-21546135
http://www.chron.com/news/houston-texas/article/Laptop-theft-
puts-Texas-Children-s-patient-info-1589473.php
http://www.sundaymercury.net/news/sundaymercuryexclusives/
2010/09/05/bun-gling-west-midlands-medics-lose-
12%E2%80%93000-private-patient-records-
66331%E2%80%9327203177/
http://www.fastcocreate.com/1681986/earth-s-nervous-system-
looking-at-humanity-through-big-data#1
http://www.nytimes.com/2012/08/12/business/how-big-data-
became-so-big-unboxed.html?_r=2&smid=tw-share&
http://www.delve.us/downloads/Brief-Defensible-Disposal.pdf

http://www.digitallandfill.org/2009/06/8-reasons-why-
information-governance-ig-makes-sense.html
http://www.bbc.co.uk/news/world-us-canada-21546135
http://www.chron.com/news/houston-texas/article/Laptop-theft-
puts-Texas-Children-s-patient-info-1589473.php
http://www.sundaymercury.net/news/sundaymercuryexclusives/
2010/09/05/bun-gling-west-midlands-medics-lose-
12%E2%80%93000-private-patient-records-
66331%E2%80%9327203177/
http://www.forbes.com/sites/ciocentral/2012/07/17/defensible -
disposal-you-cant-keep-all-your-data-forever/
15
Information
Governance,
IT Governance, Data
Governance: What’s
the Difference?

C H A P T E R 2
T
here has been a great deal of confusion around the term
information gover-
nance (IG) and how it is distinct from other similar industry
terms, such as
information technology (IT) governance and data governance .
They are all
a subset of corporate governance, and in the above sequence,
become increasingly
more granular in their approach. Data governance is a part of
broader IT governance,
which is also a part of even broader information governance.
The few texts that exist
have compounded the confusion by offering a limited defi ni tion
of IG, or sometimes
offering a defi nition of IG that is just plain incorrect , often
confusing it with simple datat
governance.
So in this chapter we spell out the differences and include
examples in hopes of
clarifying what the meaning of each term is and how they are

related.
Data Governance
Data governance involves processes and controls to ensure that
information at the data
level—raw alphanumeric characters that the organization is
gathering and inputting—
is true and accurate, and unique (not redundant). It involves
data cleansing ( or data
scrubbing) to strip out corrupted, inaccurate, or extraneous data
and gg de-duplication,
to eliminate redundant occurrences of data.
Data governance focuses on information quality from the
ground up at the lowest
or root level, so that subsequent reports, analyses, and
conclusions are based on clean,
reliable, trusted data (or records) in database tables. Data
governance is the most rudi-
mentary level at which to implement information governance.
Data governance efforts
seek to ensure that formal management controls—systems,
processes, and accountable
employees who are stewards and custodians of the data—are

implemented to govern
critical data assets to improve data quality and to avoid negative
downstream effects of
poor data. The biggest negative consequence of poor or
inaccurate data is poorly and
inaccurately based decisions.
Data governance is a newer, hybrid quality control discipline
that includes
elements of data quality, data management, IG policy
development, business process
improvement, and compliance and risk management.
Data Governance Strategy Tips
Everyone in an organization wants good-quality data to work
with. But it is not so
easy to implement a data governance program. First of all, data
is at such a low level
that executives and board members are typically unaware of the
details of the “smoky

back room” of data collection: cleansing, normalization, and
input. So it is diffi cult to
gain an executive sponsor and funding to initiate the effort. 1
And if a data governance
program does move forward, there are challenges in getting
business users to adhere
to new policies. This is a crucial point, since much of the data
is being generated by
business units. But there are some general guidelines that can
help improve a data
governance program’s chances for success:
■ Identify a measureable impact. A data governance program
must be able to dem-
onstrate business value, or it will not get the executive
sponsorship and funding
it needs to move forward. A readiness assessment should
capture the current
state of data quality and whether an enterprise or business unit
level effort
is warranted. Other key issues include: Can the organization
save hard costs
by implementing data governance? Can it reach more customers
or increase
revenue generated from existing customers?2

■ Assign accountability for data quality to business units, not
IT. Typically, IT has had
responsibility for data quality, yet it is mostly not under that
department’s con-
trol, since most of the data is being generated in the business
units. A pointed
effort must be made to push responsibility and ownership for
data to the busi-
ness units that create and use the data.
■ Recognize the uniqueness of data as an asset. Unlike other
assets, such as people,
factories, equipment, and even cash, data is largely unseen, out
of sight, and
intangible. It changes daily. It spreads throughout business
units. It is copied
and deleted. Data growth can spiral out of control, obscuring
the data that has
true business value. So data has to be treated differently, and its
unique qualities
must be considered.
■ Forget the past; implement a going-forward strategy. It is a
signifi cantly greater

task to try to improve data governance across the enterprise for
existing data.
Remember, you may be trying to fi x decades of bad behavior,
mismanagement,
and lack of governance. Taking an incremental approach with an
eye to the
future provides for a clean starting point and can substantially
reduce the pain
required to implement. A proven best practice is to implement a
from-this-
point-on strategy where new data governance policies for
handling data are
implemented beginning on a certain date.
Data governance uses techniques like data cleansing and de-
duplication to
improve data quality and reduce redundancies.
INFORMATION GOVERNANCE, IT GOVERNANCE, DATA
GOVERNANCE 17
Good data governance ensures that downstream negative
effects of poor data

are avoided and that subsequent reports, analyses, and
conclusions are based
on reliable, trusted data.
■ Manage the change. Educate, educate, educate. People must
be trained to under-
stand why the data governance program is being implemented
and how it will
benefi t the business. The new policies represent a cultural
change, and people
need supportive program messages and training in order to make
the shift. 3
IT Governance
IT governance is the primary way that stakeholders can ensure
that investments in IT create
business value and contribute toward meeting business
objectives.4 This strategic align-
ment of IT with the business is challenging yet essential. IT
governance programs
go further and aim to “improve IT performance, deliver
optimum business value and
ensure regulatory compliance.” 5

Although the CIO typically has line responsibility for
implementing IT gover-
nance, the CEO and board of directors must receive reports and
updates to discharge
their responsibilities for IT governance and to see that the
program is functioning well
and providing business benefi ts.
Typically, in past decades, board members did not get involved
in overseeing IT
governance. But today it is a critical and unavoidable
responsibility. According to the
IT Governance Institute’s Board Briefi ng on IT Governance ,
“IT governance is the re-
sponsibility of the board of directors and executive
management. It is an integral part
of enterprise governance and consists of the leadership and
organizational structures
and processes that ensure that the organization’s IT sustains and
extends the organiza-
tion’s strategies and objectives.” 6
The focus is on the actual software development and
maintenance activities of the
IT department or function, and IT governance efforts focus on

making IT effi cient
and effective. That means minimizing costs by following proven
software develop-
ment methodologies and best practices, principles of data
governance and information
quality, and project management best practices while aligning
IT efforts with the busi-
ness objectives of the organization.
IT Governance Frameworks
Several IT governance frameworks can be used as a guide to
implementing an IT
governance program. (They are introduced in this chapter in a
cursory way; detailed
discussions of them are best suited to books focused solely on
IT governance.)
IT governance seeks to align business objectives with IT
strategy to deliver
business value.

Although frameworks and guidance like CobiT® and ITIL
have been widely
adopted, there is no absolute standard IT governance
framework; the combination
that works best for an organization depends on business factors,
corporate culture, IT
maturity, and staffi ng capability. The level of implementation
of these frameworks will
also vary by organization.
CobiT®
CobiT (Control Objectives for Information and related
Technology) is a process-T
based IT governance framework that represents a consensus of
experts worldwide.
Codeveloped by the IT Governance Institute and ISACA
(previously known as the
Information Systems Audit and Control Association), CobiT
addresses business
risks, control requirements, compliance, and technical issues. 7
CobiT offers IT controls that:
■ Cut IT risks while gaining business value from IT under an

umbrella of a glob-
ally accepted framework.
■ Assist in meeting regulatory compliance requirements.
■ Utilize a structured approach for improved reporting and
management deci-
sion making.
■ Provide solutions to control assessments and project
implementations to im-
prove IT and information asset control. 8
CobiT consists of detailed descriptions of processes required in
IT and also tools
to measure progress toward maturity of the IT governance
program. It is industry
agnostic and can be applied across all vertical industry sectors,
and it continues to be
revised and refi ned. 9
CobiT is broken out into three basic organizational levels and
their responsibili-
ties: (1) board of directors and executive management; (2) IT
and business manage-

ment; and (3) line-level governance, and security and control
knowledge workers. 10
The CobiT model draws on the traditional “plan, build, run,
monitor” paradigm of
traditional IT management, only with variations in semantics.
The CobiT framework
is divided into four IT domains—(1) plan and organize, (2)
acquire and implement, (3)
deliver and support, and (4) monitor and evaluate—which
contain 34 IT processes and
210 control objectives. Specifi c goals and metrics are assigned,
and responsibilities and
accountabilities are delineated.
The CobiT framework maps to the international information
security standard,
ISO 17799, and is also compatible with IT Infrastructure
Library (ITIL) and other y
“accepted practices” in IT development and operations.11
ValIT®
ValIT is a newer value-oriented framework that is compatible
with and complemen-
tary to CobiT. Its principles and best practices focus is on

leveraging IT investments
to gain maximum value. Forty key ValIT essential management
practices (analogous to
CobiT’s control objectives) support three main processes: value
governance, portfolio
management, and investment management. ValIT and CobiT
“provide a full frame-
work and supporting tool set” to help managers develop policies
to manage business
risks and deliver business value while addressing technical
issues and meeting control
objectives in a structured, methodic way. 12
GOVERNANCE 19
ITIL
ITIL (Information Technology Infrastructure Library) is a set
of process-oriented
best practices and guidance originally developed in the United
Kingdom to standard-
ize delivery of IT service manage ment. ITIL is applicable to
both the private and

public sectors and is the “most widely accepted approach to IT
service management
in the world.”13 As with other IT governance frameworks,
ITIL provides essential
guidance for delivering business value through IT, and it
“provides guidance to or-
ganizations on how to use IT as a tool to facilitate
business change, transformation
and growth.”14
ITIL best practices form the foundation for ISO/IEC 20000
(previously BS15000),
the International Service Management Standard for
organizational certifi cation and
compliance. 15 ITIL 2011 is the latest revision (as of this
printing), and it consists of fi ve
core published volumes that map the IT service cycle in a
systematic way:
1. ITIL Service Strategy
2. ITIL Service Design
3. ITIL Service Transition
4. ITIL Service Operation
5. ITIL Continual Service Improvement 16

ISO 38500
ISO/IEC 38500:2008 is an international standard that provides
high-level principles
and guidance for senior executives and directors, and those
advising them, for the
effective and effi cient use of IT. 17 Based primarily on AS
8015, the Australian IT gov-
ernance standard, it “applies to the governance of management
processes” that are
performed at the IT service level, but the guidance assists
executives in monitoring IT
and ethically discharging their duties with respect to legal and
regulatory compliance
of IT activities.
The ISO 38500 standard comprises three main sections:
1. Scope, Application and Objectives
2. Framework for Good Corporate Governance of IT
3. Guidance for Corporate Governance of IT
CobiT is process-oriented and has been widely adopted as an
IT governance
framework. ValIT is value-oriented and compatible and
complementary with

CobiT, yet focuses on value delivery.
ITIL is the “most widely accepted approach to IT service
management in the
world.”
It is largely derived from AS 8015, the guiding principles of
which were:
■ Establish responsibilities
■ Plan to best support the organization
■ Acquire validly
■ Ensure performance when required
■ Ensure conformance with rules
■ Ensure respect for human factors
The standard also has relationships with other major ISO
standards, and embraces
the same methods and approaches. 18

Corporate governance is the highest level of governance in an
organization, and a
key aspect of it is IG. IG processes are higher level than the
details of IT governance
and much higher than data governance, but both data and IT
governance can be (and
should be) a part of an overall IG program. The IG approach to
governance focuses
not on detailed IT or data capture and quality processes but
rather on controlling the
information that is generated by IT and offi ce systems. d
IG efforts seek to manage and control information assets to
lower risk, ensure com-
pliance with regulations, and improve information quality and
accessibility while imple-
menting information security measures to protect and preserve
information that has busi-
ness value.19 (See Chapter 1 for more detailed defi nitions.)
Impact of a Successful IG Program
When making the business case for IG and articulating its
benefi ts, it is useful to focus

on its central impact. Putting cost-benefi t numbers to this may
be diffi cult, unless you
ISO 38500 is an international standard that provides high-
level principles and
guidance for senior executives and directors responsible for IT
governance.
IG is how an organization maintains security, complies with
regulations and
laws, and meets ethical standards when managing information.
GOVERNANCE 21
also consider the worst-case scenario of loss or misuse of
corporate or agency records.
What is losing the next big lawsuit worth? How much are confi
dential merger and
acquisition documents worth? How much are customer records
worth? Frequently,
executives and managers do not understand the value of IG until
it is a crisis, an ex-

pensive legal battle is lost, heavy fi nes are imposed for
noncompliance, or executives
go to jail.
There are some key outputs from implementing an IG program.
A successful IG
program should enable organizations to:
■ Use common terms across the enterprise. This means that
departments must agree
on how they are going to classify document types, which
requires a cross-
functional effort. With common enterprise terms, searches for
information
are more productive and complete. This normalization process
begins with
developing a standardized corporate taxonomy, which defi nes
the terms (and
substitute terms in a custom corporate thesaurus), document
types, and their
relationships in a hierarchy.
■ Map information creation and usage. This effort can be
buttressed with the use of
technology tools such as data loss prevention , which can be

used to discover
the fl ow of information within and outside of the enterprise.
You must fi rst
determine who is accessing which information when and
where it is going. Then
you can monitor and analyze these information fl ows. The goal
is to stop the
erosion or misuse of information assets and to stem data
breaches with moni-
toring and security technology.
■ Obtain “information confi dence” —that is, the assurance
that information has ”
integrity, validity, accuracy, and quality; this means being able
to prove that the
information is reliable and that its access, use, and storage mee t
compliance and
legal demands.
■ Harvest and leverage information. Using techniques and
tools like data min-
ing and business intelligence, new insights may be gained that
provide an
enterprise with a sustainable competitive advantage over the
long term,

since managers will have more and better information as a basis
for busi-
ness decisions.21
Summing Up the Differences
IG consists of the overarching polices and processes to
optimize and leverage informa-
tion while keeping it secure and meeting legal and privacy
obligations in alignment
with stated organizational business objectives.
IT governance consists of following established frameworks
and best practices to
gain the most leverage and benefi t out of IT investments and
support accomplishment
of business objectives.
Data governance consists of the processes, methods, and
techniques to ensure that
data is of high quality, reliable, and unique (not duplicated), so
that downstream uses
in reports and databases are more trusted and accurate.

Notes
1. “New Trends and Best Practices for Data Governance
Success,” SeachDataManagement.com eBook,
http://viewer.media.bitpipe.com/1216309501_94/1288990195_9
46/Talend_sDM_SO_32247_EB-
ook_1104.pdf, accessed March 11, 2013.
2. Ibid.
3. Ibid.
4. M.N. Kooper, R. Maes, and E.E.O. RoosLindgreen, “On
the Governance of Information: Introducing
a New Concept of Governance to Support the Management of
Information,” International Journal of
Information Management 31 (2011): 195–120,
http://dl.acm.org/citation.cfm?id=2297895 . (accessed t
November 14, 2013).
5. Nick Robinson, “The Many Faces of IT Governance:
Crafting an IT Governance Architecture,”
ISACA Journal 1 (2007), www.isaca.org/Journal/Past-

Issues/2007/Volume-1/Pages/The-Many-Faces-l
of-IT-Governance-Crafting-an-IT-Governance-Architecture.aspx
6. Bryn Phillips, “IT Governance for CEOs and Members of
the Board,” 2012, p.18.
7. Ibid., p.26.
8. IBM Global Business Services/Public Sector, “Control
Objectives for Information and related Tech-
nology (CobiT®) Internationally Accepted Gold Standard for IT
Controls & Governance,” http://
www-304.ibm.com/industries/publicsector/fi
leserve?contentid=187551(accessed March 11, 2013).
■ Data governance uses techniques like data cleansing and
de-duplication to
improve data quality and reduce redundancies.
■ Good data governance ensures that downstream negative
effects of poor
data are avoided and that subsequent reports, analyses, and
conclusions are
based on reliable, trusted data.

■ IT governance seeks to align business objectives with IT
strategy to deliver
business value.
■ CobiT is processoriented and has been widely adopted as an
IT governance
framework. ValIT is valueoriented and compatible and
complementary with
CobiT yet focuses on value delivery.
■ The CobiT framework maps to the international information
security stan-
dard ISO 17799 and is also compatible with ITIL (IT
Infrastructure Library).
■ ITIL is the “most widely accepted approach to IT service
management in the
world.”
■ ISO 38500 is an international standard that provides high-
governance.

■ Information governance is how an organization maintains
security, complies
with regulations and laws, and meets ethical standards when
managing
information.
46/Talend_sDM_SO_32247_EB-ook_1104.pdf
http://dl.acm.org/citation.cfm?id=2297895
http://www.isaca.org/Journal/Past-Issues/2007/Volume-
1/Pages/The-Many-Faces-of-IT-Governance-Crafting-an-IT-
Governance-Architecture.aspx
http://www-
304.ibm.com/industries/publicsector/fileserve?contentid=18755
1

1
GOVERNANCE 23
9. Phillips, “IT Governance for CEOs and Members of the
Board.”
10. IBM Global Business Services/Public Sector, “Control
Objectives for Information and related Tech-
nology (CobiT®) Internationally Accepted Gold Standard for IT
Controls & Governance.”
11. Ibid.
12. Ibid.
13. www.itil-offi cialsite.com/ (accessed March 12, 2013).
14. ITIL, “What Is ITIL?” www.itil-offi
cialsite.com/AboutITIL/WhatisITIL.aspx(accessed March 12,
2013).
15. Ibid.
16. Ibid.
17. “ISO/IEC 38500:2008 “Corporate Governance of
Information Technology” www.iso.org/iso/

catalogue_detail?csnumber=51639(accessed November 14,
2013).
18. ISO 38500 www.38500.org/ (accessed March 12, 2013).
19. www.naa.gov.au/records-
management/agency/digital/digital-continuity/principles/
(accessed November 14,
2013).
20. ARMA International, Glossary of Records and
Information Management Terms , 4th ed. TR 22–2012 (from s
ARMA.org).
21. Arvind Krishna, “Three Steps to Trusting Your Data in
2011,” CTO Edge , March 9, 2011, www.ctoedge
.com/content/three-steps-trusting-your-data-2011
http://www.itil-officialsite.com/
http://www.itil-officialsite.com/AboutITIL/WhatisITIL.aspx
http://www.iso.org/iso/catalogue_detail?csnumber=51639
http://www.38500.org/
http://www.naa.gov.au/records-
management/agency/digital/digital-continuity/principles/
http://www.ctoedge.com/content/three-steps-trusting-your-data-

2011
http://www.ctoedge.com/content/three-steps-trusting-your-data-
2011
25
Information
Governance
Principles *
C H A P T E R 3
P
rinciples of information governance (IG) are evolving and
expanding. Successful
IG programs are characterized by ten key principles, which are
the basis for best
practices and should be designed into the IG approach. They
include:
1. Executive sponsorship. No IG effort will survive and be

successful if it does not
have an accountable, responsible executive sponsor. The
sponsor must drive
the effort, clear obstacles for the IG team or committee,
communicate the
goals and business objectives that the IG program addresses,
and keep upper
management informed on progress.
2. Information policy development and communication. Clear
policies must be es-
tablished for the access and use of information, and those
policies must be
communicated regularly and crisply to employees. Policies for
the use of e-
mail, instant messaging, social media, cloud computing, mobile
computing,
and posting to blogs and internal sites must be developed in
consultation
with stakeholders and communicated clearly. This includes
letting employees
know what the consequences of violating IG policies are, as
well as its value.
3. Information integrity. This area considers the consistency

of methods used to
create, retain, preserve, distribute, and track information.
Adhering to good
IG practices include data governance techniques and
technologies to ensure
quality data. Information integrity means there is the assurance
that informa-
tion is accurate, correct, and authentic. IG efforts to improve
data quality
and information integrity include de-duplicating (removing
redundant data)
and maintaining only unique data to reduce risk, storage costs,
and informa-
tion technology (IT) labor costs while providing accurate,
trusted information
for decision makers. Supporting technologies must enforce
policies to meet
legal standards of admissibility and preserve the integrity of
information to
guard against claims that it has been altered, tampered with, or
deleted (called
“ spoliation ”). Audit trails must be kept and monitored to
ensure compliance
with IG policies to assure information integrity. 1

4. Information organization and classifi cation. This means
standardizing formats,
categorizing all information, and semantically linking it to
related information.
It also means creating a retention and disposition schedule that
spells out how
* Portions of this chapter are adapted from Chapter 3 of
Robert F. Smallwood, Managing Electronic Records: Methods,
Best
Practices, and Technologies , © John Wiley & Sons, Inc., 2013.
Reproduced with permission of John Wiley & Sons, Inc. s
long the information (e.g. e-mail, e-documents, spreadsheets,
reports) and
records should be retained and how they are to be disposed of or
archived.
Information, and particularly documents, should be classifi ed
according to a
global or corporate taxonomy that considers the business
function and owner

of the information, and semantically links related information.
Information
must be standardized in form and format. Tools such as
document labeling
can assist in identifying and classifying documents. Metadata
associated with
documents and records must be standardized and kept up-to-
date. Good IG
means good metadata management and utilizing metadata
standards that are
appropriate to the organization.
5. Information security. This means securing information in
its three states: at rest,
in motion, and in use. It means implementing measures to
protect information
from damage, theft, or alteration by malicious outsiders and
insiders as well
as nonmalicious (accidental) actions that may compromise
information. For
instance, an employee may lose a laptop with confi dential
information, but
if proper IG policies are enforced using security-related
information tech-
nologies, the information can be secured. This can be done by

access control
methods, data or document encryption, deploying information
rights manage-
ment software, using remote digital shredding capabilities, and
implement-
ing enhanced auditing procedures. Information privacy is
closely related to
information security and is critical when dealing with
personally identifi able
information (PII).n
6. Information accessibility. Accessibility is vital not only in
the short term but also
over time using long-term digital preservation (LTDP)
techniques when
appropriate (generally if information is needed for over fi ve
years). Accessibil-
ity must be balanced with information security concerns.
Information acces-
sibility includes making the information as simple as possible to
locate and
access, which involves not only the user interface but also
enterprise search
principles, technologies, and tools. It also includes basic access
controls, such

as password management, identity and access management , and
delivering t
information to a variety of hardware devices.
7. Information control. Document management and report
management software
must be deployed to control the access to, creation, updating,
and printing
of documents and reports. When documents or reports are
declared records,
they must be assigned to the proper retention and disposition
schedule to be
retained for as long as the records are needed to comply w ith
legal retention
periods and regulatory requirements. Also, information that may
be needed or
requested in legal proceedings is safeguarded through a legal
hold process.
8. Information governance monitoring and auditing. To
ensure that guidelines and
policies are being followed and to measure employee
compliance levels, in-
formation access and use must be monitored. To guard against
claims of spo-

liation, use of e-mail, social media, cloud computing, and report
generation
should be logged in real time and maintained as an audit record.
Technology
tools such as document analytics can track how many
documents or reports
users access and print and how long they spend doing so.
9. Stakeholder consultation. Those who work most closely to
information are the
ones who best know why it is needed and how to manage it, so
business units
must be consulted in IG policy development. The IT department
understands
INFORMATION GOVERNANCE PRINCIPLES 27
its capabilities and technology plans and can best speak to those
points. Le-
gal issues must always be deferred to the in-house council or
legal team. A
cross-functional collaboration is needed for IG policies to hit
the mark and

be effective. The result is not only more secure information but
also better
information to base decisions on and closer adherence to
regulatory and legal
demands. 2
10. Continuous improvement. IG programs are not one-time
projects but rather
ongoing programs that must be reviewed periodically and
adjusted to account
for gaps or shortcomings as well as changes in the business
environment, tech-
nology usage, or business strategy.
Accountability Is Key
According to Debra Logan at Gartner Group, none of the
proffered defi nitions of IG in-
cludes “any notion of coercion, but rather ties governance to
accountability [emphasis added]
that is designed to encourage the right behavior. . . . The word
that matters most is
accountability .” The root of many problems with managing
information is the “fact that
there is no accountability for information as such.” 3

Establishing policies, procedures, processes, and controls to
ensure the quality, in-
tegrity, accuracy, and security of business records are the
fundamental steps needed to
reduce the organization’s risk and cost structure for managing
these records. Then it is
essential that IG efforts are supported by IT. The auditing,
testing, maintenance, and im-
provement of IG is enhanced by using electronic records
management (ERM) software
along with other complementary technology sets, such as workfl
ow and business process
management suite (BPMS) software and digital signatures.
Generally Accepted Recordkeeping Principles ®
Contributed by Charmaine Brooks, CRM
A major part of an IG program is managing formal business
records. Although they
account for only about 7 to 9 percent of the total information
that an organization
holds, they are the most critically important subset to manage,
as there are serious
compliance and legal ramifi cations to not doing so.

Principles of successful IG programs are emerging. They
include executive
sponsorship, information classifi cation, integrity, security,
accessibility, control,
monitoring, auditing, policy development, and continuous
improvement.
Accountability is a key aspect of IG.
Records and recordkeeping are inextricably linked with any
organized business
activity. Through the information that an organization uses and
records, creates, or
receives in the normal course of business, it knows what has
been done and by whom.
This allows the organization to effectively demonstrate
compliance with applicable
standards, laws, and regulations as well as plan what it will do
in the future to meet its
mission and strategic objectives.

Standards and principles of recordkeeping have been developed
by records and
information management (RIM) practitioners to establish
benchmarks for how or-t
ganizations of all types and sizes can build and sustain
compliant, defensible records
management (RM) programs. t
The Principles
In 2009 ARMA International published a set of eight Generally
Accepted Recordkeep-
ing Principles,® known as The Principles 4 (or sometimes
GAR Principles), to foster
awareness of good recordkeeping practices. These principles
and associated metrics
provide an IG framework that can support continuous
improvement.
The eight Generally Accepted Recordkeeping Principles are:
1. Accountability. A senior executive (or person of
comparable authority) oversees
the recordkeeping program and delegates program responsibility

to appro-
priate individuals. The organization adopts policies and
procedures to guide
personnel, and ensure the program can be audited.
2. Transparency. The processes and activities of an
organization’s recordkeeping
program are documented in a manner that is open and verifi able
and is avail-
able to all personnel and appropriate interested parties.
3. Integrity. A recordkeeping program shall be constructed so
the records and
information generated or managed by or for the organization
have a reason-
able and suitable guarantee of authenticity and reliability.
4. Protection. A recordkeeping program shall be constructed
to ensure a reason-
able level of protection to records and information that are
private, confi den-
tial, privileged, secret, or essential to business continuity.
5. Compliance. The recordkeeping program shall be
constructed to comply with ap-

plicable laws and other binding authorities, as well as the
organization’s policies.
6. Availability. An organization shall maintain records in a
manner that ensures
timely, effi cient, and accurate retrieval of needed information.
7. Retention. An organization shall maintain its records and
information for an
appropriate time, taking into account legal, regulatory, fi scal,
operational, and
historical requirements.
8. Disposition. An organization shall provide secure and
appropriate disposition
for records that are no longer required to be maintained by
applicable laws
and the organization’s policies. 5
The Generally Accepted Recordkeeping Principles consist of
eight principles
that provide an IG framework that can support continuous
improvement.

The Principles apply to all sizes of organizations, in all types
of industries, in both
the private and public sectors, and can be used to establish
consistent practices across
business units. The Principles are an IG maturity model, and it
is used as a preliminary
evaluation of recordkeeping programs and practices.
Interest in and the application of The Principles for assessing
an organization’s
recordkeeping practices have steadily increased since their
establishment in 2009. The
Principles form an accountability framework that includes the
processes, roles, stan-
dards, and metrics that ensure the effective and effi cient use of
records and informa-
tion in support of an organization’s goals and business
objectives.
As shown in Table 3.1 , the Generally Accepted
Recordkeeping Principles matu-
rity model associates characteristics that are typical in fi ve

levels of recordkeeping
capabilities ranging from 1 (substandard) to 5
(transformational). The levels are both
descriptive and color coded for ease of understanding. The eight
principles and levels
(metrics) are applied to the current state of an organization’s
recordkeeping capabili-
ties and can be cross-referenced to the policies and procedures.
While it is not unusual
for an organization to be at different levels of maturity in the
eight principles, the question
“How good is good enough?” must be raised and answered ; a
rating of less than “transforma-d
tional” may be acceptable, depending on the organization’s
tolerance for risk and an
analysis of the costs and benefi ts of moving up each level.
The maturity levels defi ne the characteristics of evolving and
maturing RM programs. The
assessment should refl ect the current RM environment and
practices. The principles
and maturity level defi nitions, along with improvement
recommendations (roadmap),
outline the tasks required to proactively approach addressing
systematic RM practices

and reach the next level of maturity for each principle. While
the Generally Accepted
Table 3.1 Generally Accepted Recordkeeping Principles
Levels
Level 1
Substandard
Characterized by an environment where recordkeeping concerns
are either not
addressed at all or are addressed in an ad hoc manner.
Level 2
In Development
Characterized by an environment where there is a developing
recognition that
recordkeeping has an impact on the organization, and the
organization may
benefi t from a more defi ned information governance program.
Level 3

Essential
Characterized by an environment where defi ned policies and
procedures exist
that address the minimum or essential legal and regulatory
requirements, but
more specifi c actions need to be taken to improve
recordkeeping.
Level 4
Proactive
Characterized by an environment where information governance
issues and
considerations are integrated into business decisions on a
routine basis, and
the organization consistently meets its legal and regulatory
obligations.
Level 5
Transformational

Characterized by an environment that has integrated information
governance
into its corporate infrastructure and business processes to such
an extent that
compliance with program requirements is routine.
Source: Used with permission from ARMA.
The Generally Accepted Recordkeeping Principles maturity
model measures
recordkeeping maturity in fi ve levels.
Recordkeeping Principles are broad in focus, they illustrate the
requirements of good
RM practices. The Principles Assessment can also be a powerful
communication tool
to promote cross-functional dialogue and collaboration among
business units and staff.
Accountability
The principle of accountability covers the assigned

responsibility for RM at a seniory
level to ensure effective governance with the appropriate level
of authority. A senior-
level executive must be high enough in the organizational
structure to have suffi cient
authority to operate the RM program effectively. The primary
role of the senior ex-
ecutive is to develop and implement RM policies, procedures,
and guidance and to
provide advice on all recordkeeping issues. The direct
responsibility for managing or
operating facilities or services may be delegated.
The senior executive must possess an understanding of the
business and legislative
environment within which the organization operates, business
functions and activities,
and the required relationships with key external stakeholders to
understand how RM
contributes to achieving the corporate mission, aims, and
objectives.
It is important for top-level executives to take ownership of the
RM issues of
the organization and to identify corrective actions required for

mitigation or ensure
resolution of problems and recordkeeping challenges. An
executive sponsor should
identify opportunities to raise awareness of the relevance and
importance of RM and
effectively communicate the benefi ts of good RM to staff and
management.
The regulatory and legal framework for RM must be clearly
identifi ed and
understood. The senior executive must have a sound knowledge
of the organization’s
information and technological architecture and actively
participate in strategic deci-
sions for IT systems acquisition and implementation.
The senior executive is responsible for ensuring that the
processes, procedures,
governance structures, and related documentation are
developed. The policies should
identify the roles and responsibilities at all levels of the
organization.
An audit process must be developed to cover all aspects of RM
within the organization,

including substantiating that suffi cient levels of accountability
have been assigned and
accountability defi ciencies are identifi ed and remedied. Audit
processes should include
compliance with the organization policies and procedures for all
records, regardless
of format or media. Accountability audit requirements for
electronic records include
employing appropriate technology to audit the information
architecture and systems.
Accountability structures must be updated and maintained as
changes occur in the
technology infrastructure.
The audit process must reinforce compliance and hold
individuals accountable.
The results should be constructive, encourage continuous
improvement, but not be
used as a means of punishment. The audit should contribute to
records program improve-
ments in risk mitigation, control, and governance issues and
have the capacity to support
sustainability.
An audit process must be developed to cover all aspects of

RM in the
organization.
Transparency
Policies are broad guidelines for the operation of the
organization and provide a basic
guide to action that prescribes the boundaries within which
business activities are to
take place. They state the course of action to be followed by the
organization, business
unit, department, and employees.
Transparency of recordkeeping practices includes documenting
processes and y
promoting an understanding of the roles and responsibilities of
all stakeholders. To be
effective, policies must be formalized and integrated into
business processes. Business rules and
recordkeeping requirements need to be communicated and
installed at all levels of the
organization.

Senior management must recognize that transparency is
fundamental to IG and
compliance. Documentation must be consistent, current, and
complete. A review and
approval process must be established to ensure that the
introduction of new programs
or changes can be implemented and integrated into business
processes.
Employees must have ready access to RM policies and
procedures. They must re-
ceive guidance and training to ensure they understand their
roles and requirements for
RM. Recordkeeping systems and business processes must be
designed and developed
to clearly defi ne the records lifecycle.
In addition to policies and procedures, guidelines and
operational instructions,
diagrams and fl owcharts, system documentation, and user
manuals must include clear
guidance on how records are to be created, retained, stored, and
dispositioned. The
documentation must be readily available and incorporated in

communications and
training provided to staff.
Integrity
Record generating systems and repositories must be assessed to
determine record-
keeping capabilities. A formalized process must be in place for
acquiring or developing new
systems, including requirements for capturing the metadata
required for lifecycle management
of records in the systems. In addition, the record must contain
all the necessary elements
of an offi cial record, including structure, content, and context.
Records integrity, y
reliability, and trustworthiness are confi rmed by ensuring that a
record was created by
a competent authority according to established processes.
Maintaining the integrity of records means that they are
complete and protected from
being altered. The authenticity of a record is ascertained from
internal and exter-
nal evidence, including the characteristics, structure, content,
and context of the
records, to verify they are genuine and not corrupted or altered.

In order to trust
that a record is authentic, organizations must ensure that
recordkeeping systems
that create, capture , and manage electronic records are capable
of protecting re-
cords from accidental or unauthorized alteration or deletion
while the record has
value.
To be effective, policies must be formalized and integrated
into business
processes.
Protection
Organizations must ensure the protection of records and ensure
they are unaltered through
loss, tampering, or corruption. This includes technological
change or the failure of digital
storage media and protecting records against damage or
deterioration.

This principle applies equally to physical and electronic
records, each of which has
unique requirements and challenges.
Access and security controls need to be established,
implemented, monitored, and
reviewed to ensure business continuity and minimize business
risk. Restrictions on
access and disclosure include the methods for protecting
personal privacy and propri-
etary information. Access and security requirements must be
integrated into the busi-
ness systems and processes for the creation, use, and storage of
records.
LTDP is a series of managed activities required to ensure
continued access to digi-
tal materials for as long as necessary. Electronic records
requiring long-term retention
may require conversion to a medium and format suitable to
ensure long-term access
and readability.
Compliance
RM programs include the development and training of the

fundamental components,
including compliance monitoring to ensure sustainability of the
program.g
Monitoring for compliance involves reviewing and inspecting
the various facets of records
management, including ensuring records are being properly
created and captured, im-
plementation of user permissions and security procedures,
workfl ow processes through
sampling to ensure adherence to policies and procedures,
ensuring records are being
retained following disposal authorization, and documentation of
records destroyed or
transferred to determine whether destruction/transfer was
authorized in accordance
with disposal instructions.
Compliance monitoring can be carried out by an internal audit,
external organiza-
tion, or RM and must be done on a regular basis.
Availability
Organizations should evaluate how effectively and effi ciently
records and information are

stored and retrieved using present equipment, networks, and
software . The evaluation
should identify current and future requirements and recommend
new systems
as appropriate. Certain factors should be considered before
upgrading or imple-
menting new systems. These factors are practicality, cost, and
effectiveness of new
confi gurations.
A major challenge for organizations is ensuring timely and
reliable access to and
use of information and that records are accessible and usable for
the entire length of
the retention period. Rapid changes and enhancements to both
hardware and software
compound this challenge.
Retention
Retention is the function of preserving and maintaining records
for continuing use. The reten-
tion schedule identifi es the actions needed to fulfi ll the
requirements for the retention
and disposal of records and provides the authority for
employees and systems to retain,

destroy, or transfer records. The records retention schedule
documents the record-
keeping requirements and procedures, identifying how records
are to be organized
and maintained, what needs to happen to records and when, who
is responsible for
doing what, and whom to contact with questions or guidance.
Organizations must identify the scope of their recordkeeping
requirements for
documenting business activities based on regulated activities
and jurisdictions that im-
pose control over records. This includes business activities
regulated by the govern-
ment for every location or jurisdiction in which the company
does business. Other
considerations for determining retention requirements include
operational, legal, fi s-
cal, and historical ones.

Records appraisal is the process of assessing the value and risk
of records to
determine their retention and disposition requirements. Legal
research is outlined in
appraisal reports. This appraisal process may be accomplished
as a part of the process
of developing the records retention schedules as well as
conducting a regular review to
ensure that citations and requirements are current.
The records retention period is the length of time that records
should be retained and d
the actions taken for them to be destroyed or preserved. The
retention periods for different
records should be based on legislative or regulatory
requirements as well as on admin-
istrative and operational requirements.
It is important to document the legal research conducted and
used to determine
whether the law or regulation has been reasonably applied to the
recordkeeping prac-
tices and provide evidence to regulatory offi cials or courts that
due diligence has been
conducted in good faith to comply with all applicable

requirements.
Disposition
Disposition is the last stage in the life cycle of records. When
the retention requirements
have been met and the records no longer serve a useful business
purpose, records may
be destroyed. Records requiring long-term or permanent
retention should be trans-
ferred to an archive for preservation. The timing of the
transfer of physical or elec-
tronic records should be determined through the records
retention schedule process.
Additional methods, including migration or conversion, are
often required to preserve
electronic records.
Records must be destroyed in a controlled and secure manner
and in accordance
with authorized disposal instructions. The destruction of records
must be clearly doc-
umented to provide evidence of destruction according to an
agreed-on program.
Destruction of records must be undertaken by methods

appropriate to the con-
fi dentiality of the records and in accordance with disposal
instructions in the records
retention schedule. An audit trail documenting the destruction
of records should be
maintained, and certifi cates of destruction should be obtained
for destruction under-
taken by third parties. In the event disposal schedules are not in
place, written autho-
rization should be obtained prior to destruction. Procedures
should specify who must
supervise the destruction of records. Approved methods of
destruction must be speci-
fi ed for each media type to ensure that information cannot be
reconstructed.
Disposition is the last stage in the life cycle of records.
Disposition is not syn-
onymous with destruction, although destruction may be one
disposal option.

Disposition is not synonymous with destruction, although
destruction may be one disposal
option. Destruction of records must be carried out under
controlled, confi dential
conditions by shredding or permanent disposition. This includes
the destruction of
confi dential microfi lm, microfi che, computer cassettes, and
computer tapes as well
as paper.
Methods of Disposition
■ Discard. The standard destruction method for nonconfi
dential records. If pos-
sible, all records should be shredded prior to recycling. Note
that transitory
records can also be shredded.
■ Shred. Confi dential and sensitive records should be
processed under strict
security. This may be accomplished internally or by secure on-
site shredding
by a third party vendor who provides certifi cates of secure
destruction. The
shredded material is then recycled.

■ Archive. This designation is for records requiring long-term
or permanent
preservation. Records of enduring legal, fi scal, administrative,
or historical
value are retained.
■ Imaging. Physical records converted to digital images, after
which the original
paper documents are destroyed.
■ Purge. This special designation is for data, documents, or
records sets that need
to be purged by removing material based on specifi ed criteria.
This often ap-
plies to structure records in databases and applications.
Assessment and Improvement Roadmap
The Generally Accepted Recordkeeping Principles® maturity
model can be lever-
aged to develop a current state assessment of an organization’s
recordkeeping prac-
tices and resources, identify gaps and assess risks, and develop
priorities for desired

improvements.
The Principles were developed by ARMA International to
identify characteristics
of an effective recordkeeping program. Each of the eight
principles identifi es issues
and practices that, when evaluated against the unique needs and
circumstances of an
organization, can be applied to improvements for a
recordkeeping program that meets
recordkeeping requirements. The Principles identify
requirements and can be used to
guide incremental improvement in creation, organization,
security, maintenance, and
other activities over a period of one to fi ve years.
Fundamentally, RM and information
governance are business disciplines that must be tightly
integrated with operational
policies, procedures, and infrastructure.
The Principles can be mapped to the four improvement areas in
Table 3.2 .
As an accepted industry guidance maturity model, the
Principles provide a con-

venient and complete framework for assessing the current state
of an organization’s
recordkeeping and developing a roadmap to identify
improvements that will bring
the organization into compliance. An assessment/analysis of the
current RM practices,
procedures, and capabilities together with current and future
state practices provides
two ways of looking at the future requirements of a complete
RM (see Table 3.3 ).
Table 3.2 Improvement Areas for Generally Accepted
Recordkeeping Principles
Improvement Area A
cc
o
u
n

ta
b
ili
ty
Tr
an
sp
ar
e
n
cy
In
te
g
ri
ty

P
ro
te
ct
io
n
C
o
m
p
lia
n
ce
A
va
ila

b
ili
ty
R
e
te
n
ti
o
n
D
is
p
o
si
ti
o

n
Roles and responsibilities ◊ ◊ ◊
Policies and procedures ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊
Communication and training ◊ ◊ ◊ ◊ ◊
Systems and automation ◊ ◊ ◊ ◊ ◊ ◊
Who Should Determine IG Policies?
When forming an IG steering committee or board, it is essential
to include represen-
tatives from cross-functional groups and at different levels of
the organization. The
committee must be driven by an executive sponsor and include
active members from
key business units as well as other departments, including IT, fi
nance, risk, compli-
ance, RM, and legal. Then corporate training/education and
communications must be
involved to keep employees trained and current on IG policies.
This function may be
performed by an outside consulting fi rm if there is no corporate

education staff.
Knowledge workers who work with records and sensitive
information in any ca-
pacity best understand the nature and value of the records they
work with as they
perform their day-to-day functions. IG policies must be
developed and communicated
clearly and consistently. Policies are worthless if people do not
know or understand them or
how to comply with them . And training is a crucial element
that will be examined in any
compliance hearing or litigation that may arise. “Did senior
management not only cre-
ate the policies but provide adequate training on them on a
consistent basis?” This will
be a key question raised. So a training plan is a necessary piece
of IG, and education
should be heavily emphasized. 6
The need for IG is increasing due to increased and tightened
regulations, in-
creased litigation, and the increased incidence of theft and
misuse of internal docu-
ments and records. Organizations that do not have active IG

programs should reevaluate
IG policies and their internal processes following any major
loss of records, the inability to
When forming an IG steering committee or board, it is
essential to include
representatives from cross-functional groups.
Knowledge workers who work with records in any capacity
best understand
the nature and value of the records they work with.
36
T
ab
le
3
.3

A
ss
es
sm
en
t
R
ep
or
t
an
d
R
oa
d
M
ap

.
P
ri
n
ci
p
le
Le
ve
l
Fi
n
d
in
g
s
R

e
q
u
ir
e
m
e
n
ts
t
o
M
o
ve
t
o

t
h
e
N
e
xt
S
te
p
A
cc
o
u
n
ta
b
ili

ty
Le
ve
l 1
Su
b
st
an
d
ar
d
N
o
s
en
io

r
ex
ec
u
ti
ve
(
o
r
p
er
so
n
o
f
co
m

p
ar
ab
le
a
u
th
o
ri
ty
)
is
r
es
p
o
n

si
b
le
f
o
r
th
e
R
M
p
ro
g
ra
m
.
T

h
e
re
co
rd
s
m
an
ag
er
r
o
le
is
la
rg
el

y
n
o
n
ex
is
te
n
t
o
r
is
a
n
a
d
m

in
is
tr
at
iv
e
an
d
/
o
r
cl
er
ic
al
r
o

le
d
is
tr
ib
u
te
d
a
m
o
n
g
g
en
er
al

s
ta
ff
.
1
.
A
ss
ig
n
R
M
r
es
p
o
n

si
b
ili
ti
es
t
o
s
en
io
r
ex
ec
u
ti
ve
.

2
.
H
ir
e
o
r
p
ro
m
o
te
r
ec
o
rd
s

m
an
ag
er
.
Tr
an
s p
ar
en
cy
Le
ve
l 1
Su
b

st
an
d
ar
d
It
is
d
iffi
c
u
lt
t
o
o
b
ta

in
in
fo
rm
at
io
n
a
b
o
u
t
th
e
o
rg
an
iz

at
io
n
o
r
it
s
re
co
rd
s
in
a
ti
m

el
y
fa
sh
io
n
.
N
o
c
le
ar
d
o
cu
m
en

ta
ti
o
n
is
r
ea
d
ily
a
va
ila
b
le
.
T
h

er
e
is
n
o
e
m
p
h
as
is
o
n
t
ra
n

sp
ar
en
cy
.
P
u
b
lic
r
e q
u
es
ts
f
o
r

in
fo
rm
at
io
n
,
d
is
co
ve
ry
f
o
r
lit
ig

at
io
n
,
re
g
u
la
to
ry
r
es
p
o
n
se
s,
o

r
o
th
er
r
eq
u
es
ts
(
e.
g
.,
f
ro
m
p

o
te
n
ti
al
b
u
si
n
es
s
p
ar
tn
er
s,
in

ve
st
o
rs
,
o
r
b
u
ye
rs
)
ca
n
n
o
t
b

e
re
ad
ily
a
cc
o
m
m
o
d
at
ed
.
T
h
e

o
rg
an
iz
at
io
n
h
as
n
o
t
es
ta
b
lis
h

ed
c
o
n
tr
o
ls
t
o
e
n
su
re
t
h
e
co
n

si
st
en
cy
o
f
in
fo
rm
at
io
n
d
is
cl
o
su

re
.
B
u
si
n
es
s
p
ro
ce
ss
es
a
re
n
o

t
w
el
l d
efi
n
ed
.
1
.
D
ev
el
o
p
p
o

lic
ie
s
an
d
p
ro
ce
d
u
re
s.
2
.
D
ev

el
o
p
t
ra
in
in
g
f
o
r
al
l l
ev
el
s
o

f
st
af
f.
3
.
Id
en
ti
fy
r
eq
u
ir
em
en

ts
f
o
r
re
co
rd
s
fi n
d
ab
ili
ty
an
d
a

cc
es
si
b
ili
ty
.
4
.
D
efi
n
e
b
u
si
n

es
s
p
ro
ce
ss
es
.
In
te
g
ri
ty
Le
ve
l 1

Su
b
st
an
d
ar
d
T
h
er
e
ar
e
n
o
s
ys

te
m
at
ic
a
u
d
it
s
o
r
d
efi
n
ed
p
ro

ce
ss
es
f
o
r
sh
o
w
in
g
t
h
e
o
ri
g

in
an
d
a
u
th
en
ti
ci
ty
o
f
a
re
co
rd

.
V
ar
io
u
s
o
rg
an
iz
at
io
n
al
f
u
n

ct
io
n
s
u
se
a
d
h
o
c
m
et
h
o
d
s

to
d
em
o
n
st
ra
te
au
th
en
ti
ci
ty
a
n

d
c
h
ai
n
o
f
cu
st
o
d
y,
a
s
ap
p
ro

p
ri
at
e,
b
u
t
th
ei
r
tr
u
st
w
o
rt
h

in
es
s
ca
n
n
o
t
ea
si
ly
b
e
g
u
ar
an

te
ed
.
1
.
D
ev
el
o
p
a
u
d
it
p
ro
ce

ss
.
2
.
Id
en
ti
fy
b
u
si
n
es
s
ac
ti
vi

ti
es
f
o
r
cr
ea
ti
o
n
a
n
d
st
o
ra
g

e
o
f
re
co
rd
s.
P
ro
te
ct
io
n
Le
ve
l 1

Su
b
st
an
d
ar
d
N
o
c
o
n
si
d
er
at

io
n
is
g
iv
en
t
o
r
ec
o
rd
p
ri
va
cy
.

R
ec
o
rd
s
ar
e
st
o
re
d
h
ap
h
az
ar
d

ly
,
w
it
h
p
ro
te
ct
io
n
t
ak
en
b
y
va

ri
o
u
s
g
ro
u
p
s
an
d
d
ep
ar
tm
en

ts
w
it
h
n
o
c
en
tr
al
iz
ed
a
cc
es
s
co

n
tr
o
ls
.
A
cc
es
s
co
n
tr
o
ls
,
if

an
y,
a
re
a
ss
ig
n
ed
b
y
th
e
au
th
o
r.

1
.
A
ss
es
s
se
cu
ri
t y
a
n
d
a
cc
es
s

co
n
tr
o
ls
.
2
.
D
ev
el
o
p
a
cc
es
s

an
d
s
ec
u
ri
ty
c
o
n
tr
o
l s
ch
em
e.

C
o
m
p
lia
n
ce
Le
ve
l 3
Es
se
n
ti
al
T

h
e
o
rg
an
iz
at
io
n
h
as
id
en
ti
fi e
d
a

ll
re
le
va
n
t
co
m
p
lia
n
ce
la
w
s
an
d

r
eg
u
la
ti
o
n
s.
R
ec
o
rd
c
re
at
io

n
a
n
d
c
ap
tu
re
a
re
s
ys
te
m
at
ic
al

ly
c
ar
ri
ed
o
u
t
in
a
cc
o
rd
an
ce
w
it

h
R
M
p
ri
n
ci
p
le
s.
T
h
e
o
rg
an
iz

at
io
n
h
as
a
s
tr
o
n
g
c
o
d
e
o
f

b
u
si
n
es
s
co
n
d
u
ct
,
w
h
ic
h
is

in
te
g
ra
te
d
in
to
it
s
o
ve
ra
ll
IG
s

tr
u
ct
u
re
a
n
d
r
ec
o
rd
-k
ee
p
in
g
p

o
lic
ie
s.
C
o
m
p
lia
n
ce
a
n
d
t
h
e

re
co
rd
s
th
at
d
em
o
n
st
ra
te
it
a
re

h
ig
h
ly
v
al
u
ed
a
n
d
m
ea
su
ra
b
le

.
1
.
Im
p
le
m
en
t
sy
st
em
s
to
c
ap
tu

re
a
n
d
p
ro
te
ct
re
co
rd
s.
2
.
D
ev

el
o
p
m
et
ad
at
a
sc
h
em
e.
3
.
D
ev
el

o
p
r
em
ed
ia
ti
o
n
p
la
n
a
n
d
im
p

le
m
en
t
co
rr
ec
ti
ve
a
ct
io
n
s.

37
T
h
e
h
o
ld
p
ro
ce
ss
is
in
te
g
ra
te

d
in
to
t
h
e
o
rg
an
iz
at
io
n
’s
in
fo

rm
at
io
n
m
an
ag
em
en
t
an
d
d
is
co
ve
ry

p
ro
ce
ss
es
f
o
r
th
e
m
o
st
c
ri
ti
ca

l s
ys
te
m
s.
T
h
e
o
rg
an
iz
at
io
n
h
as

d
efi
n
ed
s
p
ec
ifi
c
g
o
al
s
re
la
te
d

t
o
c
o
m
p
lia
n
ce
.
A
va
ila
b
ili
ty

Le
ve
l 2
In
D
ev
el
o
p
m
en
t
R
ec
o
rd

r
et
ri
ev
al
m
ec
h
an
is
m
s
h
av
e
b
ee

n
im
p
le
m
en
te
d
in
c
er
ta
in
a
re
as
o

f
th
e
o
rg
an
iz
at
io
n
.
In
t
h
o
se
a

re
as
w
it
h
r
et
ri
ev
al
m
ec
h
an
is
m
s,

it
is
p
o
ss
ib
le
t
o
d
is
ti
n
g
u
is
h

b
et
w
ee
n
o
ffi
c
ia
l r
ec
o
rd
s,
d
u
p

lic
at
es
,
an
d
n
o
n
re
co
rd
m
at
er
ia
ls

.
T
h
er
e
ar
e
so
m
e
p
o
lic
ie
s
o
n

w
h
er
e
an
d
h
o
w
t
o
s
to
re
o
ffi
c

ia
l r
ec
o
rd
s,
b
u
t
a
st
an
d
ar
d
is
n

o
t
im
p
o
se
d
a
cr
o
ss
t
h
e
o
rg
an
iz

at
io
n
.
Le
g
al
d
is
co
ve
ry
is
c
o
m

p
lic
at
ed
a
n
d
c
o
st
ly
d
u
e
to
t
h

e
in
co
n
si
st
en
t
tr
ea
tm
en
t
o
f
in
fo

rm
at
io
n
.
1
.
D
ev
el
o
p
e
n
te
rp

ri
se
c
la
ss
ifi
ca
ti
o
n
s
ch
em
e.
2
.
Id

en
ti
fy
u
se
r
se
ar
ch
a
n
d
r
et
ri
ev
al

re
q
u
ir
em
en
ts
.
3
.
D
ev
el
o
p
s

ta
n
d
ar
d
s
fo
r
m
an
ag
in
g
t
h
e
re

co
rd
s
lif
ec
yc
le
.
R
et
en
ti
o
n
Le
ve

l 2
In
D
ev
el
o
p
m
en
t
A
r
et
en
ti
o
n

s
ch
ed
u
le
is
a
va
ila
b
le
b
u
t
d
o
es

n
o
t
en
co
m
p
as
s
al
l r
ec
o
rd
s,
d
id

n
o
t
g
o
t
h
ro
u
g
h
o
ffi
c
ia
l r
ev

ie
w
,
an
d
is
n
o
t
w
el
l k
n
o
w
n
t

h
ro
u
g
h
o
u
t
th
e
o
rg
an
iz
at
io
n
.

T
h
e
re
te
n
ti
o
n
s
ch
ed
u
le
is
n
o

t
re
g
u
la
rl
y
u
p
d
at
ed
o
r
m
ai
n

ta
in
ed
.
Ed
u
ca
ti
o
n
a
n
d
t
ra
in
in

g
a
b
o
u
t
th
e
re
te
n
ti
o
n
p
o
lic

ie
s
ar
e
n
o
t
av
ai
la
b
le
.
1
.
D
ev

el
o
p
e
n
te
rp
ri
se
-w
id
e
fu
n
ct
io
n

al
r
et
en
ti
o
n
sc
h
ed
u
le
.
2
.
M

ap
r
et
en
ti
o
n
s
ch
ed
u
le
t
o
c
la
ss

ifi
ca
ti
o
n
sc
h
em
e.
3
.
Im
p
le
m
en
t

an
a
n
n
u
al
r
ev
ie
w
p
ro
ce
ss
f
o
r

re
co
rd
s
er
ie
s
an
d
le
g
al
r
es
ea
rc
h

.
4
.
D
ev
el
o
p
t
ra
in
in
g
f
o
r
cl

as
si
fi c
at
io
n
s
ch
em
e
an
d
re
te
n
ti

o
n
s
ch
ed
u
le
.
D
is
p
o
si
ti
o
n
Le

ve
l 2
In
D
ev
el
o
p
m
en
t
P
re
lim
in
ar

y
g
u
id
el
in
es
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■ Principles of successful IG programs are emerging. They
include executive
sponsorship, information classifi cation, integrity, security,
accessibility, control,
monitoring, auditing, policy development, and continuous
improvement.
■ Accountability is a key aspect of IG.

■ The Generally Accepted Recordkeeping Principles® (“The
Principles”) consist
of eight principles that provide an IG framework that can
support continuous
improvement.
■ An audit process must be developed to cover all aspects of
RM in the
organization.
■ To be effective, policies must be formalized and integrated
into business
processes.
■ Disposition is the last stage in the life cycle of records.
Disposition is not
synonymous with destruction, although destruction may be one
disposal
option.
■ Knowledge workers who work with records in any capacity
best understand
the nature and value of the records they work with.
■ When forming an information governance steering

committee or board, it is
essential to include representatives from cross-functional
groups.
■ Organizations without active IG programs should reevaluate
IG policies and
their internal processes following any major loss of records, the
inability to
produce accurate records in a timely manner, or any document
security
breach or theft.
produce accurate records in a timely manner, or any document
security breach or theft. If
review boards include a broad section of critical players on the
IG committee and
leverage executive sponsorship, theywill better prepare the
organization for legal
and regulatory rigors.
Notes
1. Laura DuBois and Vivian Tero, “Practical Information
Governance: Balancing Cost, Risk, and Produc-
tivity,” IDC White Paper, August 2010,

www.emc.com/collateral/analyst-reports/idc-practical-infor-
mation-governance-ar.pdf
2. Ibid.
3. Debra Logan, “What Is Information Governance? And Why
Is It So Hard?” January 11, 2010, http://
blogs.gartner.com/debra_logan/2010/01/11/what-is-information-
governance-and-why-is-it-so-hard/ .
infor-mation-governance-ar.pdf
http://blogs.gartner.com/debra_logan/2010/01/11/what-is-
information-governance-and-why-is-it-so-hard/
http://blogs.gartner.com/debra_logan/2010/01/11/what-is-
information-governance-and-why-is-it-so-hard/
4. ARMA International, “Generally Accepted Recordkeeping

Principles,” www.arma.org/r2/generally-
accepted-br-recordkeeping-principles/copyright (accessed
November 14, 2013).
5. ARMA International,“Information Governance Maturity
Model,” www.arma.org/r2/generally-
accepted-br-recordkeeping-principles (accessed November 14,
2013).
6. “Governance Overview (SharePoint Server 2010),”
http://technet.microsoft.com/en-us/library/
cc263356.aspx (accessed April 19, 2011).
http://www.arma.org/r2/generally-accepted-br-recordkeeping-
principles/copyright
principles
principles
principles

http://technet.microsoft.com/en-us/library/cc263356.aspx
http://technet.microsoft.com/en-us/library/cc263356.aspx
PA RT T W O
Information
Governance
Risk
Assessment
and Strategic
Planning
43
C H A P T E R 4
Information Risk
Planning and
Management

I
nformation risk planning involves a number of progressive
steps: identifying poten-
tial risks to information, weighing those risks, creating strategic
plans to mitigate the
risks, and developing those plans into specifi c policies. Then
it moves to develop-
ing metrics to measure compliance levels and identifying those
who are accountable
for executing the new risk mitigating processes. These
processes must be audited and
tested periodically not only to ensure compliance, but also to fi
ne tune and improve
the processes.
Depending on the jurisdiction, information is required by
specifi c laws and regu-
lations to be retained for specifi ed periods, and to be pr oduced
in specifi ed situations.
To determine which laws and regulations apply to your
organization’s information, re-
search into the legal and regulatory requirements for
information in the jurisdictions
in which your organization operates must be conducted.

Step 1: Survey and Determine Legal and Regulatory
Applicability and Requirements
There are federal, provincial, state, and even municipal laws
and regulations that may
apply to the retention of information (data, documents, and
records). Organizations
operating in multiple jurisdictions must maintain compliance
with laws and regula-
tions that may cross national, state, or provincial boundaries.
Legally required pri-
vacy requirements and retention periods must be researched for
each jurisdiction (e.g.
county, state, country) in which the business operates, so that it
complies with all ap-
plicable laws.
IG, compliance, and records managers must conduct their own
legislative research
to apprise themselves of mandatory information retention
requirements, as well as
privacy considerations and requirements, especially in regard to
personally identifi -
able information (PII). This information must be analyzed and

structured and pre-
sented to legal staff for discussion. Then further legal and
regulatory research must
be conducted, and fi rm legal opinions must be rendered by
legal counsel regarding
information retention, privacy, and security requirements in
accordance with laws and
regulations. This is an absolute requirement. In order to arrive
at a consensus on records
that have legal value to the organization and to construct an
appropriate retention
schedule, your legal staff or outside legal counsel should
explain the legal hold process,
provide opinions and interpretations of law that apply to your
organization, and ex-
plain the value of formal records.
Legal requirements trump all others. The retention period for a
particular type of
document or PII data or records series must meet minimum

retention, privacy, and
security requirements as mandated by law. Business needs and
other considerations are
secondary. So, legal research is required before determining and
implementing reten-
tion periods, privacy policies, and security measures.
In order to locate the regulations and citations relating to
retention of records,
there are two basic approaches. The fi rst approach is to use a
records retention
citation service, which publishes in electronic form all of the
retention-related
citations. These services usually are purchased on a subscription
basis, as the cita-
tions are updated on an annual or more frequent basis as
legislation and regula-
tions change.
Figure 4.1 is an excerpt from a Canadian records retention
database product
called FILELAW®. 1 In this case, the act, citation, and
retention periods are clearly
identifi ed.

Another approach is to search the laws and regulations directly
using online or
print resources. Records retention requirements for corporations
operating in the
United States may be found in the Code of Federal Regulations
(CFR).
In identifying information requirements and risks, legal
requirements trump
all others.
Figure 4.1 Excerpt from Canadian Records Retention
Database
Source: Ontario, Electricity Act, FILELAW database,
Thomson Publishers, May 2012.
INFORMATION RISK PLANNING AND MANAGEMENT 45
The Code of Federal Regulations (CFR) annual edition is the
codifi cation of
the general and permanent rules published in the Federal
Register by the de-
partments and agencies of the federal government. It is divided

into 50 titles
that represent broad areas subject to federal regulation. The 50
subject matter
titles contain one or more individual volumes, which are
updated once each
calendar year, on a staggered basis. The annual update cycle is
as follows: titles
1 to 16 are revised as of January 1; titles 17 to 27 are revised as
of April 1; titles
28 to 41 are revised as of July 1; and titles 42 to 50 are revised
as of October 1.
Each title is divided into chapters, which usually bear the name
of the issu-
ing agency. Each chapter is further subdivided into parts that
cover specifi c
regulatory areas. Large parts may be subdivided into subparts.
All parts are
organized in sections, and most citations to the CFR refer to
material at the
section level. 2
There is an up-to-date version that is not yet a part of the offi
cial CFR but is
updated daily, the Electronic Code of Federal Regulations (e-
CFR) . “It is not an

offi cial legal edition of the CFR. The e-CFR is an editorial
compilation of CFR ma-
terial and Federal Register amendments produced by the
National Archives and Re-
cords Administration’s Offi ce of the Federal Register . . . and
the Government Printing
Offi ce.”3 According to the gpoaccess.gov Web site:
The Administrative Committee of the Federal Register (ACFR)
has autho-
rized the National Archives and Records Administration’s
(NARA) Offi ce of
the Federal Register (OFR) and the Government Printing Offi ce
(GPO) to
develop and maintain the e-CFR as an informational resource
pending ACFR
action to grant the e-CFR offi cial legal status. The OFR/GPO
partnership is
committed to presenting accurate and reliable regulatory
information in the
e-CFR editorial compilation with the objective of establishing it
as an ACFR
sanctioned publication in the future. While every effort has
been made to en-
sure that the e-CFR on GPO Access is accurate, those relying on

it for legal
research should verify their results against the offi cial editions
of the CFR,
Federal Register and List of CFR Sections Affected (LSA), all
available online
at www.gpoaccess.gov . Until the ACFR grants it offi cial
status, the e-CFR
editorial compilation does not provide legal notice to the public
or judicial
notice to the courts.
The OFR updates the material in the e-CFR on a daily basis.
Generally,
the e-CFR is current within two business days. The current
update status is
displayed at the top of all e-CFR web pages.
For governmental agencies, a key consideration is complying
with requests for
information as a result of freedom of information laws like the
U.S. Freedom of
In the United States the Code of Federal Regulations lists
retention require-
ments for businesses, divided into 50 subject matter areas.

http://www.gpoaccess.gov
Information Act, Freedom of Information Act 2000 (in the
United Kingdom), and
similar legislation in other countries. So the process of
governing information is criti-
cal to meeting these requests by the public for governmental
records.
Step 2: Specify IG Requirements to Achieve Compliance
Once the legal research has been conducted and a process for
keeping updated on laws
and regulations has been established, specifi c external
compliance requirements can be
listed and those data, document, and record sets that apply to
those external compliance
requirements can be mapped back to applicable holdings of data
sets, document col-
lections, and records series. The crucial task is keeping your
legal and records manage-

ment staff apprised of changes and updating the policies and
processes appropriately.
Internal IG retention policies may be different from the legally
mandated minimums. For
instance, an organization that is not operating in a highly
regulated industry that wants
to balance defensible disposition with a need to retain corporate
memory and develop
knowledge management (KM) content or “knowledge bases”
may have the optiont
to dispose of e-mail that is not declared a record or cited for
legal hold after 90 days,
but may choose, based on corporate culture and other business
factors, to retain e-mail
messages for a year. Similarly, the organization may make
legally defensible disposition
decisions that reduce the total amount of information it must
manage by using a “last ac-
cessed” rationale, whereby information that has not been
accessed for over one year (or
whatever the specifi ed period is) may be destroyed and
discarded, as a matter of policy.
Step 3: Create a Risk Profi le

Creating a risk profi le is a basic building block in enterprise
risk management (yet t
another ERM acronym), which assists executives in
understanding the risks associatedr
with stated business objectives and allocating resources, within
a structured evaluation
approach or framework. There are multiple ways to create a risk
profi le, and how often
it is done, the external sources consulted, and stakeholders who
have input will vary
from organization to organization. 4 A key tenet to bear in mind
is that simpler is better and
that sophisticated tools and techniques should not make the
process overly complex. According
to the ISO, risk is defi ned as “the effect of uncertainty on
objectives,” and a risk profi le
is “a description of a set of risks.”5 Creating a risk profi le
involves identifying, docu-
menting, assessing, and prioritizing risks that an organization
may face in pursuing its
business objectives. It can be a simple table chart. Those
associated risks can then be
evaluated and delineated within a risk or IG framework.

The corporate risk profi le should be an informative tool for
executive manage-
ment, the CEO, and the board of directors, so it should refl ect
that tone. In other
The risk profi le is a high-level, executive decision input
tool.
words, it should be clear, succinct, and simplifi ed. A risk profi
le may also serve to in-
form the head of a division or subsidiary, in which case it may
contain more detail. The
process can also be applied to public and nonprofi t entities.
The time horizon for a risk profi le varies, but looking out three
to fi ve years is a good rule
of thumb . 6 The risk profi le typically will be created
annually, although semiannually
would serve the organization better and account for changes in
the business and legal
environment. But if an organization is competing in a market

sector with rapid busi-
ness cycles or volatility, the risk profi le should be generated
more frequently, perhaps
quarterly.
There are different types of risk profi le methodologies;
common methodologies
are a top-10 list, a risk map , and a heat map . The top-10 list
is a simple identifi cation
and ranking of the 10 greatest risks in relation to business
objectives. The risk map is
a visual tool that is easy to grasp, with a grid depicting a
likelihood axis and an impact
axis, usually rated on a scale of 1 to 5. In a risk assessment
meeting, stakeholders can
weigh in on risks using voting technology to generate a
consensus. A heat map is a
color-coded matrix generated by stakeholders voting on risk
level by color (e.g., red
being highest).
Information gathering is a fundamental activity in building the
risk profi le. Surveys
are good for gathering basic information, but for more detail, a
good method to employ

is direct, person-to-person interviews, beginning with
executives and risk professionals.7
Select a representative cross section of functional groups to
gain a broad view. Depend-
ing on the size of the organization, you may need to conduct 20
to 40 interviews, with
one person asking the questions and probing while another team
member takes notes
and asks occasionally for clarifi cation or elaboration. Conduct
the interviews in a com-
pressed timeframe—knock them out within one to three weeks
and do not drag the
process out, as business conditions and personnel can change
over the course of months.
Here are three helpful considerations to conducting successful
interviews.
1. Prepare some questions for interviewees in advance and
provide them to in-
terviewees so they may prepare and do some of their own
research.
2. Schedule the interview close to their offi ces, and at their
convenience.

3. Keep the time as short as possible but long enough to get
the answers you will
need: approximately 20 to 45 minutes. Be sure to leave some
open time be-
tween interviews to collect your thoughts and prepare for the
next interview.
And follow up with interviewees after analyzing and distilling
your notes to
confi rm you have gained the correct insights.
The information you will be harvesting will vary depending on
the interviewee’s
level and function. You will need to look for any hard data or
reports that show
performance and trends related to information risk. There may
be benchmarking data
A common risk profi le method is to create a prioritized or
ranked top-10
list of greatest risks to information.

available as well. Delve into information access and security
policies, policy devel-
opment, policy adherence, and the like. Ask questions about
retention of e-mail and
legal hold processes. Ask about records retention and
disposition policies. Ask about
long-term preservation of digital records. Ask about data
deletion policies. Ask for
documentation regarding IG-related training and
communications. Dig into policies
for access to confi dential data and securing vital records. Try
to get a real sense of the
way things are run, what is standard operating procedure, and
also how workers might
get around overly restrictive policies, or operate without clear
policies. Learn enough
so that you can grasp the management style and corporate
culture, and then distill that
information into your fi ndings.
Key events and developments must also be included in the risk
profi le. For in-
stance, a major data breach, the loss or potential loss of a major
lawsuit, pending regu-

latory changes that could impact your IG policies, or a change
in business ownership
or structure must all be accounted for and factored into the
information risk profi le.
Even changes in governmental leadership should be considered,
if they might impact
IG policies. These types of developments should be tracked on a
regular basis and
should continue to feed into the risk equation. 8 Key events
should be monitored and
incorporated in developing and subsequently updating the risk
profi le.
At this point, it should be possible to generate a list of specifi c
potential risks. It
may be useful to group or categorize the potential risks into
clusters, such as natural disaster,
regulatory, safety, competitive, and so forth . Armed with this
list of risks, you should solicit
input from stakeholders as to the likelihood and timing of the
threats or risks. As the
organization matures in its risk identifi cation and handling
capabilities, a good practice
is to look at the risks and their ratings from previous years to
attempt to gain insights

into change and trends—both external and internal—that
affected the risks.
Step 4: Perform Risk Analysis and Assessment
Once you have created a risk profi le and identifi ed key risks,
you must conduct an as-
sessment of the likelihood that these risks hold and their
resultant impact.
There are fi ve basic steps in conducting a risk assessment: 9
1. Identify the risks. This should be an output of creating a
risk profi le, but if con-
ducting an information risk assessment, fi rst identify the major
information-
related risks.
2. Determine potential impact. If a calculation of a range of
economic impact is
possible (e.g., lose $5 to $10 million in legal damages), then
include it. If not,
be as specifi c as possible as to how a negative event related to
an identifi ed risk
can impact business objectives.

Once a list of risks is developed, grouping them into basic
categories helps
stakeholders grasp them more easily and consider their
likelihood and impact.
3. Evaluate risk levels and probabilities and recommend
action. This may be in the
form of recommending new procedures or processes, new
investments in in-
formation technology (IT), or other actions to mitigate identifi
ed risks.
4. Create a report with recommendations and implement. You
may want to include a
risk assessment table (see Table 4.1 ) as well as written
recommendations, then
implement.
5. Review periodically. Review annually or semiannually, as
appropriate for your

organization.
A helpful exercise and visual tool is to draw up a table of top
risks, their potential
impacts, actions that have been taken to mitigate the risks, and
suggested new risk
countermeasures, as in Table 4.1 .
Step 5: Develop an Information Risk Mitigation Plan
After setting out the risks, their potential impacts, and
suggested countermeasures
for mitigation, you must create the information risk mitigation
plan , which means
developing options and tasks to reduce the specifi ed risks and
improve the odds of
achieving business objectives. 10 Basically, you are putting in
writing the information
you have collected and analyzed in creating the risk profi le and
risk assessment, and as-
signing specifi cs. The information risk mitigation plan should
include a timetable and
milestones for implementation of the recommended risk
mitigation measures, includ-
ing IT acquisition and implementation and assigning roles and

responsibilities, such
as executive sponsor, project manager (PM), and project team.
Table 4.1 Risk Assessment
What Are
the
Risks?
How Might
They Impact
Business
Objectives?
Actions and
Processes
Currently
in Place
Additional
Resources
Needed to
Manage This Risk
Action

by
Whom?
Action by
When? Done
Breach of
confi dential
documents
Compromise
confi dential
information
Compromise
competitive
position
Compromise
business
negotiations
Utilizing ITIL
and CobiT IT
frameworks

Published
security
policies
Semiannual
security
audits
Implement newer
technologies
including
information rights
management
Implement quarterly
audits
IT staff,
security
offi cer
01/10/2016 01/10/2016
The risk mitigation plan develops risk reduction options and

tasks to reduce
specifi ed risks and improve the odds for achieving business
objectives.
Step 6: Develop Metrics and Measure Results
How do you know how well you are doing? Have you made
progress in reducing
your organization’s exposure to information risk? To measure
conformance and per-
formance of your IG program, you must have an objective way
to measure how you
are doing, which means numbers and metrics. Assigning some
quantitative measures
that are meaningful and do, in fact, measure progress may take
some serious effort and
consultation with stakeholders. Determining relevant ways of
measuring progress will
allow executives to see progress, as, realistically, reducing risk
is not something anyone
can see or feel—the painful realizations are made only when the

risk comes home to
roost. Also, valid metrics help to justify investment in the IG
program.
Although the proper metrics will vary from organization to
organization, some
specifi c metrics include:
■ Reduce the data lost on stolen or misplaced laptops by 50
percent over the
previous fi scal year.
■ Reduce the number of hacker intrusion events by 75
percent over the previous
fi scal year.
■ Reduce e-discovery costs by 25 percent over the previous
fi scal year.
■ Reduce the number of adverse fi ndings in the risk and
compliance audit by 50
percent over the previous fi scal year.
■ Provide information risk training to 100 percent of the
knowledge-level work-

force this fi scal year.
■ Roll out the implementation of information rights
management software to
protect confi dential e-documents to 50 users this fi scal year.
■ Provide confi dential messaging services for the
organization’s 20 top executives
this fi scal year.
Your organization’s metrics should be tailored to address the
primary goals of your
IG program and should tie directly to stated business objectives.
Step 7: Execute Your Risk Mitigation Plan
Now that you have the risk mitigation plan, it must be
executed. To do so, you must set
up regular project/program team meetings, develop key reports
on your information risk
mitigation metrics, and manage the process. This is done using
proven project and pro-
gram management tools and techniques, which you may want to
supplement with collab-
oration software tools, knowledge management software, or

even internal social media.
But most important, execution of the risk mitigation plan
involves communicating
clearly and regularly with the IG team on the progress and
status of the IG effort to
reduce information risk.
Metrics are required to measure progress in the risk
mitigation plan.
Step 8: Audit the Information Risk Mitigation Program
The metrics you have developed to measure risk mitigation
effectiveness must also be
used for audit purposes. Put a process in place to separately and
independently audit
compliance to risk mitigation measures, to see that they are
being implemented. The
result of the audit should be a useful input in improving and fi
ne-tuning the program.

It should not be viewed as an opportunity to cite shortfalls and
implement punitive
actions. It should be a periodic and regular feedback loop into
the IG program.
Notes
1. Ontario, Electricity Act, FILELAW database, Thomson
Publishers, May 2012.
2. U.S. Government Printing Offi ce (GPO), “Code of Federal
Regulations,” www.gpo.gov/help/index
.html#about_code_of_federal_regulations.htm (accessed April
22, 2012).
3. National Archives and Records Administration, “Electronic
Code of Federal Regulations,” http://ecfr
.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl
(accessed October 2, 2012).
4. John Fraser and Betty Simkins, eds., Enterprise Risk
Management: Today’s Leading Research and Best
Practices for Tomorrow’s Executives (Hoboken, NJ: John
Wiley & Sons, 2010), p. 171. s
5. “ISO 31000 2009 Plain English, Risk Management

Dictionary,” www.praxiom.com/iso-31000-terms
.htm (accessed March 25, 2013).
6. Fraser and Simkins, p. 172.
7. Ibid.
8. Ibid., p. 179.
9. Health and Safety Executive, “Five Steps to Risk
Assessment,” www.hse.gov.uk/risk/fi vesteps.htm
(accessed March 25, 2013).
10. Project Management Institute, A Guide to the Project
Management Body of Knowledge ( PMBOK Guide ),
4th ed. (Project Management Institute, 2008), ANSI/PMI 99-
001-2008, pp. 273–312.
■ In identifying information requirements and risks, legal
requirements trump
all others.
■ In the United States, the Code of Federal Regulations lists
information reten-
tion requirements for businesses, divided into 50 subject matter

areas.
■ The risk profi le is a high-level, executive decision input tool.
■ A common risk profi le method is to create a prioritized or
ranked top-10 list
of greatest risks to information.
■ Once a list of risks is developed, grouping them into basic
categories helps stake-
holders to grasp them more easily and consider their likelihood
and impact.
■ The risk mitigation plan develops risk reduction options and
tasks to reduce
objectives.
■ Metrics are required to measure progress in the risk
mitigation plan.
■ The risk mitigation plan must be reviewed and audited
regularly and proper
adjustments made.

http://www.gpo.gov/help/index.html#about_code_of_federal_re
gulations.htm
http://ecfr.gpoaccess.gov/cgi/t/text/text-
idx?c=ecfr&tpl=%2Findex.tpl
http://www.praxiom.com/iso-31000-terms.htm
http://www.hse.gov.uk/risk/fivesteps.htm
gulations.htm
http://www.praxiom.com/iso-31000-terms.htm
53
C H A P T E R 5
Strategic Planning
and Best Practices
for Information
Governance
Securing a sponsor at the executive management level is
always crucial to projectsand programs, and this is especially

true of any strategic planning effort. An gexecutive must be on
board and supporting the effort in order to garner the re-
sources needed to develop and execute the strategic plan, and
that executive must be
held accountable for the development and execution of the plan.
These axioms apply
to the development of an information governance (IG) strategic
plan.
Also, resources are needed—time, human capital, and budget
money. The fi rst is a
critical element: It is not possible to require managers to take
time out of their other
duties to participate in a project if there is no executive edict
and consistent follow up,
support, and communication. Executive sponsorship is a best
practice and supports the
key principle of accountability of the Generally Accepted
Recordkeeping Principles ®
(The Principles)1 (see Chapter 3 for more detail). And, of
course, without an allocated
budget, no program can proceed.
The higher your executive sponsor is in the organization, the
better. 2 The imple-

mentation of an IG program may be driven by the chief
compliance offi cer, chief
information offi cer (CIO), or, ideally, the chief executive offi
cer (CEO). With CEO
sponsorship come many of the key elements needed to complete
a successful project,
including allocated management time, budget money, and
management focus.
It is important to bear in mind that this IG effort is truly a
change management
effort, in that it aims to change the structure, guidelines, and
rules within which em-
ployees operate. The change must occur at the very core of the
organization’s culture. It
must be embedded permanently, and for it to be, the message
must be constantly and
consistently reinforced. Achieving this kind of change requires
commitment from the
very highest levels of the organization.
Executive sponsorship is critical to project success. There is
no substitute.
Without it, a project is at risk of failure.

If the CEO is not the sponsor, then another high-level executive
must lead the ef-
fort and be accountable for meeting milestones as the program
progresses. Programs
with no executive sponsor can lose momentum and focus,
especially as competing
projects and programs are evaluated and implemented. Program
failure is a great
risk without an executive sponsor. Such a program likely will
fade or fi zzle out or
be relegated to the back burner. Without strong high-level
leadership, when things
go awry, fi nger pointing and political games may take over,
impeding progress and
cooperation.
The executive sponsor must be actively involved, tracking
program objectives and
milestones on a regular, scheduled basis and ensuring they are
aligned with business
objectives. He or she must be aware of any obstacles or disputes

that arise, take an ac-
tive role in resolving them, and push the program forward.
Crucial Executive Sponsor Role
The role of an executive sponsor is high level, requiring
periodic and regular atten-
tion to the status of the program, particularly with budget
issues, staff resources, and
milestone progress. The role of a program or project manager
(PM) is more detailed
and day to day, tracking specifi c tasks that must be executed to
make progress toward
milestones. Both roles are essential. The savvy PM brings in the
executive sponsor to
push things along when more authority is needed but reserves
such project capital for
those issues that absolutely cannot be resolved without
executive intervention. It is
best for the PM to keep the executive sponsor fully informed
but to ask for assistance
only when absolutely needed.
At the same time, the PM must manage the relationship with
the executive spon-

sor, perhaps with some gentle reminders, coaxing, or prodding,
to ensure that the
role and tasks of executive sponsorship are being fulfi lled.
“[T]he successful Project
Manager knows that if those duties are not being fulfi lled, it’s
time to call a timeout
and have a serious conversation with the Executive Sponsor
about the viability of the
project.” 3
The executive sponsor serves six key purposes on a project:
1. Budget. The executive sponsor ensures an adequate fi
nancial commitment is
made to see the project through and lobbies for additional
expenditures when
change orders are made or cost overruns occur.
2. Planning and control. The executive sponsor sets direction
and tracks accom-
plishment of specifi c, measureable business objectives.
3. Decision making. The executive sponsor makes or
approves crucial decisions
and resolves issues that are escalated for resolution.

4. Expectation Management. The executive sponsor must
manage expectation,
since success is quite often a stakeholder perception.
5. Anticipation. Every project that is competing for resources
can run into un-
foreseen blockages and objections. Executive sponsors run
interference and
provide political might for the PM to lead the project to
completion, through
a series of milestones.
6. Approval. The executive sponsor signs off when all
milestones and objectives
have been met.
STRATEGIC PLANNING AND BEST PRACTICES FOR
INFORMATION GOVERNANCE 55
An eager and effective executive sponsor makes all the
difference to a project—if
the role is properly managed by the PM. It is a tricky

relationship, since the PM is
always below the executive sponsor in the organization’s
hierarchy, yet the PM must
coax the superior into tackling certain high-level tasks.
Sometimes a third-party con-
sultant who is an expert in the specifi c project can instigate and
support requests made
of the sponsor and provide a solid business rationale.
Evolving Role of the Executive Sponsor
The role of the executive sponsor necessarily evolves and
changes over the life of the
initial IG program launch, during the implementation phases,
and on through the
continued IG program.
To get the program off the ground, the executive sponsor must
make the business
case and get adequate budgetary funding. But an effort such as
this takes more than
money; it takes time— not just time to develop new policies
and implement new tech-—
nologies, but the time of the designated PM, program leaders,
and needed program

team members.
In order to get this time set aside, the IG program must be
made a top prior-
ity of the organization. It must be recognized, formalized, and
aligned with orga-
nizational objectives. All this up-front work is the
responsibility of the executive
sponsor.
Once the IG program team is formed, team members must
clearly understand
why the new program is important and how it will help the
organization meet its busi-
ness objectives. This message must be regularly reinforced by
the executive sponsor;
he or she must not only paint the vision of the future state of the
organization but
articulate the steps in the path to get there.
When the formal program effort commences, the executive
sponsor must remain
visible and accessible. He or she cannot disappear into everyday
duties and expect the
program team to carry the effort through. The executive sponsor

must be there to help
the team confront and overcome business obstacles as they arise
and must praise the
successes along the way. This requires active involvement and a
willingness to spend
the time to keep the program on track and focused.
The executive sponsor must be the lighthouse that shows the
way even through
cloudy skies and rough waters. This person is the captain who
must steer the ship, even
if the fi rst mate (PM) is seasick and the deckhands (program
team) are drenched and
tired.
After the program is implemented, the executive sponsor is
responsible for main-
taining its effectiveness and relevance. This is done through
periodic compliance au-
dits, testing and sampling, and scheduled meetings with the
ongoing PM.
While the executive sponsor role is high level, the PM’s role
and tasks are more
detailed and involve day-to-day management.

Building Your IG Team
Who should make up the IG team? Although there are no set
requirements or for-
mulas, the complex nature of IG and the fact that it touches
upon a number of spe-
cialized disciplines and functional areas dictates that a cross -
functional approach be
taken. So you will need representatives from several
departments. There are some
absolutes: you must have a representative from your legal staff
or outside counsel,
your information technology (IT) department, a senior records
offi cer (SRO) or the
equivalent, a risk management specialist or manager, an
executive sponsor, and the IG
program manager. In addition, there may be a need for input
from managers of hu-
man resources, company communications, and certain business
units. Depending on

the scope of the effort, other possible IG team members might
include an IT security
expert, the corporate or agency archivist, business analysts,
chief knowledge offi cer or
knowledge management (KM) professional, litigation support
head, fi nancial analyst,
business process specialist, project management professional,
and other professionals
in functions related to these areas.
Assigning IG Team Roles and Responsibilities
The executive sponsor will need to designate an IG PM.
Depending on the focus of
the IG effort, that person could come from several areas,
including legal, compliance,
risk management, records management, or IT.
In terms of breaking down the roles and responsibilities of the
remainder of the
IG team, the easy decision is to have IG team representatives
take responsibility for the
functional areas of their expertise. But there will be overlap,
and it is best to have some
pairs or small work groups teamed up to gain the broadest

amount of input and optimum
results. This will also facilitate cross training. For instance,
inside legal counsel may be
responsible for rendering the fi nal legal opinions, but because
they are not expert in
records, document management, or risk management, they could
benefi t from input
of others in specialized functional areas, which will inform
them and help narrow and
focus their legal research. Basic research into w hich regulations
and laws apply to the
The role of the executive sponsor changes during the
inception, planning, and
execution of the IG program.
The risk mitigation plan develops risk reduction options and
tasks to reduce
objectives.

organization regarding security, retention, and preservation of
e-mail, e-records, and
personally identifi able information (PII) could be conducted by
the SRO or records
management head, in consultation with the corporate archivist
and CIO, with the results
of their fi ndings and recommendations drafted and sent to the
legal counsel. The draft
report may offer up several alternative approaches that need
legal input and decisions.
Then the legal team lead can conduct its own, focused research
and make fi nal recom-
mendations regarding the organization’s legal strategy, business
objectives, fi nancial po-
sition, and applicable laws and regulations.
The result of the research, consultation, and collaboration of
the IG team should
result in a fi nal draft of the IG strategic plan. It will still need
more input and devel-
opment to align the plan with business objectives, an analysis of
internal and external
drivers, applicable best practices, competitive analysis,
applicable IT trends, an analysis

and inclusion of the organization’s culture, and other factors.
Align Your IG Plan with Organizational Strategic Plans
The IG plan must support the achievement of the organization’s
business objectives and there-s
fore must be melded into the organization’s overall strategic
plan. Integration with the
strategic plan means that the business objectives in the IG plan
are consistent with, and
in support of, the enterprise strategic plan.
So, for example, if the corporate strategy includes plans for
acquiring smaller com-
petitors and folding them into the organization’s structure as
operating divisions, then
the IG plan must assist and contribute to this effort. Plans for
standardizing operating
policies and procedures must include a consistent, systematized
approach to the com-
ponents of IG, including stakeholder consultation, user training
and communications,
and compliance audits. The IG plan should bring a standard
approach across the spec-
trum of information use and management within the

organization and it must be forged
to accommodate the new technology acquisitions. This means
that e-mail policies,
e-discovery policies, mobile device policies, social media
policies, cloud collaboration and
storage use, and even nitty-gritty details like report formats,
data structures, document
taxonomies, and metadata must be consistent and aligned with
the overall strategic plan. In
other words, the goal is to get all employees on the same page
and working to support the
business objectives of the strategic plan in everyday small steps
within the IG plan.
The IG team must include a cross-functional group of
stakeholders from various
departments, including legal, records management, IT, and risk
management.
The IG strategic plan must be aligned and synchronized with
the organiza-
tion’s overall strategic plans, goals, and business objectives.

The organization will also have an IT plan that must be aligned
with the strategic
plan to support overall business objectives. The IT strategy may
be to convert new
acquisitions to the internal fi nancial and accounting systems of
the organization and
to train new employees to use the existing software applications
under the umbrella of
the IG plan. Again, the IG plan needs to be integrated with the
IT strategy and must
consider the organization’s approach to IT.
The result of the process of aligning the IG effort with the IT
strategy and the
organization’s overall strategic plan will mean, ideally, that
employee efforts are more
effi cient and productive since they are consistently moving
toward the achievement of the
organization’s overall strategic goals. The organization will be
healthier and will have less
dissent and confusion with clear IG policies that leverage the IT
strategy and help
employees pursue overall business objectives.

Further considerations must be folded into the IG plan. As every
corporate cul-
ture is different and has a real impact on decision-making and
operational approaches,
corporate culture must be included in the plan. Corporate
culture includes the organi-
zation’s appetite for risk, its use of IT (e.g., forward-thinking fi
rst adopter), its capital
investment strategies, and other management actions.
So, if the organization is conservative and risk averse, it may
want to hold off
on implementing some emerging e-discovery technologies that
can cut costs but
also induce greater risk. Or if it is an aggressive, progressive,
risk-taking organi-
zation, it may opt to test and adopt newer e-discovery
technologies under the IT
strategy and umbrella of IG policies. An example may be the
use of predictive
coding technology in early case assessment (ECA). Predictive
coding uses text
auto-classifi cation technology and neural technology with the
assistance of human

input to “learn” which e-documents might be relevant in a
particular legal matter
and which may not be. Through a series of steps of testing and
checking subsets
of the documents, humans can provide input to improve the
document sorting
and selection process. The software uses machine learning
(artifi cial intelligence
whereby the software can change and improve on a particular
task, as its decision
engine is shaped and “trained” by input ) to improve its ability
to cull through and
sort documents.
Predictive coding can reduce e-discovery costs, yet there are
risks that the ap-
proach can be challenged in court and could, in fact, affect the
case adversely. Thus,
a decision on a technology like predictive coding can involve
and include elements of
the IG plan, IT strategy, and overall organizational strategic
plan.
And there are resource issues to consider: How much
management time, or band-

width, is available to pursue the IG plan development and
execution? Is there a budget
item to allow for software acquisitions and training and
communications to support
the execution of the IG plan? Obviously, without the allocated
management time and
budget money, the IG plan cannot be executed.
Survey and Evaluate External Factors
The IG plan is now harmonized and aligned with your
organization’s strategic plan
and IT strategy, but you are not fi nished yet, because the plan
cannot survive in a
vacuum: Organizations must analyze and consider the external
business, legal, and
technological environment and fold their analysis into their
plans.
Analyze IT Trends

IG requires IT to support and monitor implementation of
polices, so it matters what is s
developing and trending in the IT space. What new technologies
are coming online?
Why are they being developed and becoming popular? How do
these changes in the
business environment that created opportunities for new
technologies to be developed
affect your organization and its ability execute its IG plan? How
can new technologies
assist? Which ones are immature and too risky? These are some
of the questions that
must be addressed in regard to the changing IT landscape.
Some changes in information and communications technology
(ICT) are rathery
obvious, such as the trends toward mobile computing, tablet and
smartphone devices,
cloud storage, and social media use. Each one of these major
trends that may affect or
assist in implementing IG needs to be considered within the
framework of the organiza-
tion’s strategic plan and IT strategy. If the corporate culture is
progressive and supportive

of remote work and telecommuting, and if the organizational
strategy aims to lower fi xed
costs by reducing the amount of offi ce space for employees and
moving to a more mobile
workforce, then trends in tablet and smartphone computing that
are relevant to your or-
ganization must be analyzed and considered. Is the organization
going to provide mobile
devices or support a bring-your-own-device (BYOD)
environment? Which equipment
will you support? Will you support iOS, Android, or both? What
is your policy going to
be on phone jacking? What is the IG policy regarding confi
dential documents on mobile
devices? Will you use encryption? If so, which software? Is
your enterprise moving to the
cloud computing model? Utilizing social media? What about
Big Data and analytics ?
Are you going to consider deploying auto-classifi cation and
predictive coding technolo-
gies? What are the trends that might affect your organization?
Many, many questions must be addressed, but the evaluation
must be narrowed
down to those technology trends that specifi cally might impact

the execution of your
IG plan and rollout of new technology.
On a more granular level, you must evaluate even supported fi
le and document
formats. It gets that detailed, when you are crafting IG policy.
For instance, PDF/A is
the standard format for archiving electronic documents. So your
plans must include
long-term digital preservation (LTDP) standards and best
practices.
Survey Business Conditions and the Economic Environment
If the economy is on a down cycle, and particularly if your
business sector has been nega-
tively affected, resources may be scarcer than in better times.
Hence, it may be more dif-
fi cult to get budget approval for necessary program expenses,
such as new technologies,
staff, training materials, communications, and so forth. This
means your IG plan may
need to be scaled back or its scope reduced. Implementing the
plan in a key division rath-
er than attempting an enterprise rollout may be the best tactic in

tough economic times.
The IG strategic plan must be informed with an assessment of
relevant tech-
nology trends.
But if things are booming and the business is growing fast,
budget money for in-
vestments in the IG program may be easier to secure, and the
goals may be expanded.
IG should be an ongoing program, but it takes time to
implement, and it takes
resources to execute, audit, and continue to refi ne. So an
executive looking for a quick
and calculable payback on the investment may want to focus on
narrower areas. For
instance, the initial focus may be entirely on the legal hold and
e-discovery process,
with business objectives that include reducing pretrial costs and
attorney fees by a cer-

tain percentage or amount. It is much easier to see concrete
results when focusing on
e-discovery, since legal costs are real, and always will be there.
The business case may
be more diffi cult to make if the IG effort is broader and
improves the ability to or-
ganize and search for information faster and to execute more
complete searches to
improve the basis for management decision making. Improved
management decision
making will improve the organization’s competitiveness long-
term, but it may be dif-
fi cult to cite specifi c examples where costs were saved or
revenues were increased as a
result of the “better decisions” that should come about through
better IG.
Analyze Relevant Legal, Regulatory, and Political Factors
In consultation with your legal team or lead, the laws and
regulations that affect your
industry should be identifi ed. Narrowing the scope of your
analysis, those that specifi -
cally could impact your governance of information should be
considered and analyzed.

What absolute requirements do they impose? Where there is
room for interpretation,
where, legally, does your organization want to position itself?
How much legal risk is
acceptable? These are the types of questions you will have to
look to your legal and
risk management professionals to make. Again, legal
requirements trump all others.
Your decision process must include considerations for the
future and anticipated fu-
ture changes. Changes in the legal and regulatory environment
happen based on the po-
litical leaders who are in place and any pending legislation. So
you must go further and
analyze the current political environment and make some
judgments based on the best
information you can gather, the organization’s culture and
appetite for risk, management
style, available resources, and other factors. Generally, a more
conservative environment
means less regulation, and this analysis must also be folded into
your IG strategic plan.
Trends and conditions in the internal and external business

environment must
be included in the IG strategic plan.
Laws and regulations relevant to your organization’s
management and distri-
bution of information in all jurisdictions must be considered and
included in
the IG strategic plan. Legal requirements trump all others.
Survey and Determine Industry Best Practices
IG is a developing hybrid discipline. In a sense, it is a superset
of records management
and a subset of governance, risk management, and compliance
(GRC), that emerged
to help manage the explosion in the amount of records,
documents, and data that must
be managed in today’s increasingly high-volume and velocity
business environment and
highly regulated compliance and litigation environment. As

such, best practices are still
being formed and added to. This process of testing, proving, and
sharing best practices
will continue for some time as the practices are expanded,
revised, and refi ned.
The most relevant study of IG best practices is one that is
conducted for your
organization and surveys your industry and what some of your
more progressive com-
petitors are doing in regard to IG. Often the best way to
accomplish such a study is by
engaging a third-party consultant, who can more easily contact,
study, and interview
your competitors in regard to their practices. Business peer
groups and trade associa-
tions also can provide some consensus as to emerging best
practices.
Twenty-fi ve IG best practices covering a number of areas in
which IG has an im-
pact or should be a major consideration are listed next.
1. IG is a key underpinning for a successful RM program.
Practicing good IG is the

essential foundation for building a legally defensible RM
program; it pro-
vides the basis for consistent, reliable methods for managing
documents and
records. Having trusted and reliable records, reports, and
databases allows
managers to make key decisions with confi dence.4 And
accessing that infor-
mation and business intelligence in a timely fashion can yield a
long-term
sustainable competitive advantage, creating more agile
enterprises.
To implement a successful IG program, enterprises must
standardize and
systematize their handling of information, in particular their
formal busi-
ness records. They must analyze and optimize how information
is accessed,
controlled, managed, shared, stored, preserved, and audited.
They must have
complete, current, and relevant policies, processes, and
technologies to man-
age and control information, including who is able to access
what information ,t

and when , to meet external legal and regulatory demands and
internal gover-
nance requirements. This, in short, is IG.
2. IG is not a project but rather an ongoing program that
provides an umbrella of rules
and policies, monitored and enforced with the support of IT to
manage and
control information output and communications. Since
technologies change
so quickly, it is necessary to have overarching technology-
agnostic policies that
can manage the various IT platforms that an organization may
use.
Compare the IG program to a workplace safety program; every
time a new
location, team member, piece of equipment, or toxic substance
is acquired
by the organization, the workplace safety program should
dictate how that is
Include a best practices review in your IG strategic plan. The
most relevant best
practices in IG are those in your industry proven by peers and

competitors.
handled. If it does not, the workplace safety
policies/procedures/training that
are part of the workplace safety program need to be updated.
Regular reviews
are conducted to ensure the program is being followed, and
adjustments are
made based on the fi ndings. The effort never ends.5
3. Using an IG framework or maturity model is helpful in
assessing and guiding IG
programs. Various models are offered, such as The Principles
from ARMA
International; the Information Governance Reference Model ,
which grew
out of the Electronic Discovery Reference Model (found at
EDRM.net); 6 or
MIKE2.0, which was developed by the consulting fi rm Bearing
Point and
released to the public domain. Another tool that is particularly

used in the
Australian market for records management projects is Designing
and Imple-
menting Recordkeeping Systems (DIRKS).
4. Defensible deletion of data debris and information that no
longer has value is critical
in the era of Big Data. You must have IG polices in place and
be able to prove
that you follow them consistently and systematically in order to
justify, to the
courts and regulators, deletion of information. With a smaller
information
footprint, organizations can more easily fi nd what they need
and derive busi-
ness value from it. 7 Data debris must be eliminated regularly
and consistently,
and to do this, processes and systems must be in place to cull
out valuable
information and discard the data debris. An IG program sets the
framework
to accomplish this.
5. IG policies must be developed before enabling technologies
are deployed to assist in

enforcement. After the policy-making effort, seek out the
proper technology
tools to assist in monitoring, auditing, and enforcement.
6. To provide comprehensive e-document security throughout a
document’s life cycle,
documents must be secured upon creation using highly
sophisticated technologies, such
as information rights management (IRM) technology. IRM acts
as a sort of “secu-
rity wrapper” that denies access without proper credentials.
Document access
and use by individuals having proper and current credentials is
also tightly
monitored IRM software controls the access, copying, editing,
forwarding,
and printing of documents using a policy engine that manages
the rights to
view and work on an e-document. Access rights are set by levels
or “roles” that
employees are responsible for within an organization.
7. A records retention schedule and legal hold notifi cation
(LHN) process are the two
primary elements of a fundamental IG program. These are the

basics. Implemen-
tation will require records inventorying, taxonomy development,
metadata
normalization and standardization, and a survey of LHN best
practices.
8. A cross-functional team is required to implement IG. Since
IG contains and
requires elements of a number of established disciplines,
representatives
from the key areas must be included in the planning and
implantation effort.
At a minimum, you will need team leaders from legal, IT,
records manage-
ment, compliance and risk management, human resources, and
executive
management. Members from corporate communications,
knowledge man-
agement, systems security, fi nance and accounting, and other
functional areas
also may be needed. Depending on the circumstances, you may
need repre-
sentatives from major business units within the organization.
9. The fi rst step in information risk planning is to consider the

applicable laws and
regulations that apply to your organization in the jurisdictions
in which it conducts
business . Federal, provincial, state, and even municipal laws
and regulationss
may apply to the retention of data, documents, and records.
Organizations
operating in multiple jurisdictions must be compliant with laws
and regula-
tions that may cross national, state, or provincial boundaries.
Legally required
privacy requirements and retention periods must be researched
for each ju-
risdiction (state, country) in which the business operates, so
that all applicable
laws are complied with.
10. Developing a risk profi le is a basic building block in
enterprise risk management,

which assists executives in understanding the risks associated
with stated business
objectives and in allocating resources within a structured
evaluation approach or
framework . There are multiple ways to create a risk profi le,
and the frequency
with which it is created, the external sources consulted, and
stakeholders who
have input will vary from organization to organization. 8 A
key tenet to bear
in mind is that simpler is better and that sophisticated tools and
techniques
should not make the process overly complex.
11. An information risk mitigation plan is a critical part of the
IG planning process. An
information risk mitigation plan helps in developing risk
mitigation options
and tasks to reduce the specifi ed risks and improve the odds of
achieving busi-
ness objectives. 9
12. Proper metrics are required to measure the conformance
and performance of your IG
program. You must have an objective way to measure how you

are doing, which
means numbers and metrics. Assigning some quantitative
measures that are
meaningful before rolling out the IG program is essential.
13. IG programs must be audited for effectiveness. Periodic
audits will tell you how
your organization is doing and where to fi ne-tune your efforts.
To keep an IG
program healthy, relevant, and effective, changes and fi ne-
tuning will always
be required.
14. An enterprise wide retention schedule is preferable
because it eliminates the possibility
that different business units will have confl icting records
retention periods. For exam-
ple, if one business unit discards a group of records after 5
years, it would not
make sense for another business unit to keep the same records
for 10 years.
Where enterprise-wide retention schedules are not possible,
smaller business
units, such as divisions or regions, should operate under a
consistent retention

schedule.
15. Senior management must set the tone and lead sponsorship
for vital records program
governance and compliance. Although e-records are easier to
protect and back-
up, most vital records today are e-records. These are an
organization’s most
essential records. Without them, an organization cannot
continue operations.
16. Business processes must be redesigned to improve and
optimize the management and
security of information and especially the most critical of
information, electronic re-
cords, before implementing enabling technologies. For
instance, using electronic
records management (ERM) software fundamentally changes the
way people
work, and greater effi ciencies can be gained with business
process redesign
(versus simply using ERM systems as electronic fi ling cabinets
to speed up
poor processes).

17. E-mail messages, both inbound and outbound, should be
archived automatically and
(preferably) in real time. This ensures that spoliation (i.e., the
loss of proven
authenticity of an e-mail) does not occur. Archiving preserves
legal validity
and forensic compliance. By policy, most messages will be
deleted in a short
timeframe. Additionally, e-mail should be indexed to facilitate
the searching
process, and all messages should be secured in a single location
(with backups).
With these measures, the authenticity and reliability of e-mail
records can be
ensured.
18. Personal archiving of e-mail messages should be disallowed.
Although users will
want to save certain e-mail messages for their own reasons,
control and man-

agement of e-mail archiving must be at the organization level or
as high of a
level as is practical, such as division or region.
19. Destructive retention of e-mail helps to reduce storage costs
and legal risk while im-
proving “fi ndability” of critical records. It makes good
business sense to have a
policy to, say, destroy all e-mail messages after 90 or 120 days
that are not
fl agged as potential records (which, e.g., help document a
transaction or a situ-
ation that may come into dispute in the future) or those that
have a legal hold.
20. Take a practical approach and limit cloud use to documents
that do not have long
retention periods and carry a low litigation risk. Doing this will
reduce the risk
of compromising or losing critical documents and e-records.
Some duplicate
copies of vital records may be stored securely in the cloud to
help the organi-
zation recover in the event of a disaster.

21. Manage social media content by IG policies and monitor it
with controls that ensure
protection of critical information assets and preservation of
business records. Your
organization must state clearly what content and tone is
acceptable in social
media use, and it must retain records of that use, which should
be captured in
real time.
22. International and national standards provide effective
guidance for implementing IG.
Although there are no absolutes, researching and referencing
International
Organization for Standardization (ISO) and other standards
must be a part of
any IG effort.
23. Creating standardized metadata terms should be part of an
IG effort that enables
faster, more complete, and more accurate searches and retrieval
of records. This
is important not only in everyday business operations but also
when delv-
ing through potentially millions of records during the discovery

phase of
litigation. Good metadata management also assists in the
maintenance of
corporate memory and in improving accountability in business
operations. 10
Using a standardized format and controlled vocabulary provides
a “precise
and comprehensible description of content, location, and
value.”11 Using a
controlled vocabulary means your organization has standardized
a set of terms
used for metadata elements that describe records. This ensures
consistency
across a collection and helps with optimizing search and
retrieval functions
and records research as well as with meeting e-discovery
requests, compliance
demands, and other legal and regulatory requirements.
24. Some digital information assets must be preserved
permanently as part of an orga-
nization’s documentary heritage.12 It is critical to identify
records that must be
kept long term as early in the process as possible; ideally, these
records should

be identifi ed prior to or upon creation. LTDP applies to content
that is born
digital as well as content that is converted to digital form.
Digital preservation
is defi ned as long-term, error-free storage of digital
information, with means
for retrieval and interpretation, for the entire time span that the
information
is required to be retained. Dedicated repositories for historical
and cultural
memory, such as libraries, archives, and museums, need to
move forward
to put in place trustworthy digital repositories that can match
the secu-
rity, environmental controls, and wealth of descriptive metadata
that these
institutions have created for analog assets (such as books and
paper records).
Digital challenges associated with records management affect

all sectors of
society—academic, government, private, and not-for-profi t
enterprises—and
ultimately citizens of all developed nations.
25. Executive sponsorship is crucial. Securing an executive
sponsor at the senior
management level is key to successful IG programs. It is not
possible to
require managers to take time out of their other duties to
participate in a
project if there is no executive edict. It is a best practice across
industry sec-
tors and technology sets and supports the Accountability
principle of The
Principles.13
Formulating the IG Strategic Plan
Now comes the time to make sense of all the data and input
your IG team has
gathered and hammer it into a workable IG strategic plan. Doing
this will involve
some give-and-take among IG team members, each having their
own perspective

and priorities. Everyone will be lobbying for the view of their
functional groups. It
is the job of the executive sponsor to set the tone and to
emphasize organizational
business objectives so that the effort does not drag out or turn
into a competition but
is a well-informed consensus development process that results
in a clear, workable
IG strategic plan.
Synthesize Gathered Information and Fuse It into IG Strategy
Your IG team will have gathered a great deal of information,
which needs to be ana-
lyzed and distilled into actionable strategies. This process will
depend on the expertise
and input of the specialized knowledge your team brings to the
table within your
organizational culture. Team members must be able to make
decisions and establish
priorities that refl ect organizational business objectives and
consider a number of in-
fl uencing factors.
Do not prolong the strategy development process. The longer it

lasts, the more key factors
infl uencing it can change. You want to develop a strategic plan
that is durable enough to
withstand changes in technology, legislation, and other key infl
uencing factors, but it
should be relevant to that snapshot of information that was
collected early on. When
all the parts and pieces start changing and require
reconsideration, a dated IG plan
does not serve the organization well.
Develop IG strategies for each of the critical areas, including
the legal hold pro-
cess, e-discovery action plans, e-mail policy, mobile computing
policy, IT acquisition
strategy, confi dential document handling, vital records and
disaster planning, social
media policy, and other areas that are important to your
organization. To maintain
focus, do this fi rst without regard to the prioritization of these
areas.

Then you must go through the hard process of prioritizing your
strategies and aligning them
to your organizational goal and objectives . This may not be
diffi cult in the beginning—fors
instance, your IG strategies for legal holds and e-discovery
readiness are likely going
to take higher priority than your social media policy, and
protecting vital records is
paramount to any organization. As the process progresses, it
will become more chal-
lenging to make trade-offs and establish priorities. Then you
must tie these strategies
to overall organizational goals and business objectives.
A good technique to keep goals and objectives in mind may be
to post them prom-
inently in the meeting room where these strategy sessions take
place. This will help to
keep the IG team focused.
Develop Actionable Plans to Support Organizational
Goals and Objectives
Plans and policies to support your IG efforts must be developed

that identify specifi c
tasks and steps and defi ne roles and responsibilities for those
who will be held ac-
countable for their implementation. This is where the rubber
meets the road. But you
cannot simply create the plan and marching orders: You must
build in periodic checks
and audits to test that new IG policies are being followed and
that they have hit their
mark. Invariably, there will be adjustments made continually to
craft the policies for
maximum effectiveness and continued relevance in the face of
changes in external
factors, such as legislation and business competition, and
internal changes in manage-
ment style and structure.
Create New IG Driving Programs to Support Business
Goals and Objectives
You have to get things moving and get employees motivated,
and launching new sub-
programs within the overall IG program is a good way to start.
For instance, a new
“e-discovery readiness” initiative can show almost immediate

results if implemented
properly, with the support of key legal and records management
team members,
driven by the executive sponsor. You may want to revamp the
legal hold process
to make it more complete and verifi able, assigning specifi c
employees accountabil-
ity for specifi c tasks. Part of that effort may be evaluating and
implementing new
technology-assisted review (TAR) processes and predictive
coding technology. So
you will need to bring in the IG team members responsible for
IT and perhaps busi-
ness analysis. Working cooperatively on smaller parts of the
overall IG program is a
way to show real results within defi ned time frames. Piecing
together a series of pro-
gram components is the best way to get started, and it breaks
the overall IG program
Fuse the fi ndings of all your analyses of external and
internal factors into your
IG strategic plan. Develop strategies and then prioritize them.

down into digestible, doable chunks. A small win early on is
crucial to maintain mo-
mentum and executive sponsorship. And e-discovery has real
costs: yet progress can
be measured objectively in terms of reducing the cost of
activities such as early case
assessment (ECA). Benefi ts can be measured in terms of
reduced attorney review
hours, reduced costs, and reduced time to accomplish pretrial
tasks.
To be clear, you will need to negotiate and agree on the success
metrics the pro-
gram will be measured on in advance.
There are other examples of supporting IG subprograms, such
as e-mail manage-
ment and archiving, where storage costs, search times, and
information breaches can
be measured in objective terms. Or you may choose to roll out
new policies for the use

of mobile devices within your organization, where adherence to
policy can be mea-
sured by scanning mobile devices and monitoring their use.
Draft the IG Strategic Plan and Gain Input from a Broader
Group of Stakeholders
Once you have the pieces of the plan drafted and the IG team is
in agreement that it
has been harmonized and aligned with overall organizational
goals and objectives, you
must test the waters to see if you have hit the mark. It is a good
practice to expose a
broader group of stakeholders to the plan to gain their input.
Perhaps your IG team
has become myopic or has passed over some points that are
important to the broader
stakeholder audience. Solicit and discuss their input, and to the
degree that there is a
consensus, refi ne the IG strategic plan one last time before fi
nalizing it. But remember,
it is a living document, a work in progress, which will require
revisiting and updating
to ensure it is in step with changing external and internal
factors. Periodic auditing

and review of the plan will reveal areas that need to be adjusted
and revised to keep it
relevant and effective.
Get Buy-in and Sign-off and Execute the Plan
Take the fi nalized plan to executive management, preferably
including the CEO, and
present the plan and its intended benefi ts to them. Field their
questions and address
any concerns to gain their buy-in and the appropriate signatures.
You may have to
make some minor adjustments if there are signifi cant
objections, but, if you have ex-
ecuted the stakeholder consultation process properly, you
should be very close to the
mark. Then begin the process of implementing your IG strategic
plan, including regu-
lar status meetings and updates, steady communication and
reassurance of your execu-
tive sponsor, and planned audits of activities.
Create supporting subprograms to jump-start your IG
program effort. Smaller
programs should be able to measure real results based on

metrics that are
agreed on in advance.
■ Engaged and vested executive sponsors are necessary for IG
program success.
It is not possible to require managers to take time out of their
other duties to
participate in a project if there is no executive edict or allocated
budget.
■ The executive sponsor must be: (1) directly tied to the
success of the pro-
gram, (2) fully engaged in and aware of the program, and (3)
actively elimi-
nating barriers and resolving issues.
■ The role of the executive sponsor evolves over the life of
the IG program and
IG program effort. Initially, the focus is on garnering the

necessary resources,
but as the program commences, the emphasis is more on
supporting the
IG program team and clearing obstacles. Once the program is
implement-
ed, the responsibilities shift to maintaining the effectiveness of
the program
through testing and audits.
■ While the executive sponsor role is high level, the project
manager’s role and
tasks involve more detailed and day-to-day management.
■ The risk mitigation plan develops risk reduction options and
tasks to reduce
objectives.
■ The IG team must include a cross-functional group of
stakeholders from various
departments, including legal, records management, IT, and risk
management.
■ The IG strategic plan must be aligned and synchronized
with the organiza-

tion’s overall strategic plans, goals, and business objectives.
■ The IG strategic plan must include an assessment of
relevant technology trends.
■ Trends and conditions in the internal and external business
environment
must be included in the IG strategic plan.
■ Laws and regulations relevant to your organization’s
management and distri-
bution of information in all jurisdictions must be considered and
included in
the IG strategic plan. Legal requirements trump all others.
■ Include a best practices review in your IG strategic plan.
The most relevant best
practices in IG are those in your industry proven by peers and
competitors.
(Twenty-fi ve IG best practices are listed in this chapter for the
fi rst time in print.)
■ Fuse the fi ndings of all your analysis of external and
internal factors into your
IG strategic plan. Develop strategies and then prioritize them.

■ Creating supporting subprograms to jump-start your IG
program effort.
Smaller programs should be able to measure real results based
on metrics
that are agreed on in advance.
■ Make sure to get executive sign-off on your IG strategic
plan before moving
to execute it.
Notes
1. ARMA International, “How to Cite GARP,”
www.arma.org/garp/copyright.cfm (accessed October 9,
2013).
2. Roger Kastner, “Why Projects Succeed—Executive
Sponsorship,” February 15, 2011, http://blog
.slalom.com/2011/02/15/why-projects-succeed-%E2%80%93-

executive-sponsorship/
3. Ibid.
4. Economist Intelligence Unit, “The Future of Information
Governance,” www.emc.com/leadership
/business-view/future-information-governance.htm (accessed
October 9, 2013).
6. EDRM, “Information Governance Reference Model
(IGRM) Guide,” www.edrm.net/resources
/guides/igrm (accessed November 30, 2012).
7. Randolph A. Kahn,
https://twitter.com/InfoParkingLot/status/273791612172259329,
Nov. 28, 2012.
8. John Fraser and Betty Simkins, eds., Enterprise Risk
Management: Today’s Leading Research and Best Prac-
tices for Tomorrow’s Executives (Hoboken, NJ: John Wiley &
Sons, 2010), p. 171. s
Management Body of Knowledge (PMBOK Guide ),
4th ed. (Newtown Square, PA Project Management Institute,

2008), ANSI/PMI 99–001–2008,
pp. 273–312.
10. Kate Cumming, “Metadata Matters,” in Julie McLeod and
Catherine Hare, eds., Managing Electronic
Records , p. 34 (London: Facet, 2005).s
11. Minnesota State Archives, Electronic Records
Management Guidelines, “Metadata,” March 12, 2012,
www.mnhs.org/preserve/records/electronicrecords/ermetadata.ht
ml .
12. Charles Dollar and Lori Ashley, e-mail to author, August
10, 2012.
13. ARMA International, “How to Cite GARP.”
http://www.arma.org/garp/copyright.cfm
http://blog.slalom.com/2011/02/15/why-projects-succeed-
%E2%80%93-executive-sponsorship/
http://www.edrm.net/resources/guides/igrm
https://twitter.com/InfoParkingLot/status/273791612172259329
http://www.mnhs.org/preserve/records/electronicrecords/ermeta
data.html

http://blog.slalom.com/2011/02/15/why-projects-succeed-
%E2%80%93-executive-sponsorship/
71
Information
Governance Policy
Development
C H A P T E R 6
To develop an information governance (IG) policy, you must
inform and frame the policy with internal and external
frameworks, models, best practices, and standards—those that
apply to your organization and the scope of its planned IG
program. In this chapter, we fi rst present and discuss major IG
frameworks and models
and then identify key standards for consideration.

A Brief Review of Generally Accepted Recordkeeping
Principles®
In Chapter 3 we introduced and discussed ARMA
International’s eight Generally
Accepted Recordkeeping Principles ® , known as The Principles
1 (or sometimes GAR
Principles). These Principles and associated metrics provide an
IG framework that can
support continuous improvement.
To review, the eight Principles are:
1. Accountability
2. Transparency
3. Integrity
4. Protection
5. Compliance
6. Availability
7. Retention
8. Disposition2
The Principles establish benchmarks for how organizations of
all types and sizes
can build and sustain compliant, legally defensible records

management (RM)t
programs. Using the maturity model (also presented in Chapter
3 ), organizations can
assess where they are in terms of IG, identify gaps, and take
steps to improve across the
eight areas The Principles cover.
IG Reference Model
In late 2012, with the support and collaboration of ARMA
International and the Com-
pliance, Governance and Oversight Council (CGOC), the
Electronic Discovery Ref-
erence Model (EDRM) Project released version 3.0 of its
Reference Model (IGRM), which added information privacy
and security “as pri-y
mary functions and stakeholders in the effective governance of
information.” 3 The
model is depicted in Figure 6.1 .

The IGRM is aimed at fostering IG adoption by facilitating
communication and
collaboration between disparate (but overlapping) IG
stakeholder functions, includ-
ing information technology (IT), legal, RM, risk management,
and business unit
Figure 6.1 Information Governance Reference Model
Source: EDRM.net
Linking duty + value to information asset = efficient, effective
management
Duty:
Legal obligation
for specific
information
Value:
Utility or business
purpose of specific
information

Asset:
Specific container
of information
VALUE
Create, Use
DUTY ASSET
Dispose
Hold,
Discover
Store,
Secure
Retain
Archive
UN
IFIED G
OVERNANCE

BUSINESS
Profit
IT
Efficiency
LEGAL
Risk
RIM
Risk
PRIVACY
AND
SECURITY
Risk
PROCESS TRAN
SP
AR
EN

C
Y
POL
ICY INTEGRATION
Information Governance Reference Model / © 2012 / v3.0 /
edrm.net
INFORMATION GOVERNANCE POLICY DEVELOPMENT 73
stakeholders. 4 It also aims to provide a common, practical
framework for IG that will
foster adoption of IG in the face of new Big Data challenges
and increased legal and
regulatory demands. It is a clear snapshot of where IG touches
and shows critical in-
terrelationships and unifi ed governance.5 It can help
organizations forge policy in an
orchestrated way and embed critical elements of IG policy
across functional groups.

Ultimately, implementation of IG helps organizations leverage
information value, re-
duce risk, and address legal demands.
The growing CGOC community (2,000+ members and rising)
has widely adopted
the IGRM and developed a process maturity model that
accompanies and leverages
IGRM v3.0. 6
Interpreting the IGRM Diagram *
Outer Ring
Starting from the outside of the diagram, successful
information management is about
conceiving a complex set of interoperable processes and
implementing the procedures
and structural elements to put them into practice. It requires:
■ An understanding of the business imperatives of the
enterprise,
■ Knowledge of the appropriate tools and infrastructure for
managing informa-
tion, and

■ Sensitivity to the legal and regulatory obligations with
which the enterprise
must comply.
For any piece of information you hope to manage, the primary
stakeholder is the business
user of that information [emphasis added]. We use the term
“business” broadly; the same
ideas apply to end users of information in organizations whose
ultimate goal might not
be to generate a profi t.
Once the business value is established, you must also
understand the legal duty at-
tached to a piece of information. The term “legal” should also
be read broadly to refer
to a wide range of legal and regulatory constraints and
obligations, from e-discovery
and government regulation to contractual obligations such as
payment card industry
requirements.
Finally, IT organizations must manage the information
accordingly, ensuring pri-

vacy and security as well as appropriate retention as dictated by
both business and legal
or regulatory requirements.
* This section is adapted with permission by EDRM.net,
http://www.edrm.net/resources/guides/igrm (accessed
January 24, 2014).
You must inform and frame IG policy with internal and
external frameworks,
models, best practices, and standards.
Center
In the center of the diagram is a work-fl ow or life-cycle
diagram. We include this com-
ponent in the diagram to illustrate the fact that information
management is important
at all stages of the information life cycle—from its creation
through its ultimate disposition.

This part of the diagram, once further developed, along with
other secondary-level
diagrams, will outline concrete, actionable steps that
organizations can take in imple-
menting information management programs.
Even the most primitive business creates information in the
course of daily operations,
and IT departments spring up to manage the logistics; indeed,
one of the biggest challeng-
es in modern organizations is trying to stop individuals from
excess storing and securing
of information. Legal stakeholders can usually mandate the
preservation of what is most
critical, though often at great cost. However, it takes the
coordinated effort of all three
groups to defensibly dispose of a piece of information that has
outlived its usefulness and
retain what is useful in a way that enables accessibility and
usability for the business user. s
How the IGRM Complements the Generally Accepted
Recordkeeping Principles *
The IGRM supports ARMA International’s “Principles” by

identifying the cross-
functional groups of key information governance stakeholders
and by depicting
their intersecting objectives for the organization. This
illustration of the relation-
ship among duty, value, and the information asset demonstrates
cooperation among
stakeholder groups to achieve the desired level of maturity of
effective information
governance.
Effective IG requires a continuous and comprehensive focus.
The IGRM will be
used by proactive organizations as an introspective lens to
facilitate visualization and
discussion about how best to apply The Principles. The IGRM
puts into sharp focus
The Principles and provides essential context for the maturity
model.
* This section is adapted with permission by EDRM.net,
http://www.edrm.net/resources/guides/igrm (accessed
January 24, 2014).
The business user is the primary stakeholder of managed

information.
Information management is important at all stages of the life
cycle.
Legal stakeholders can usually mandate the preservation of
what is most criti-
cal, though often at great cost.
Best Practices Considerations
IG best practices should also be considered in policy
formulation . Best practices in IG are evolv-
ing and expanding, and those that apply to organizational
scenarios may vary. A best
practices review should be conducted, customized for each
particular organization.
In Chapter 5 , we provided a list of 25 IG best practices, with
some detail. The IG

world is maturing, and more best practices will evolve. The 25
best practices, summa-
rized next, are fairly generic and widely applicable.
1. IG is a key underpinning for a successful ERM program.
2. IG is not a project but rather an ongoing program.
3. Using an IG framework or maturity model is helpful in
assessing and guiding
IG programs.
4. Defensible deletion of data debris and information that no
longer has value is
critical in the era of Big Data.
5. IG policies must be developed before enabling
technologies are added to as-
sist in enforcement.
6. To provide comprehensive e-document security throughout
a document’s life
cycle, documents must be secured upon creation using highly
sophisticated
technologies, such as information rights management (IRM)
technology.

7. A records retention schedule and legal hold notifi cation
process (LHN) are
the two primary elements of a fundamental IG program.
8. A cross-functional team is required to implement IG.
9. The fi rst step in information risk planning is to consider
the applicable laws
and regulations that apply to your organization in the
jurisdictions in which it
conducts business.
10. A risk profi le is a basic building block in enterprise risk
management, assisting
executives in understanding the risks associated with stated
business objec-
tives and in allocating resources within a structured evaluation
approach or
framework.
11. An information risk mitigation plan is a critical part of
the IG planning
process. An information risk mitigation plan involves
developing risk mitiga-

tion options and tasks to reduce the specifi ed risks and improve
the odds of
achieving business objectives. 7
12. Proper metrics are required to measure the conformance
and performance of
your IG program.
13. IG programs must be audited for effectiveness.
14. An enterprise-wide retention schedule is preferable
because it eliminates the
possibility that different business units will have different
records retention
periods.
The IGRM was developed by the EDRM Project to foster
communication
among stakeholders and adoption of IG. It complements
ARMA’s Generally
Accepted Recordkeeping Principles.

15. Senior management must set the tone and lead sponsorship
for vital records
program governance and compliance.
16. Business processes must be redesigned to improve the
management of electron-
ic records or implement an electronic records management
(ERM) system. t
17. E-mail messages, both inbound and outbound, should be
archived automati-
cally and (preferably) in real time.
18. Personal archiving of e-mail messages should be
disallowed.
19. Destructive retention of e-mail helps to reduce storage
costs and legal risk
while improving “fi ndability” of critical records.
20. Take a practical approach and limit cloud use to documents
that do not have
long retention periods and carry a low litigation risk.
21. Manage social media content by IG policies and monitor it

with controls that en-
sure protection of critical information assets and preservation of
business records.
22. International and national standards provide effective
guidance for imple-
menting IG.
23. Creating standardized metadata terms should be part of an
IG effort that
enables faster, more complete, and more accurate searches and
retrieval of
records. 8
24. Some digital information assets must be preserved
permanently as part of an
organization’s documentary heritage.
25. Executive sponsorship is crucial.
Standards Considerations
Standards must also be considered in policy development. There
are two general types

of standards: de jure and de facto. De jure (“the law”)
standards are those published by
recognized standards-setting bodies, such as the International
Organization for Stan-
dardization (ISO), American National Standards Institute
(ANSI), National Institute
of Standards and Technology (NIST—this is how most people
refer to it, as they do
not know what the acronym stands for), British Standards
Institute (BSI), Standards
Council of Canada, and Standards Australia. Standards
promulgated by authorities
such as these have the formal status of standards.
De facto (“the fact”) standards are not formal standards but are
regarded by
many as if they were. They may arise though popular use (e.g.,
Windows at the busi-
ness desktop in the 2001–2010 decade) or may be published by
other bodies, such as
the U.S. National Archives and Records Administration (NARA)
or Department of
Defense (DoD) for the U.S. military sector. They may also be
published by formal
standards-setting bodies without having the formal status of a

“standard” (such as
some technical reports published by ISO). 9
Benefi ts and Risks of Standards
Some benefi ts of developing and promoting standards are:
■ Quality assurance support. If a product meets a standard,
you can be confi dent of
a certain level of quality.
■ Interoperability support. Some standards are detailed and
mature enough to allow
for system interoperability between different vendor platforms.
■ Implementation frameworks and certifi cation checklists.
These help to provide
guides for projects and programs to ensure all necessary steps
are taken.
■ Cost reduction , due to supporting uniformity of systems.

Users have lower main-
tenance requirements and training and support costs when
systems are more
uniform.
■ International consensus. Standards can represent “best
practice” recommenda-
tions based on global experiences. 10
Some downside considerations are:
■ Possible decreased fl exibility in development or
implementation. Standards can, at
times, act as a constraint when they are tied to older
technologies or methods,
which can reduce innovation.
■ “Standards confusion” from competing and overlapping
standards. For instance, ”
an ISO standard may be theory-based and use different
terminology, whereas
regional or national standards are more specifi c, applicable,
and understandable
than broad international ones.

■ Real-world shortcomings due to theoretical basis. Standards
often are guides based
on theory rather than practice.
■ Changing and updating requires cost and maintenance. There
are costs to develop-
ing, maintaining, and publishing standards. 11
Key Standards Relevant to IG Efforts
Below we introduce and discuss some established standards that
should be researched
and considered as a foundation for developing IG policy.
Risk Management
ISO 31000:2009 is a broad, industry-agnostic (not specifi c to
vertical markets) risk
management standard. It states “principles and generic
guidelines” of risk manage-
ment that can be applied to not only IG but also to a wide range
of organizational ac-
tivities and processes throughout the life of an organization.12
It provides a structured
framework within which to develop and implement risk

management strategies and
programs.
ISO 31000 defi nes a risk management framework as a set of
two basic compo-k
nents that “support and sustain risk management throughout an
organization.” 13 The
stated components are: foundations, which are high level and
include risk management
policy, objectives, and executive edicts; and organizational
arrangements, which are
more specifi c and actionable, including strategic plans, roles
and responsibilities, al-
located budget, and business processes that are directed toward
managing an organiza-
tion’s risk.
Additional risk management standards may be relevant to your
organization’s IG
policy development efforts, depending on your focus, scope,
corporate culture, and
demands of your IG program executive sponsor.

Information Security and Governance
ISO/IEC 27001:2005 is an information security management
system (ISMS) stan-
dard that provides guidance in the development of security
controls to safeguard
information assets. Like ISO 31000, the standard is applicable
to all types of organiza-
tions, irrespective of vertical industry. 14 It “specifi es the
requirements for establishing,
implementing, operating, monitoring, reviewing, maintaining
and improving a docu-
mented information security management system within the
context of the organiza-
tion’s overall business risks.”
ISO/IEC 27001 is fl exible enough to be applied to a variety of
activities and pro-
cesses when evaluating and managing information security
risks, requirements, and
objectives, and compliance with applicable legal and regulatory
requirements. This
includes use of the standards guidance by internal and external

auditors as well as internal and
external stakeholders (including customers and potential
customers).
ISO/IEC 27002:2005, “Information Technology—Security
Techniques—Code
of Practice for Information Security,” 15
establishes guidelines and general principles for initiating,
implementing,
maintaining, and improving information security management in
an orga-
nization and is identical to the previous published standard, ISO
17799. The
objectives outlined provide general guidance on the commonly
accepted goals
of information security management. ISO/IEC 27002:2005
contains best
practices of control objectives and controls in the following
areas of informa-
tion security management:
■ security policy;
■ organization of information security;
■ asset management;

■ human resources security;
■ physical and environmental security;
■ communications and operations management;
■ access control;
■ information systems acquisition, development, and
maintenance;
■ information security incident management;
■ business continuity management; and
■ compliance.
The control objectives and controls in ISO/IEC 27002:2005 are
intended to
be implemented to meet the requirements identifi ed by a risk
assessment. ISO/
IEC 27002:2005 is intended as a common basis and practical
guideline for de-
veloping organizational security standards and effective
security management
practices, and to help build confi dence in inter-organizational
activities.
ISO 31000 is a broad risk management standard that applies
to all types of
businesses.

high-level prin-
ciples and guidance for senior executives and directors, and
those advising them, for
the effective and effi cient use of IT.16 Based primarily on AS
8015, the Australian IT
governance standard, it “applies to the governance of
management processes” that are
performed at the IT service level, but the guidance assists
executives in monitoring IT
and ethically discharging their duties with respect to legal and
regulatory compliance
of IT activities.

which were:
■ Acquire validly
standards, and em-
braces the same methods and approaches. It is certain to have a
major impact
upon the IT governance landscape. 17
Records and E-Records Management
ISO 15489–1:2001 is the international standard for RM. It
identifi es the elements
of RM and provides a framework and high-level overview of
RM core principles. RM
is defi ned as the “fi eld of management responsible for the effi
cient and systematic
control of the creation, receipt, maintenance, use and
disposition of records, including

the processes for capturing and maintaining evidence of and
information about busi-
ness activities and transactions in the form of records.”18
ISO/IEC 27001 and ISO/IEC 27002 are information security
management
systems standards that provide guidance in the development of
security
controls.
ISO 38500 is an international standard that provides high-
governance.
The second part of the standard, ISO 15489–2:2001, contains
the technical
specifi cations and a methodology for implementing the
standard, originally based
on early standards work in Australia ( Design and
Implementation of Recordkeeping

Systems—DIRKS ). Note: Although still actively used in
Australian states, the
National Archives of Australia has not recommended use of
DIRKS by Australian
national agencies since 2007 and has removed DIRKS from its
Web site.)19
The ISO 15489 standard makes little mention of electronic
records, as it is written to ad-
dress all kinds of records; nonetheless it was widely viewed as
the defi nitive framework
of what RM means.
In 2008, the International Council on Archives (ICA) formed a
multination-
al team of experts to develop “Principles and Functional
Requirements for Records in
Electronic Offi ce Environments,” commonly referred to as
ICA-Req. q 20 The project was
cosponsored by the Australasian Digital Recordkeeping
Initiative (ADRI), which was
undertaken by the Council of Australasian Archives and
Records Authorities, which “com-
prises the heads of the government archives authorities of the
Commonwealth of Australia,

New Zealand, and each of the Australian States and
Territories.” 21 The National Archives
of Australia presented a training and guidance manual to assist
in implementing the prin-
ciples at the 2012 International Congress on Archives Congress
in Brisbane, Australia.
In Module 1 of ICA-Req, principles are presented in a high-
level overview; Mod-
ule 2 contains specifi cations for electronic document and
records management sys-
tems (EDRMS) that are “globally harmonized”; and Module 3
contains a require-
ments set and “implementation advice for managing records in
business systems.”22
Module 3 recognizes that digital recordkeeping does not have to
be limited to the
EDRMS paradigm—the insight that has now been picked up by
“Modular Require-
ments for Records Systems” (MoReq2010, the European
standard released in 2011).23
Parts 1 to 3 of ISO 16175 were fully adopted in 2010–2011
based on the ICA-Req
standard. The standard may be purchased at www.ISO.org, and

additional information
on the Australian initiative may be found at www.adri.gov.au.
ISO 16175 is guidance, not a standard that can be tested and
certifi ed against. This
is the criticism by advocates of testable, certifi able standards
like U.S. DoD 5015.2 and
the European standard, MoReq2010.
In November 2011, ISO issued new standards for ERM, the fi
rst two in the ISO
30300 series, which are based on a managerial point of view
and targeted at a manage-l
ment-level audience rather than at records managers or
technical staff:
■ ISO 30300:2011 , “Information and Documentation—
Management Systems
for Records—Fundamentals and Vocabulary”
■ ISO 30301:2011 , “Information and Documentation—
Management Systems
for Records—Requirements”
ISO 15489 is the international RM standard.

The ICA-Req standard was adopted as ISO 16175. It does not
contain a testing
regime for certifi cation.
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The standards apply to “management systems for records ”
(MSR), a term that,
as of this printing, is not typically used to refer to ERM or RM
application [RMA]
software in the United States or Europe and is not commonly
found in ERM research
or literature.
The ISO 30300 series is a systematic approach to the creation
and management
of records that is “ aligned with organizational objectives and
strategies. ” [italics added] 24
“ISO 30300 MSR ‘Fundamentals and Vocabulary’ explains the

rationale behind
the creation of an MSR and the guiding principles for its
successful implementation.
and it provides the terminology that ensures that it is
compatible with other manage-
ment systems standards.
ISO 30301 MSR ‘Requirements’ specifi es the requirements
necessary to develop
a records policy. It also sets objectives and targets for an
organization to implement
systemic improvements. This is achieved through designing
records processes and
systems; estimating the appropriate allocation of resources; and
establishing bench-
marks to monitor, measure, and evaluate outcomes. These steps
help to ensure that
corrective action can be taken and continuous improvements are
built into the sys-
tem in order to support an organization in achieving its
mandate, mission, strategy,
and goals.”25
Major National and Regional ERM Standards

For great detail on national and regional standards related to
ERM, see the book l
Managing Electronic Records: Methods, Best Practices, and
Technologies (Wiley 2013) by s
Robert F. Smallwood. Below is a short summary:
United States E-Records Standard
The U.S. Department of Defense 5015.2 Design Criteria
Standard for Electronic Records
Management Software Applications , standard was established
in 1997 and is endorsed by s
the leading archival authority, the U.S. National Archives and
Records Administration
(NARA). There is a testing regime that certifi es software
vendors that is adminis-
tered by JITC. JITC “builds test case procedures, writes detailed
and summary fi nal
reports on 5015.2-certifi ed products, and performs on-site
inspection of software.” 26
The DoD standard was built for the defense sector, and logically
“refl ects its govern-
ment and archives roots.”
Since its endorsement by NARA, the standard has been the key

requirement for
ERM system vendors to meet, not only in U.S. public sector
bids, but also in the com-
mercial sector.
The 5015.2 standard has since been updated and expanded, in
2002 and 2007,
to include requirements for metadata, e-signatures and Privacy
and Freedom of
Information Act requirements, and, as previously stated, was
scheduled for update
by 2013.
The U.S. DoD 5015.2-STD has been the most infl uential
worldwide since it
was fi rst introduced in 1997. It best suits military applications.
Canadian Standards and Legal Considerations for Electronic
Records Management *
The National Standards of Canada for electronic records

management are: (1)
Electronic Records as Documentary Evidence CAN/CGSB-
72.34–2005 (“72.34”),
published in December 2005; and, (2) Microfi lm and
Electronic Images as Documen-
tary Evidence CAN/CGSB-72.11–93, fi rst published in 1979
and updated to 2000
(“72.11”).27 72.34 incorporates all that 72.11 deals with and
is therefore the more
important of the two. Because of its age, 72.11 should not be
relied upon for its
“legal” content. However, 72.11 has remained the industry
standard for “imaging”
procedures—converting original paper records to electronic
storage. The Canada
Revenue Agency has adopted these standards as applicable to
records concerning
taxation.28
72.34 deals with these topics: (1) management authorization and
accountability;
(2) documentation of procedures used to manage records; (3)
“reliability testing” of
electronic records according to existing legal rules; (4) the
procedures manual and

the chief records offi cer; (5) readiness to produce (the “prime
directive”); (6) records
recorded and stored in accordance with “the usual and ordinary
course of business”
and “system integrity,” being key phrases from the Evidence
Acts in Canada; (7) re-
tention and disposal of electronic records; (8) backup and
records system recovery;
and, (9) security and protection. From these standards
practitioners have derived
many specifi c tests for auditing, establishing, and revising
electronic records man-
agement systems. 29
The “prime directive” of these standards states: “An
organization shall always be
prepared to produce its records as evidence.”30 The duty to
establish the “prime directive”
falls upon senior management:31
5.4.3 Senior management, the organization’s own internal law -
making author-
ity, proclaims throughout the organization the integrity of the
organization’s records
system (and, therefore, the integrity of its electronic records) by

establishing and de-
claring:
a. the system’s role in the usual and ordinary course of
business;
b. the circumstances under which its records are made; and
c. its prime directive for all RMS [records management
system] purposes, i.e.,
an organization shall always be prepared to produce its records
as evidence.
This dominant principle applies to all of the organization’s
business records,
including electronic, optical, original paper source records,
microfi lm, and
other records of equivalent form and content.
* This section was contributed by Ken Chasse J.D., LL.M., a
records management attorney and consultant, and mem-
ber of the Law Society of Upper Canada (Ontario) and of the
Law Society of British Columbia, Canada.
The 5015.2 standard has been updated to include specifi
cations such as those
for e-signatures and FOI requirements.

Being the “dominant principle” of an organization’s electronic
records manage-
ment system, the duty to maintain compliance with the “prime
directive” should fall
upon its senior management.
Legal Considerations
Because an electronic record is completely dependent upon its
ERM system for every-
thing, compliance with these National Standards and their
“prime directive” should
be part of the determination of the “admissibility”
(acceptability) of evidence and
of electronic discovery in court proceedings (litigation) and in
regulatory tribunal
proceedings. 32
There are 14 legal jurisdictions in Canada: 10 provinces, 3
territories, and the
federal jurisdiction of the Government of Canada. Each has an

Evidence Act (the Civil
Code in the province of Quebec 33 ), which applies to legal
proceedings within its leg-
islative jurisdiction. For example, criminal law and patents and
copyrights are within
federal legislative jurisdiction, and most civil litigation comes
within provincial legisla-
tive jurisdiction. 34
The admissibility of records as evidence is determined under the
“business record” provi-
sions of the Evidence Acts.35 They require proof that a record
was made “in the usual and
ordinary course of business,” and of “the circumstances of the
making of the record.”
In addition, to obtain admissibility for electronic records, most
of the Evidence Acts
contain electronic record provisions, which state that an
electronic record is admis-
sible as evidence on proof of the “integrity of the electronic
record system in which the
data was recorded or stored.” 36 This is the “system integrity”
test for the admissibility
of electronic records. The word “integrity” has yet to be defi
ned by the courts. 37

However, by way of sections such as the following, the
electronic record provi-
sions of the Evidence Acts make reference to the use of
standards such as the National
Standards of Canada:
For the purpose of determining under any rule of law whether
an electronic
record is admissible, evidence may be presented in respect of
any standard,
procedure, usage or practice on how electronic records are to be
recorded or
stored, having regard to the type of business or endeavor that
used, recorded,
or stored the electronic record and the nature and purpose of the
electronic
record. 38
U.K. and European Standards
In the United Kingdom, The National Archives (TNA)
(formerly the Public Record
Offi ce, or PRO) “has published two sets of functional
requirements to promote the

development of the electronic records management software
market (1999 and 2002).”
It ran a program to evaluate products against the 2002
requirements.39 Initially these
requirements were established in collaboration with the central
government, and they
later were utilized by the public sector in general, and also in
other nations. The Na-
tional Archives 2002 requirements remain somewhat relevant,
although no additional
development has been underway for years. It is clear that the
second version of Model
Requirements for Management of Electronic Records, MoReq2,
largely supplanted
the UK standard, and subsequently the newer MoReq2010 may
further supplant the
UK standard.
MoReq2010 “unbundles” some of the core requirements in
MoReq2, and sets out
functional requirements in modules. The approach seeks to

permit the later creation
of e-records software standards in various vertical industries
such as defense, health
care, fi nancial services, and legal services.
MoReq2010 is available free—all 525 pages of it (by
comparison, the U.S. DoD
5015.2 standard is less than 120 pages long). For more
information on MoReq2010,
visit www.moreq2010.eu. The entire specifi cation may be
downloaded at: http://
moreq2010.eu/pdf/moreq2010_vol1_v1_1_en.pdf.
MoReq2010
In November 2010, the DLM Forum, a European Commission–
supported body, announced the
availability of the fi nal draft of the MoReq2010 specifi cation
for electronic records manage-
ment systems (ERMS), following extensive public consultation.
The fi nal specifi cation
was published in mid-2011. 40
The DLM Forum explains that “With the growing demand for
[electronic] re-
cords management, across a broad spectrum of commercial, not-

for-profi t, and gov-
ernment organizations, MoReq2010 provides the fi rst practical
specifi cation against
which all organizations can take control of their corporate
information. IT software
and services vendors are also able to have their products tested
and certifi ed that they
meet the MoReq2010 specifi cation.” 41
MoReq2010 supersedes its predecessor MoReq2 and has the
continued support and backing
of the European Commission.
Australian ERM and Records Management Standards
Australia has adopted all three parts of ISO 16175 as its e-
records management
standard. 42 (For more detail on this standard go to ISO.org.)
Australia has long led the introduction of highly automated
electronic document
management systems and records management standards.
Following the approval and
release of the AS 4390 standard in 1996, the international
records management com-

munity began work on the development of an International
standard. This work used
AS 4390–1996 Records Management as its starting point.
Development of Australian Records Standards
In 2002 Standards Australia published a new Australian
Standard on records manage-
ment, AS ISO 15489, based on the ISO 15489 international
records management stan-
dard. It differs only in its preface verbiage. 43 AS ISO 15489
carries through all these
main components of AS 4390, but internationalizes the concepts
and brings them up
to date. The standards thereby codify Australian best practice
but are also progressive
in their recommendations.
Additional Relevant Australian Standards
The Australian Government Recordkeeping Metadata Standard
Version 2.0 pro-
vides guidance on metadata elements and subelements for
records management. It is a
baseline tool that “describes information about records and the
context in which they
are captured and used in Australian Government agencies.” This

standard is intended
to help Australian agencies “meet business, accountability and
archival requirements
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in a systematic and consistent way by maintaining reliable,
meaningful and accessible
records.” The standard is written in two parts, the fi rst
describing its purpose and
features and the second outlining the specifi c metadata
elements and subelements.44
The Australian Government Locator Service , AGLS, is
published as AS 5044–
2010, the metadata standard to help fi nd and exchange
information online. It updates
the 2002 version, and includes changes made by the Dublin
Core Metadata Initiative
(DCMI).

Another standard, AS 5090:2003, “Work Process Analysis for
Recordkeep-
ing ,” complements AS ISO 15489 and provides guidance on
understanding business g
processes and workfl ow so that recordkeeping requirements
may be determined. 45
Long-Term Digital Preservation
Although many organizations shuffl e dealing with digital
preservation issues to the
back burner, long-term digital preservation (LTDP) is a key
area in which IG policy
should be applied. LTDP methods, best practices, and standards
should be applied to
preserve an organization’s historical and vital records ( those
without which it cannot
operate or restart operations) and to maintain its corporate or
organizational memory.
The key standards that apply to LTDP are listed next.
The offi cial standard format for preserving electronic
documents is PDF/A-1, based on
PDF 1.4 originally developed by Adobe. ISO 19005–1:2005,

“Document Manage-
ment—Electronic Document File Format for Long-Term
Preservation—Part 1: Use
of PDF 1.4 (PDF/A-1),” is the published specifi cation for using
PDF 1.4 for LTDP,
which is applicable to e-documents that may contain not only
text characters but also
graphics (either raster or vector). 46
ISO 14721:2012 , “Space Data and Information Transfer
Systems—Open Archival
Information Systems—Reference Model (OAIS),” is applicable
to LTDP. 47 ISO 14271
“specifi es a reference model for an open archival information
system (OAIS). The pur-
pose of ISO 14721 is to establish a system for archiving
information, both digitalized
and physical, with an organizational scheme composed of
people who accept the re-
sponsibility to preserve information and make it available to a
designated commu-
nity.” 48 The fragility of digital storage media combined with
ongoing and sometimes
rapid changes in computer software and hardware poses a
fundamental challenge to

ensuring access to trustworthy and reliable digital content over
time. Eventually, ev-
ery digital repository committed to long-term preservation of
digital content must
have a strategy to mitigate computer technology obsolescence.
Toward this end, the
The ISO 30300 series of e-records standards are written for a
managerial audi-
ence and encourage ERM that is aligned to organizational
objectives.
LTDP is a key area to which IG policy should be applied.
Consultative Committee for Space Data Systems developed the
OAIS reference model
to support formal standards for the long-term preservation of
space science data and
information assets. OAIS was not designed as an
implementation model.

OAIS is the lingua franca of digital preservation, as the
international digital pres-
ervation community has embraced it as the framework for viable
and technologically
sustainable digital preservation repositories. An LTDP strategy
that is OAIS compliant
offers the best means available today for preserving the digital
heritage of all organizations,
private and public. (See Chapter 17 .)
ISO TR 18492 (2005) , “ Long-Term Preservation of Electronic
Document Based
Information,” provides practical methodological guidance for
the long-term preser-
vation and retrieval of authentic electronic document-based
information, when the
retention period exceeds the expected life of the technology
(hardware and software)
used to create and maintain the information assets. ISO 18492
takes note of the role of
ISO 15489 but does not cover processes for the capture, classifi
cation, and disposition
of authentic electronic document-based information.
ISO 16363:2012 , “ Space Data and Information Transfer

Systems—Audit and
Certifi cation of Trustworthy Digital Repositories,” “defi nes a
recommended prac-
tice for assessing the trustworthiness of digital repositories. It
is applicable to the
entire range of digital repositories.”49 It is an audit and certifi
cation standard orga-
nized into three broad categories: Organization Infrastructure,
Digital Object Man-
agement, and Technical Infrastructure and Security Risk
Management. ISO 16363
represents the gold standard of audit and certifi cation for
trustworthy digital repositories.
(See Chapter 17 .)
Business Continuity Management
ISO 22301:2012, “Societal Security—Business Continuity
Management Systems—
Requirements,” spells out the requirements for creating and
implementing a stan-
dardized approach to business continuity management (BCM,
also known as di-
saster recovery [DR]), in the event an organization is hit with a
disaster or major

business interruption. 50 The guidelines can be applied to any
organization regard-
less of vertical industry or size. The specifi cation includes the
“requirements to
plan, establish, implement, operate, monitor, review, maintain
and continually im-
prove a documented management system to protect against,
reduce the likelihood
An LTDP strategy that is OAIS compliant (based on ISO
14721) offers the best
means available today for preserving the digital heritage of all
organizations.
ISO 16363 represents the gold standard of audit and certifi
cation for trustwor-
thy digital repositories.
of occurrence, prepare for, respond to, and recover from
disruptive incidents when
they arise.”

The UK business continuity standard, BS25999-2, which
heavily infl uenced the
newer ISO standard, was withdrawn when ISO 22301 was
released. 51 The business
rationale is that, with the increasing globalization of business,
ISO 22301 will allow
and support more consistency worldwide not only in business
continuity planning
and practices but also will promote common terms and help to
embed various ISO
management systems standards within organizations. U.S.-based
ANSI, Standards
Australia, Standards Singapore, and other standards bodies also
contributed to the
development of ISO 22301.
Benefi ts of ISO 22301
■ Threat identifi cation and assessment. Discover, name, and
evaluate potential seri-
ous threats to the viability of the business.
■ Threat and recovery planning. so the impact and resultant
downtime and recov-

ery from real threats that do become incidents is minimized
■ Mission-critical process protection. Identifying key
processes and taking steps to
ensure they continue to operate even during a business
interruption.
■ Stakeholder confi dence. Shows prudent management
planning and business re-
silience to internal and external stakeholders, including
employees, business
units, customers, and suppliers. 52
Making Your Best Practices and Standards Selections to Inform
Your IG Framework
You must take into account your organization’s corporate
culture, management style,
and organizational goals when determining which best practices
and standards should
receive priority in your IG framework. However, you must step
through your business
rationale in discussions with your cross-functional IG team and
fully document the
reasons for your approach. Then you must present this approach

and your draft IG
ISO 22301 spells out requirements for creating and
implementing a standard-
ized approach to business continuity management.
You must take into account your organization’s corporate
culture, manage-
ment style, and organizational goals when determining which
best practice
and standards should be selected for your IG framework.
framework to your key stakeholders and be able to defend your
determinations while
allowing for input and adjustments. Perhaps you have
overlooked some key factors
that your larger stakeholder group uncovers, and their input
should be folded into a
fi nal draft of your IG framework.
Next, you are ready to begin developing IG policies that apply

to various aspects
of information use and management, in specifi c terms. You
must detail the policies you
expect employees to follow when handling information on
various information deliv-
ery platforms (e.g., e-mail, blogs, social media, mobile
computing, cloud computing).
It is helpful at this stage to collect and review all your current
policies that apply and
to gather some examples of published IG policies, particularly
from peer organiza-
tions and competitors (where possible). Of note: You should not
just adopt another
organization’s polices and believe that you are done with policy
making. Rather, you
must enter into a deliberative process, using your IG framework
for guiding principles
and considering the views and needs of your cross-functional IG
team. Of paramount
importance is to be sure to incorporate the alignment of your
organizational goals and
business objectives when crafting policy.
With each policy area, be sure that you have considered the
input of your stake-

holders, so that they will be more willing to buy into and
comply with the new policies
and so that the policies do not run counter to their business
needs and required busi-
ness processes. Otherwise, stakeholders will skirt, avoid, or
halfheartedly follow the
new IG policies, and the IG program risks failure.
Once you have fi nalized your policies, be sure to obtain
necessary approvals from
your executive sponsor and key senior managers.
Roles and Responsibilities
Policies will do nothing without people to advocate, support,
and enforce them. So
clear lines of authority and accountability must be drawn , and
responsibilities must be
assigned.
Overall IG program responsibility resides at the executive
sponsor level, but
beneath that, an IG program manager should drive team
members toward mile-
stones and business objectives and should shoulder the

responsibility for day-to-day
program activities, including implementing and monitoring key
IG policy tasks.
These tasks should be approved by executive stakeholders and
assigned as appropri-
ate to an employee’s functional area of expertise. For instance,
the IG team member
from legal may be assigned the responsibility for researching
and determining legal
requirements for retention of business records, perhaps working
in conjunction
with the IG team member from RM, who can provide additional
input based on
interviews with representatives from business units and
additional RM research
into best practices.
Lines of authority, accountability, and responsibility must be
clearly drawn for
the IG program to succeed.

Program Communications and Training
Your IG program must contain a communications and training
component, as a stan-
dard function. Your stakeholder audience must be made aware
of the new policies and
practices that are to be followed and how this new approach
contributes toward the
organization’s goals and business objectives.
The fi rst step in your communications plan is to identify and
segment your stake-
holder audiences and to customize or modify your message to
the degree that is neces-
sary to be effective. Communications to your IT team can have
a more technical slant,
and communications to your legal team can have some legal
jargon and emphasize le-
gal issues. The more forethought you put into crafting your
communications strategy,
the more effective it will be.
That is not to say that all messages must have several
versions: Some core concepts l
and goals should be emphasized in communications to all

employees.
How should you communicate? The more ways you can get
your IG message
to your core stakeholder audiences, the more effective and
lasting the message will
be. So posters, newsletters, e-mail, text messages, internal blog
or intranet posts,
and company meetings should all be a part of the
communications mix. Remember,
the IG program requires not only training but re training, and
the aim should be
to create a compliance culture that is so prominent and expected
that employees
adopt the new practices and policies and integrate them into
their daily activities.
Ideally, employees will provide valuable input to help fi ne-tune
and improve the
IG program.
Training should take multiple avenues as well. Some can be
classroom instruc-
tion, some online learning, and you may want to create a series
of training videos.
But the training effort must be consistent and ongoing to

maintain high levels of IG
effectiveness. Certainly, this means you will need to add to your
new hire training pro-
gram for employees joining or transferring to your organization.
Program Controls, Monitoring, Auditing, and Enforcement
How do you know how well you are doing? You will need to
develop metrics to de-
termine the level of employee compliance, its impact on key
operational areas, and
progress made toward established business objectives.
Testing and auditing the program provides an opportunity to
give feedback to
employees on how well they are doing and to recommend
changes they may make.
But having objective feedback on key metrics also will allow
for your executive
sponsor to see where progress has been made and where
improvements need to
focus.
Communications regarding your IG program should be
consistent and clear

and somewhat customized for various stakeholder groups.
■ You must inform and frame IG policy with internal and
external frameworks,
models, best practices, and standards
■ The business user is the primary stakeholder of managed
information.
■ Information management is important at all stages of the
life cycle.
■ Legal stakeholders usually can mandate the preservation of
what is most criti-
cal, though often at great cost.
■ The IGRM was developed by the EDRM Project to foster
communication
among stakeholders and adoption of IG. It complements

ARMA’s The
Principles.
■ ISO 31000 is a broad risk management standard that applies
to all types of
businesses.
■ ISO/IEC 27001 and ISO/IEC 27002 are ISMS standards that
provide guidance
in the development of security controls.
■ ISO 15489 is the international RM standard.
■ The ICA-Req standard was adopted as ISO 16175. It does
not contain a test-
ing regime for certifi cation.
■ The ISO 30300 series of e-records standards are written for
a managerial au-
dience and encourage ERM that is aligned to organizational
objectives.
■ DoD 5015.2 is the U.S. ERM standard; the European ERM
standard is
MoReq2010. Australia has adopted all three parts of ISO 16175

as its
e-records management standard.
■ LTDP is a key area to which IG policy should be applied.
■ An LTDP strategy that is OAIS compliant (based on ISO
14721) offers the best
means available today for preserving the digital heritage of all
organizations.
■ ISO 16363 represents the gold standard of audit and certifi
cation for trust-
worthy digital repositories.
governance.
■ ISO 22301 spells out requirements for creating and
implementing a
standardized approach to business continuity management.
Clear penalties for policy violations must be communicated to
employees so they

know the seriousness of the IG program and how important it is
in helping the orga-
nization pursue its business goals and accomplish stated
business objectives.
Notes
1. ARMA International, “Generally Accepted Recordkeeping
Principles,” www.arma.org/r2/generally-
accepted-br-recordkeeping-principles/copyright (accessed
November 25, 2013).
2. ARMA International, “Information Governance Maturity
Model,” www.arma.org/r2/generally-
accepted-br-recordkeeping-principles/metrics (accessed
November 25, 2013).
3. Electronic Discovery, “IGRM v3.0 Update: Privacy &
Security Offi cers As Stakeholders – Electronic
Discovery,” http://electronicdiscovery.info/igrm-v3-0-update-
privacy-security-offi cers-as-stakehold-

ers-electronic-discovery/ (accessed April 24, 2013).
4. EDRM, “Information Governance Reference Model
(IGRM),” www.edrm.net/projects/igrm (accessed
October 9, 2013).
5. Ibid.
6. Ibid.
Management Body of Knowledge (PMBOK Guide ),
4th ed. (Newtown Square, PA, Project Management Institute,
2008), ANSI/PMI 99-001-2008,
pp. 273–312.
8. Kate Cumming, “Metadata Matters,” in Julie McLeod and
Catherine Hare, eds., Managing Electronic
Records , p. 34 (London: Facet, 2005).s
9. Marc Fresko, e-mail to author, May 13, 2012.
10. Hofman, “The Use of Standards and Models,” in Julie
McLeod and Catherine Hare, eds., Managing
Electronic Records , p. 34 (London: Facet, 2005) pp. 20–21. s
11. Ibid.

12. International Organization for Standardization, “ISO
31000:2009 Risk Management—Principles and
Guidelines,”
www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?
csnumber=43170 (accessed
April 22, 2013).
13. Ibid.
14. International Organization for Standardization, ISO/IEC
27001:2005, “Information Technology—
Security Techniques—Information Security Management
Systems—Requirements,” www.iso.org/iso/
catalogue_detail?csnumber=42103 (accessed April 22, 2013).
27002:2005, “Information Technology—
Security Techniques—Code of Practice for Information Security
Management,” www.iso.org/iso/cata-
logue_detail?csnumber=50297 (accessed July 23, 2012).
38500:2008, www.iso.org/iso/catalogue_
detail?csnumber=51639 (accessed March 12, 2013).

17. ISO 38500 IT Governance Standard, www.38500.org/
18. International Organization for Standardization, ISO
15489-1: 2001 Information and Documentation—
Records Management. Part 1: General (Geneva: ISO, 2001),
section 3.16. l
■ You must take into account your organization’s corporate
culture, manage-
ment style, and organizational goals when determining which
best practices
and standards should be selected for your IG framework.
■ Lines of authority, accountability, and responsibility must
be clearly drawn for
the IG program to succeed.
■ Communications regarding your IG program should be
consistent and clear
and somewhat customized for various stakeholder groups.
■ IG program audits are an opportunity to improve training
and compliance,

not to punish employees.
CHAPTER SUMMARY: KEY POINTS (Continued )
principles/metrics
principles/metrics
principles/metrics
http://electronicdiscovery.info/igrm-v3-0-update-privacy-
security-officers-as-stakeholders-electronic-discovery/
http://www.edrm.net/projects/igrm
http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail
.htm?csnumber=43170
http://www.iso.org/iso/cata-logue_detail?csnumber=50297

http://electronicdiscovery.info/igrm-v3-0-update-privacy-
security-officers-as-stakeholders-electronic-discovery/
19. National Archives of Australia, www.naa.gov.au/records-
management/publications/DIRKS-manual
.aspx (accessed October 15, 2012).
20. International Council on Archives, “ICA-Req: Principles
and Functional Requirements for Records
in Electronic Offi ce Environments: Guidelines and Trai ning
Material,” November 29, 2011, www
.ica.org/11696/activities-and-projects/icareq-principles-and-
functional-requirements-for-records-in-
electronic-offi ce-environments-guidelines-and-training-
material.html.
21. Council of Australasian Archives and Records Authorities,
www.caara.org.au/ (accessed May 3, 2012).

22. Adrian Cunningham, blog post comment, May 11, 2011.
http://thinkingrecords.co.uk/2011/05/06/
how-moreq-2010-differs-from-previous-electronic-records-
management-erm-system-specifi cations/.
23. Ibid.
24. “Relationship between the ISO 30300 Series of Standards
and Other Products of ISO/TC 46/SC
11: Records Processes and Controls,” White Paper, ISO
TC46/SC11- Archives/Records Management
(March 2012), www.iso30300.es/wp-
content/uploads/2012/03/ISOTC46SC11_White_paper_rela-
tionship_30300_technical_standards12032012v6.pdf
25. Ibid.
26. Julie Gable, Information Management Journal, November
1, 2002, www.thefreelibrary.com/Everything-
+you+wanted+to+know+about+DoD+5015.2:+the+standard+is+
not+a…-a095630076.
27. These standards were developed by the CGSB (Canadian
General Standards Board), which is a stan-
dards-writing agency within Public Works and Government

Services Canada (a department of the
federal government). It is accredited by the Standards Council
of Canada as a standards development
agency. The Council must certify that standards have been
developed by the required procedures be-
fore it will designate them as being National Standards of
Canada. 72.34 incorporates by reference as
“normative references”: (1) many of the standards of the
International Organization for Standardiza-
tion (ISO) in Geneva, Switzerland. (“ISO,” derived from the
Greek word isos (equal) so as to provide s
a common acronym for all languages); and (2) several of the
standards of the Canadian Standards
Association (CSA). The “Normative references” section of
72.34 (p. 2) states that these “referenced
documents are indispensable for the application of this
document.” 72.11 cites (p. 2, “Applicable Pub-
lications”) several standards of the American National
Standards Institute/Association for Information
and Image Management (ANSI/AIIM) as publications
“applicable to this standard.” The process by
which the National Standards of Canada are created and
maintained is described within the standards
themselves (reverse side of the front cover), and on the CGSB’s
Web site (see, “Standards Develop-

ment”), from which Web site these standards may be obtained;
http://www.ongc-cgsb.gc.ca.
28. The Canada Revenue Agency (CRA) informs the public of
its policies and procedures by means, among
others, of its Information Circulars (IC’s), and s GST/HST
Memoranda . (GST: goods and services tax; HST:
harmonized sales tax, i.e. , the harmonization of federal and
provincial sales taxes into one retail sales tax.)
In particular, see: IC05-1 , dated June 2010, entitled,
Electronic Record Keeping , paragraphs 24, 26 and 28.g
Note that use of the National Standard cited in paragraph 26,
Microfi lm and Electronic Images as Documen-
tary Evidence CAN/CGSB-72.11-93 is mandatory for, “Imaging
and microfi lm (including microfi che)
reproductions of books of original entry and source documents .
. .” Paragraph 24 recommends the use
of the newer national standard, Electronic Records as
Documentary Evidence CAN/CGSB-72.34-2005, “To
ensure the reliability, integrity and authenticity of electronic
records.” However, if this newer standard is
given the same treatment by CRA as the older standard, it will
be made mandatory as well. And similar
statements appear in the GST Memoranda, Computerized
Records 500-1-2, s Books and Records 500-1. IC05-s

1. Electronic Record Keeping , concludes with the note, “Most
Canada Revenue Agency publications areg
available on the CRA Web site www.cra.gc.ca under the
heading ‘Forms and Publications.’”
29. There are more than 200 specifi c compliance tests that can
be applied to determine if the principles
of 72.34 are being complied with. The analysts—a combined
team of records management and legal
expertise—analyze: (1) the nature of the business involved; (2)
the uses and value of its records for its
various functions; (3) the likelihood and risk of the various
types of its records being the subject of legal
proceedings, or of their being challenged by some regulating
authority; and (4) the consequences of the
unavailability of acceptable records—for example, the
consequences of its records not being accepted
in legal proceedings. Similarly, in regard to the older National
Standard of Canada, 72.11, there is a
comparable series of more than 50 tests that can be applied to
determine the state of compliance with
its principles.
30. Electronic Records as Documentary Evidence
CAN/CGSB-72.34-2005 (“72.34”), clause 5.4.3 c) at p. 17;

and Microfi lm and Electronic Images as Documentary
Evidence CAN/CGSB-72.11-93 (“72.11”), paragraph
4.1.2 at p. 2, supra note 49.
31. 72.34, Clause 5.4.3, ibid.
32. “Admissibility” refers to the procedure by which a
presiding judge determines if a record or other
proffered evidence is acceptable as evidence according the rules
of evidence. “Electronic discovery”
management/publications/DIRKS-manual.aspx
http://www.caara.org.au/
http://thinkingrecords.co.uk/2011/05/06/how-moreq-2010-
differs-from-previous-electronic-records-management-erm-
system-specifications/
http://www.iso30300.es/wp-

http://www.thefreelibrary.com/Everything-
not+a%E2%80%A6-a095630076
http://www.thefreelibrary.com/Everything-
not+a%E2%80%A6-a095630076
http://www.ongc-cgsb.gc.ca
http://www.cra.gc.ca
management/publications/DIRKS-manual.aspx
http://thinkingrecords.co.uk/2011/05/06/how-moreq-2010-
differs-from-previous-electronic-records-management-erm-
system-specifications/
http://www.ica.org/11696/activities-and-projects/icareq-
principles-and-functional-requirements-for-records-in-
electronic-office-environments-guidelines-and-training-
material.html
material.html

material.html
is the compulsory exchange of relevant records by the parties to
legal proceedings prior to trial.” As
to the admissibility of records as evidence see: Ken Chasse,
“The Admissibility of Electronic Business
Records” (2010), 8 Canadian Journal of Law and Technology
105; and Ken Chasse, “Electronic Re-
cords for Evidence and Disclosure and Discovery” (2011) 57
The Criminal Law Quarterly 284. For the
electronic discovery of records see: Ken Chasse, “Electronic
Discovery— Sedona Canada is Inadequate
on Records Management—Here’s Sedona Canada in Amended
Form,” Canadian Journal of Law and Tech-
nology 9 (2011): 135; and Ken Chasse, “Electronic Discovery
in the Criminal Court System,” Canadian
Criminal Law Review 14 (2010): 111. See also note 18 infra ,
and accompanying text.
33. For the province of Quebec, comparable provisions are
contained in Articles 2831-2842, 2859-2862,
2869-2874 of Book 7 “Evidence” of the Civil Code of Quebec,

S.Q. 1991, c. C-64, to be read in con-
junction with, An Act to Establish a Legal Framework for
Information Technology, R.S.Q. 2001,
c. C-1.1, ss. 2, 5-8, and 68.
34. For the legislative jurisdiction of the federal and provincial
governments in Canada, see The Constitu-
tion Act, 1867 (U.K.) 30 & 31 Victoria, c. 3, s. 91 (federal), and
s. 92 (provincial), www.canlii.org/en/ca/
laws/stat/30—31-vict-c-3/latest/30—31-vict-c-3.html.
35. The two provinces of Alberta and Newfoundland and
Labrador do not have business record provisions
in their Evidence Acts. Therefore “admissibility” would be
determined in those jurisdictions by way of
the court decisions that defi ne the applicable common law
rules; such decisions as, Ares v. Venner [1970]r
S.C.R. 608, 14 D.L.R. (3d) 4 (S.C.C.), and decisions that have
applied it.
36. See for example, the Canada Evidence Act, R.S.C. 1985, c.
C-5, ss. 31.1-31.8; Alberta Evidence Act,
R.S.A. 2000, c. A-18, ss. 41.1-41.8; (Ontario) Evidence Act,
R.S.O. 1990, c. E.23, s. 34.1; and the (Nova
Scotia) Evidence Act, R.S.N.S. 1989, c. 154, ss. 23A-23G. The

Evidence Acts of the two provinces
of British Columbia and Newfoundland and Labrador do not
contain electronic record provisions.
However, because an electronic record is no better than the
quality of the record system in which it is
recorded or stored, its “integrity” (reliability, credibility) will
have to be determined under the other
provincial laws that determine the admissibility of records as
evidence.
37. The electronic record provisions have been in the Evidence
Acts in Canada since 2000. They have been
applied to admit electronic records into evidence, but they have
not yet received any detailed analysis
by the courts.
38. This is the wording used in, for example, s. 41.6 of the
Alberta Evidence Act, s. 34.1(8) of the (Ontario)
Evidence Act; and s. 23F of the (Nova Scotia) Evidence Act,
supra note 10. Section 31.5 of the Canada
Evidence Act, supra note 58, uses the same wording, the only
signifi cant difference being that the word
“document” is used instead of “record.” For the province of
Quebec, see sections 12 and 68 of, An Act
to Establish a Legal Framework for Information Technology,

R.S.Q., chapter C-1.1.
39. “Giving Value: Funding Priorities for UK Archives 2005–
2010, a key new report launched by the Na-
tional Council on Archives (NCA) in November 2005,”
www.nationalarchives.gov.uk/documents/stan-
dards_guidance.pdf (accessed October 15, 2012).
40. DLM Forum Foundation, MoReq2010 ® : Modular
Requirements for Records Systems—Volume 1: Core Ser-
vices & Plug-in Modules, 2011, http://moreq2010.eu/ (accessed
May 7, 2012, published in paper form ass
ISBN 978-92-79-18519-9 by the Publications Offi ce of the
European Communities, Luxembourg.
41. DLM Forum, Information Governance across Europe,
www.dlmforum.eu/ (accessed December 14,
2010).
42. National Archives of Australia, “Australian and
International Standards,” 2012, www.naa.gov.au
/records-management/strategic-
information/standards/ASISOstandards.aspx (accessed July 16,
2012).

43. E-mail to author from Marc Fresko, May 13, 2012.
44. National Archives of Australia, “Australian Government
Recordkeeping Metadata Standard,” 2012,
www.naa.gov.au/records-management/publications/agrk-
metadata-standard.aspx (accessed July 16,
2012).
45. National Archives of Australia, “Australian and
International Standards,” 2012, www.naa.gov.au
/records-management/strategic-
information/standards/ASISOstandards.aspx (accessed July 16,
2012).
46. International Organization for Standardization, ISO 19005-
1:2005, “Document Management—
Electronic Document File Format for Long-Term Preservation—
Part 1: Use of PDF 1.4 (PDF/A-1),”
www.iso.org/iso/catalogue_detail?csnumber=38920 (accessed
July 23, 2012).
14721:2012, “Space Data and Information Trans-
fer Systems Open Archival Information System—Reference
Model,” www.iso.org/iso/iso_catalogue/

catalogue_ics/catalogue_detail_ics.htm?csnumber=57284
(accessed November 25, 2013).
48. Ibid.
16363:2012, “Space Data and Information
Transfer Systems—Audit and Certifi cation of Trustworthy
Digital Repositories,” www.iso.org/iso/
iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=565
10 (accessed July 23, 2012).
http://www.canlii.org/en/ca/laws/stat/30%E2%80%9431-vict-c-
3/latest/30%E2%80%9431-vict-c-3.html
http://www.nationalarchives.gov.uk/documents/stan-
dards_guidance.pdf
dards_guidance.pdf
dards_guidance.pdf
http://moreq2010.eu/
http://www.dlmforum.eu/
http://www.naa.gov.au/records-management/strategic-
information/standards/ASISOstandards.aspx
http://www.naa.gov.au/records-management/publications/agrk-

metadata-standard.aspx
http://www.iso.org/iso/iso_catalogue/catalogue_ics/catalogue _d
etail_ics.htm?csnumber=57284
http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_de
tail.htm?csnumber=56510
http://www.canlii.org/en/ca/laws/stat/30%E2%80%9431-vict-c-
3/latest/30%E2%80%9431-vict-c-3.html
http://www.iso.org/iso/iso_catalogue/catalogue_ics/catalogue_d
etail_ics.htm?csnumber=57284
http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_de
tail.htm?csnumber=56510
22301:2012 “Societal Security—Business Conti-
nuity Management Systems—Requirements,”

www.iso.org/iso/catalogue_detail?csnumber=50038 (ac-
cessed April 21, 2013).
51. International Organization for Standardization, “ISO
Business Continuity Standard 22301 to Replace
BS 25999-2,”
www.continuityforum.org/content/news/165318/iso-business-
continuity-standard-22301-
replace-bs-25999-2 (accessed April 21, 2013).
52. BSI, “ISO 22301 Business Continuity Management,”
www.bsigroup.com/en-GB/iso-22301-business-
continuity (accessed April 21, 2013).
http://www.continuityforum.org/content/news/165318/iso-
business-continuity-standard-22301-replace-bs-25999-2
http://www.continuityforum.org/content/news/165318/iso-
business-continuity-standard-22301-replace-bs-25999-2
http://www.bsigroup.com/en-GB/iso-22301-business-continuity
PA RT T H R E E

Information
Governance
Key Impact
Areas Based
on the IG
Reference
Model
97
Business
Considerations for
a Successful IG
Program
C H A P T E R 7
By Barclay T. Blair
T
he business case for information governance (IG) programs has

historically
been diffi cult to justify. It is hard to apply a strict, short-term
return on invest-
ment (ROI) calculation. A lot of time, effort, and expense is
involved before true
economic benefi ts can be realized. So a commitment to the long
view and an un-
derstanding of the many areas where an organization will
improve as a result of a
successful IG program are needed. But the bottom line is that
reducing exposure to
business risk, improving the quality and security of data and e-
documents, cutting out
unneeded stored information, and streamlining information
technology (IT) develop-
ment while focusing on business results add up to better
organizational health and
viability and, ultimately, an improved bottom line.
Let us take a step back and examine the major issues affecting
information costing
and calculating the real cost of holding information, consider
Big Data and e-discov-
ery ramifi cations, and introduce some new concepts that may

help frame information
costing issues differently for business managers. Getting a good
handle on the true
cost of information is essential to governing it properly, shifting
resources to higher-
value information, and discarding information that has no
discernible business value
and carries inherent, avoidable risks.
Changing Information Environment
The information environment is changing. Data volumes are
growing, but unstructured
information (such as e-mail, word processing documents, social
media posts) is grow-
ing faster than our ability to manage it. Some unstructured
information has more
structure than others containing some identifi able metadata
(e.g., e-mail messages all
have a header, subject line, time/date stamp, and message
body). This is often termed
as semistructured information, but for purposes of this book,
we use the term “unstruc-d
tured information” to include semistructured information as
well.

The volume of unstructured information is growing
dramatically. Analysts estimate
that, over the next decade, the amount of data worldwide will
grow by 44 times (from
.8 zettabytes to 35 zettabytes: 1 zettabyte = 1 trillion
gigabytes). 1 However, the volume
of unstructured information will actually grow 50 percent
faster than structured data.
Analysts also estimate that fully 90 percent of unstructured
information will require
formal governance and management by 2020. In other words,
the problem of unstruc-
tured IG is growing faster than the problem of data volume
itself.
What makes unstructured information so challenging? There
are several factors,
including

■ Horizontal versus vertical. Unstructured information is
typically not clearly at-
tached to a department or a business function. Unlike the
vertical focus of an
enterprise resource planning (ERP) database, for example, an e-
mail system
serves multiple business functions —from employee
communication to fi ling
with regulators—for all parts of the business. Unstructured
information is
much more horizontal, making it diffi cult to develop and apply
business rules.
■ Formality. The tools and applications used to create
unstructured information
often engender informality and the sharing of opinions that can
be problematic
in litigation, investigations, and audits—as has been repeatedly
demonstrated
in front-page stories over the past decade. This problem is not
likely to get any
easier as social media technologies and mobile devices become
more common
in the enterprise.

■ Management location. Unstructured information does not
have a single, obvious
home. Although e-mail systems rely on central messaging
servers, e-mail is just
as likely to be found on a fi le share, mobile device, or laptop
hard drive. This
makes the application of management rules more diffi cult than
the application
of the same rules in structured systems, where there is a close
marriage between
the application and the database.
■ “Ownership” issues. Employees do not think that they “own”
data in an accounts
receivable system like they “own” their e-mail or documents
stored on their
hard drive. Although such information generally has a single
owner (i.e., the
organization itself), this non-ownership mind-set can make the
imposition of
management rules for unstructured information more
challenging than for
structured data.
■ Classifi cation. The business purpose of a database is

generally determined prior
to its design. Unlike structured information, the business
purpose of unstruc-
tured information is diffi cult to infer from the application that
created or stores
the information. A word processing fi le stored in a
collaboration environment
could be a multimillion-dollar contract or a lunch menu. As
such, classifi ca-
tion of unstructured content is more complex and expensive
than structured
information.
Taken together, these factors reveal a simple truth: Managing
unstructured infor-
mation is a separate and distinct discipline from managing
databases. It requires different
The problem of unstructured IG is growing faster than the
problem of data
volume itself.
BUSINESS CONSIDERATIONS FOR A SUCCESSFUL IG

PROGRAM 99
methods and tools. Moreover, determining the costs and benefi
ts of owning and man-
aging unstructured information is a unique—but critical—
challenge.
The governance of unstructured information creates enormous
complexity and
risk for business managers to consider while making it diffi cult
for organizations to
generate real value from all this information. Despite the
looming crisis, most organi-
zations have limited ability to quantify the real cost of owning
and managing unstruc-
tured information. Determining the total cost of owning
unstructured information
is an essential precursor to managing and monetizing that
information while cutting
information costs—key steps in driving profi t for the
enterprise.
Storing things is cheap . . . I’ve tended to take the attitude,
“Don’t throw elec-
tronic things away.”

—Data scientist quoted in Anne Eisenberg, “What 23 Years of
E-Mail May
Say About You,” New York Times, ” April 7, 2012
The company spent $900,000 to produce an amount of data
that would con-
sume less than one-quarter of the available capacity of an
ordinary DVD.
— Nicholas M. Pace and Laura Zakaras, “Where the Money
Goes:
Understanding Litigant Expenditures for Producing Electronic
Discovery,” RAND Institute for Civil Justice, 2012
Calculating Information Costs
We are not very good at fi guring out what information costs—
truly costs. Many orga-
nizations act as if storage is an infi nitely renewable resource
and the only cost of in-
formation. But, somehow, enterprise storage spending rises each
year and IT support
costs rise, even as the root commodity (disk drives) grows ever

cheaper and denser.
Obviously, they are not considering labor and overhead costs
incurred with managing
information, and the additional knowledge worker time wasted
sifting through moun-
tains of information to fi nd what they need.
Some of this myopic focus on disk storage cost is simple
ignorance. The executive
who concludes that a terabyte costs less than a nice meal at a
restaurant after browsing
storage drives on the shelves of a favorite big-box retailer on
the weekend is of little
help.
Rising information storage costs cannot be dismissed. Each
year the billions that or-
ganizations worldwide spend on storage grows, even though the
cost of a hard drive
is less than 1 percent of what it was about a decade ago. We
have treated storage as a
resource that has no cost to the organization outside of the
initial capital outlay and
basic operational costs. This is shortsighted and outdated.

Some of the reason that managers and executives have diffi
culty comprehending
the true cost of information is old-fashioned miscommunication.
IT departments do
not see (or pay for) the full cost of e-discovery and litigation.
Even when IT “part-
ners” with litigators, what IT learn rarely drives strategic IT
decisions. Conversely,
law departments (and outside fi rms) rarely own and pay for the
IT consequences of
their litigation strategies. It is as if when the litigation fi re
needs to be put out, nobody
calculates the cost of gasoline and water for the fi re trucks.
But calculating the cost of information—especially information
that does not sit
neatly in the rows and columns of enterprise database “systems
of record”—is complex.
It is more art than science. And it is more politics than art.
There is no Aristotelian
Golden Mean for information.

The true cost of mismanagi ng information is much more
profound than simply
calculating storage unit costs. It is the cost of opportunity
lost—the lost benefi t of in-
formation that is disorganized, created and then forgotten, cast
aside and left to rot.
It is the cost of information that cannot be brought to market.
Organizations that realize
this, and invest in managing and leveraging their unstructured
information, will be the
winners of the next decade.
Most organizations own vast pools of information that is
effectively “dark”: They
do not know what it is, where it is, who is responsible for
managing it, or whether it
is an asset or a liability. It is not classifi ed, indexed, or
managed according to the or-
ganization’s own policies. It sits in shared drives, mobile
devices, abandoned content
systems, single-purpose cloud repositories, legacy systems, and
outdated archives.
And when the light is fi nally fl icked on for the fi rst time by

an intensive hunt for
information during e-discovery, this dark information can turn
out to be a liability. An
e-mail message about “paying off fat people who are a little
afraid of some silly lung
problem” might seem innocent—until it is placed in front of a
jury as evidence that a
drug company did not care that its diet drug was allegedly
killing people. 2
The importance of understanding the total cost of owning
unstructured informa-
tion is growing. We are at the beginning of a “seismic economic
shift” in the informa-
tion landscape, one that promises to not only “reinvent society,”
(according to an MIT
data scientist) but also to create “the new oil . . . a new asset
class touching all aspects
of society.” 3
Big Data Opportunities and Challenges
We are entering the epoch of Big Data—an era of Internet-scale
enterprise infrastruc-
ture, powerful analytical tools, and massive data sets from

which we can potentially
wring profound new insights about business, society, and
ourselves. It is an epoch that,
according to the consulting fi rm McKinsey, promises to save
the European Union
public sector billions of euros, increase retailer margins by 60
percent, and reduce U.S.
national health care spending by 8 percent, while creating
hundreds of thousands of
jobs. 4 Sounds great, right?
However, the early days of this epoch are unfolding in almost
total ignorance
of the true cost of information. In the near nirvana contemplated
by some Big Data
Smart leaders across industries will see using big data for what
it is: a manage-
ment revolution.
—Andrew McAfee and Erik Brynjolfsson, “Big Data: The
Management
Revolution,” Harvard Business Review ” (October 2012)

PROGRAM 101
proponents, all data is good, and more data is better . Yet it
would be an exaggeration to r
say that there is no awareness of potential Big Data downsides.
A recent study by the
Pew Research Center was positive overall but did note concerns
about privacy, social
control, misinformation, civil rights abuses, and the possibility
of simply being over-
whelmed by the deluge of information. 5
But the real-world burdens of managing, protecting, searching,
classifying, retain-
ing, producing, and migrating unstructured information are
foreign to many Big Data
cheerleaders. This may be because the Big Data hype cycle 6
is not yet in the “trough
of disillusionment” where the reality of corporate culture and
complex legal require-
ments sets in. But set in it will, and when it does, the demand
for intelligent analysis of
costs and benefi ts will be high.

IG professionals must be ready for these new challenges and
opportunities—ready
with new models for thinking about unstructured information.
Models that calculate
the risks of keeping too much of the wrong information as well
as the s benefi ts of clean,s
reliable, and accessible pools of the right information. Models
that drive desirable
behavior in the enterprise, and position organizations to succeed
on the “next frontier
for innovation, competition, and productivity.”7
Full Cost Accounting for Information
It is diffi cult for organizations to make educated decisions
about unstructured infor-
mation without knowing its full cost. Models like total cost of
ownership (TCO) and
ROI are designed for this purpose and have much in common
with full cost account-
ing (FCA) models. FCA seeks to create a complete picture of
costs that includes past, g
future, direct, and indirect costs rather than direct cash outlays
alone.

FCA has been used for many purposes, including the decidedly
earthbound task
of determining what it costs to take out the garbage and the
loftier task of calculating
how much the International Space Station really costs. A
closely related concept, often
called triple bottom line, has gained traction in the world of
environmental account-
ing, positing that organizations must take into account societal
and environmental
costs as well as monetary costs.
The U.S. Environmental Protection Agency promotes the use of
FCA for mu-
nicipal waste management, and several states have adopted laws
requiring its use. It
is fascinating—and no accident—that this accounting model has
been widely used to
calculate the full cost of managing an unwanted by-product of
modern life. The anal-
ogy to outdated, duplicate, and unmanaged unstructur ed
information is clear.
Applying the principles of FCA to information can increase

cost transparency
and drive better management decisions. In municipal garbage
systems where citizens
do not see a separate bill for taking out the garbage, it is more
diffi cult to get new
IG professionals must be ready with new models that
calculate the risks of stor-
ing too much of the wrong information and also the benefi ts of
clean, reliable,
accessible information.
spending on waste management approved. 8 Without visibility
into the true cost, how
can citizens—or CEOs—make informed decisions?
Responsible, innovative managers and executives should
investigate FCA models for
calculating the total cost of owning unstructured information.
Consider costs such as:

■ General and administrative costs, such as cost of IT
operations and personnel,
facilities, and technical support.
■ Productivity gains or losses related to the information. s
■ Legal and e-discovery costs associated with the information
and information systems. y
■ Indirect costs, such as the accounting, billing, clerical
support, contract manage-
ment, insurance, payroll, purchasing, and so on.
■ Up-front costs, such as the acquisition of the system,
integration and confi gura-
tion, and training. This should include the depreciation of
capital outlays.
■ Future costs, such as maintenance, migration, and
decommissioning of informa-
tion systems. Future outlays should be amortized.
Calculating the Cost of Owning Unstructured Information
Any system designed to calculate the cost or benefi t of a
business strategy is inher-

ently political. That is, it is an argument designed to convince
an t audience. Well-known
models like TCO and ROI are primarily decision tools designed
to help organizations
predict the economic consequences of a decision. While there
are certainly objective
truths about the information environment, human decision
making is a complex and
imperfect process. There are plenty of excellent guides on how
to create a standard
TCO or ROI. That is not our purpose here. Rather, we want to
inspire creative think-
ing about how to calculate the cost of owning unstructured
information and help or-
ganizations minimize the risk—and maximize the value—of
unstructured information.
Any economic model for calculating the cost of unstructured
information depends
on reliable facts. But facts can be hard to come by. A client
recently went in search of an
accurate number for the annual cost per terabyte of Tier 1
storage in her company. The
company’s storage environment was completely outsourced,
leading her to believe that

the number would be transparent and easy to fi nd. However,
after days spent poring over
the massive contract, she was no closer to the truth. Although
there was a line item for
storage costs, the true costs were buried in “complexity fees”
and other opaque terms.
Organizations need tools that help them establish facts about
their unstructured
information environment. The business case for better
management depends on these
facts. Look for tools that can help you:
■ Find unstructured information wherever it resides across the
enterprise, including s
e-mail systems, shared network drives, legacy content
management systems,
and archives.
Organizations can learn from accounting models used by
cities to calculate the
total cost of managing municipal waste and apply them to the
IG problem.

PROGRAM 103
■ Enable fast and intuitive access to basic metrics , such as
size, date of last access,s
and fi le type.
■ Provide sophisticated analysis of the nature of the content
itself to drive classifi ca-s
tion and information life cycle decisions.
■ Deliver visibility into the environment through dashboards
that are easy to fors
nonspecialists to confi gure and use.
Sources of Cost
Unstructured information is ubiquitous. It is typically not the
product of a single-pur-
pose business application. It often has no clearly defi ned
owner. It is endlessly duplicat-
ed and transmitted across the organization. Determining where
and how unstructured
information generates cost is diffi cult.

However, doing so is possible. Our research shows that at
least 10 key factors that s
drive the total cost of owning unstructured information. These
10 factors identify
where organizations typically spend money throughout the life
cycle of managing un-
structured information. These factors are listed in Figure 7.1
, along with examples of
elements that typically increase cost (“Cost Drivers,” on the
left side) and elements that
typically reduce costs (“Cost Reducers,” on the right side).
1. E-discovery: fi nding, processing, and producing
information to support law-
suits, investigations, and audits. Unstructured information is
typically the
most common target in e-discovery, and a poorly managed
information
environment can add millions of dollars in cost to large
lawsuits. Simply
reviewing a gigabyte of information for litigation can cost
$14,000 or
more. 9

2. Disposition: getting rid of information that no longer has
value because it
is duplicate, out of date, or has no value to the business. In
poorly man-
aged information environments, separating the wheat from the
chaff can
cost large organizations millions of dollars. For enterprises with
frequent
litigation, the risk of throwing away the wrong piece of
information only
increases risk and cost. Better management and smart IG tool s
drive costs
down.
3. Classifi cation and organization: keeping unstructured
information organized so
that employees can use it. It also is necessary so management
rules supporting
privacy, privilege, confi dentiality, retention, and other
requirements can be
applied.
4. Digitization and automation. Many business processes
continue to be a combi-
nation of digital, automated steps and paper-based, manual

steps. Automating
Identifying and building consensus on the sources of cost for
unstructured
information is critical to any TCO or ROI calculation. It is
critical that all stake-
holders agree on these sources, or they will not incorporate the
output of the
calculation in their strategy and planning.
and digitizing these processes requires investment but also can
drive signifi -
cant returns. For example, studies have shown that automating
accounts pay-
able “can reduce invoice processing costs by 90 percent.”10
5. Storage and network infrastructure: the cost of the devices,
networks, software,
and labor required to store unstructured information. Although
the cost of
the baseline commodity (i.e., a gigabyte of storage space)

continues to fall, for
most organizations overall volume growth and complexity
means that storage
budgets go up each year. For example, between 2000 and 2010,
organization
more than doubled the amount they spent on storage-related
software even
though the cost of raw hard drive space dropped by almost 100
times. 11
6. Information search, access, and collaboration: the cost of
hardware, software, and
services designed to ensure that information is available to
those who need
it, when they need it. This typically includes enterprise content
management
systems, enterprise search, case management, and the
infrastructure necessary
to support employee access and use of these systems.
7. Migration: the cost of moving unstructured information from
outdated sys-
tems to current systems. In poorly managed information
environments, the
cost of migration can be very high—so high that some

organizations maintain
legacy systems long after they are no longer supported by the
vendor just to
avoid (more likely, simply to defer ) the migration cost and
complexity.rr
8. Policy management and compliance: the cost of developing,
implementing,
enforcing, and maintaining IG policies on unstructured
information. Good
policies, consistently enforced, will drive down the total cost of
owning un-
structured information.
9. Discovering and structuring business processes: the cost of
identifying, improv-
ing, and systematizing or “routinizing” business processes that
are currently
ad hoc and disorganized. Typical examples include contract
management and
Cost Drivers: Examples
Outdoted, unenforced policies

Poorly defined information
ownership and governance
Open loop, reactive
e-discovery processes
Uncontrolled information
respositiories
Modernist, paper-focused
information rules
Ad hoc, unstructured
business processes
Disconnected governance
programs
Formal, communicated, and
enforced policies
Automated classification and
organization
Defensible deletion and selective

content migration
Data maps
Proactive, repeatable
e-discovery procedures
Clear corporate governance
Managed and structured
repositories
Cost Reducers: Examples
1
2
3
4
5
6

7
8
9
10
E-Discovery
Disposition
Classification and Organization
Digitization and Automation
Storage and Network Infrastructure
Information Search, Access, Collaboration
Migration
Policy Management and Compliance

Discovering and Structuring Business Processes
Knowledge Capture and Transfer
Figure 7.1 Key Factors Driving Cost
Source: Barclay T. Blair
PROGRAM 105
accounts receivable as well as revenue-related activities, such
as sales and cus-
tomer support. Moving from informal e-mail and document-
based processes
to fi xed work fl ows drives down cost.
10. Knowledge capture and transfer: the cost of capturing
critical business knowl-
edge held at the department and employee level and putting that
information
in a form that enables other employees and parts of the
organization to ben-
efi t from it. Examples include intranets and their more

contemporary cousins
such as wikis, blogs, and enterprise social media platforms.
The Path to Information Value
At its peak during World War II, the Brooklyn Navy Yard had
70,000 people coming
to work every day. The site was once America’s premier
shipbuilding facility, build-
ing the steam-powered Ohio in 1820 and the aircraft carrier
USS Independence in the
1950s. But the site fell apart after it was decommissioned in the
1960s. Today, an
“Admiral’s Row” of Second Empire–style mansions once
occupied by naval offi cers
are an extraordinary sight, with gnarled oak trees pushing
through the rotting
mansard roofs. 12
Seventy percent of managers and executives say data are
“extremely impor-
tant” for creating competitive advantage. “The key, of course, is
knowing
which data matter, who within a company needs them, and fi
nding ways to

get that data into users’ hands.”
— The Economist Intelligence Unit, “Levelling the Playing
Field: How
Companies Use Data to Create Advantage” (January 2011)
However, after decades of decay, the Navy Yard is being
reborn as the home of YY
hundreds of businesses—from major movie studios to artisanal
whisky makers—taking
advantage of abundant space and a desirable location. There
were three phases in the
yard’s rebirth:
1. Clean. Survey the site to determine what had value and
what did not. Dispose
of toxic waste and rotting buildings, and modernize the
infrastructure.
2. Build and maintain. Implement a plan to continuously
improve, upgrade, and
maintain the facility.
3. Monetize. Lease the space.

Most organizations face a similar problem. However, our Navy
Yards are the vast YY
piles of unstructured information that were created with little
thought to how and
when the pile might go away. They are records management
programs built for a dif-
ferent era—like an automobile with a metal dashboard, six
ashtrays, and no seat belts.
Our Navy Yards are information environments no longer fi t for
purpose in the Big YY
Data era, overwhelmed by volume and complexity.
We are doing a bad job at managing information. McKinsey
estimates that in some
circumstances, companies are using up to 80 percent of their
infrastructure to store
duplicate data.13 Nearly half of respondents in a survey
ViaLumina recently conducted
said that at least 50 percent of the information in their
organization is duplicate, out-

dated, or unnecessary. 14 We can do better.
1. Clean
We should put the Navy Yard’s blueprint to work, fi rst by
identifying our piles of rot-YY
ting unstructured information. Duplicate information.
Information that has not been
accessed in years. Information that no longer supports a
business process and has little
value. Information that we have no legal obligation to keep. The
economics of such
“defensible deletion” projects can be compelling simply on the
basis of recovering the
storage space and thus reallocating capital that would have
been spent on the annual storage
purchase.
2. Build and Maintain
Cleaning up the Navy Yard is only the fi rst step. We cannot
repeat the past mistakes.YY
We avoid this by building and maintaining an IG program that
establishes our infor-
mation constitution (why), laws (what), and regulations (how).

We need a corporate
governance, compliance, and audit plan that gives the program
teeth, and a technology
infrastructure that makes it real. It must be a defensible program
to ensure we comply
with the law and manage regulatory risk.
3. Monetize
IG is a means to an end, and that end is value creation. IG also
mitigates risk and drives
down cost. But extracting value is the key. Although
monetization and value creation
often are associated with structured data, new tools and
techniques create exciting new
opportunities for value creation from unstructured information.
For example, what if an organization could use sophisticated
analytics on the e-
mail account of their top salesperson (the more years of e-mail
the better), look for
markers of success, then train and hire salespeople based on that
template? What is
the pattern of a salesperson’s communications with customers
and prospects in her

territory? What is the substance of the communications? What is
the tone? When do
successful salespeople communicate? How are the patterns
different between suc-
cessful deals and failed deals? What knowledge and insight
resides in the thousands
of messages and gigabytes of content? The tools and techniques
of Big Data applied
to e-mail can bring powerful business insights. However, we
have to know what
questions to ask. According to Computerworld , “the hardest
part of using big data is
trying to get business people to sit down and defi ne what they
want out of the huge
amount of unstructured and semi-structured data that is
available to enterprises
these days.”15
Key steps in driving information value are: (1) clean; (2)
build and maintain;
and (3) monetize.

PROGRAM 107
The analytics challenges of Big Data create opportunities . For
example, McKinsey pre-
dicts that demand for “deep analytical talent in the United
States could be 50 to 60
percent greater than its projected supply by 2018.” A chief
reason for this gap is that
“this type of talent is diffi cult to produce, taking years of
training in the case of some-
one with intrinsic mathematical abilities.” However, the more
profound opportunity
is for the “1.5 million extra additional managers and analysts in
the United States
who can ask the right questions and consume the results of the
analysis of big data
effectively.” 16
Some companies are using analytics to set prices. For example,
the largest dis-
tributor of heating oil in the United States sets prices on the fl
y, based on commodity
prices and customer retention risks. 17 In a case that caught
the attention of morning
news shows, with breathless headlines like “Are Mac Users

Paying More?” an online
travel company revealed that “Mac users are 40 percent more
likely to book four or
fi ve-star hotels . . . compared to PC users.”18 Despite the
headlines, the company was
not charging Mac users more. Rather, computer brand was a
variable used to deter-
mine which products were highlighted.
The path to information value is not necessarily linear.
Different parts of your
business may achieve maturity at different rates, driven by the
unique risks and op-
portunities of the information they possess.
Challenging the Culture
The best models for calculating the total cost of owning
unstructured are those that
information professionals can use to challenge and change
organizational culture.
Much of the unstructured information that represents the
greatest cost and risk to
organizations is created, communicated, and managed directly
by employees—that is,

by human beings. As such, better IG relies in part on improving
the way those human
beings use and manage information.
New Information Models
The “information calorie” and “information cap-and-trade,”
explored next, are two
new models designed to help with the challenge of governing
information.
Table 7.1 Key Steps in the IG Process
1. Clean 2. Build and Maintain 3. Monetize
Information inventory IG policies and procedures Create value
through
information, e.g., drive sales and
improve customer satisfaction
Defensible deletion Corporate governance,
compliance and audit
Business insights

Records retention and legal hold Technology Increase margins
Source: Barclay T. Blair
Information Calorie
The Western world is suffering from an embarrassment of
riches when it comes to
calories. The calorie has been weaponized in the form of tasty,
cheap, and fast food
loaded with sugar and fat. Even a cup of “coffee” can contain as
much as 800 calories.19
We have gotten very, very good at maximizing available
calories, at a staggering cost:
$190 billion per year in additional medical spending as a result
of obesity in the United
States, greater than the cost of smoking. 20
Governments are taking action. A new national health care law
in the United
States requires restaurant chains to disclose calorie counts for

the food they sell by
2013, building on similar state laws.21 Calories are not
inherently bad. We would liter-
ally die without them. But too many calories make us sick.
The analogy to information is clear. Information is the
“lifeblood” of our organi-
zations and is central to our survival. But too much unmanaged
unstructured informa-
tion leaves us fat, slow, and coughing and wheezing at the back
of the pack.
In 2012, New York City initially passed a controversial law
limiting the size of
soft drinks that can be sold at movie theaters and convenience
stores (later chal-
lenged in court). The “Bloomberg soda ban” was based on the
premise that humans
need help making good choices. There is some basis for this
approach, with studies
showing that, for example, the size of the candy scoop
determines how much free
candy we eat.22 Under the new law, it was still possible in
New York to buy two
smaller cups of soda, but it was hoped that inconvenience (and

cost) will reduce
overconsumption.
A new study . . . examined consumer behavior before and after
calorie counts
were posted, and determined that when restaurants post calories
on menu
boards, there is a reduction in calories per transaction.
—Bryan Bollinger, Phillip Leslie, Alan Sorensen, “Calorie
Posting in Chain
Restaurants,” Stanford University, January 2010
Thinking about information as calories at your organization can
improve aware-
ness of its costs and drive change. The goal is not to add
friction to desirable behaviors,
like collaboration and mobile work, but rather to make it more
diffi cult to create and
consume empty information calories.
Here are some tips to get started:
■ Educate executives and employees about the cost of
information mismanagement s

through anecdotes, case studies, and facts.
■ Show employees their information footprint by regularly
exposing them to the t
amount of data storage they are using in e-mail, shared drives,
content man-
agement systems, and other environments they work with. With
a little creative
programming, you can post “information calories” on your
menus.
■ Design systems to minimize information calories. Examples
include: preventing
employees from exporting e-mail to .pst fi les; turning off the
ability to store
documents on desktop hard drives to encourage the use of
managed collabo-
ration environment; and requiring employees to send links to
shared content
rather than creating yet another e-mail attachment. Clever
technology and
social engineering, like the soda ban, can drive healthy
information behavior.

PROGRAM 109
Information Cap-and-Trade
Originally designed as a regulatory approach for fi ghting acid
rain in the 1980s,
cap-and-trade has gained new attention as a method of curbing
carbon emissions.
Cap-and-trade systems differ from command-and-control
regulatory approaches that
mandate, rather than economically encourage , a course of
action. In other words,
rather than forcing companies to install scrubbers on power
plant exhausts (command
and control), cap-and-trade provides companies with an
emissions quota, which they
can hit as they see fi t, and even profi t from. Companies with
unused room on their
quota can sell those “credits” on specialized markets.
Consider a cap-and-trade system for information. Do not limit
the creation and
storage of useful information—that defeats the purpose of

investing in IT in the fi rst l
place. Rather, design a cap-and-trade system that controls the
amount of information
pollution and rewards innovation and management discipline.
While there is no objective “right amount” of information for
every organization
or department, we can certainly do better than “as much as you
want, junk or not.”
After all, “nearly all sectors in the US economy had at least an
average of 200 terabytes
of stored data . . . and many sectors had more than 1 petabyte in
mean stored data per
company.” 23 Moreover, up to 50 percent of that information
is easily identifi able as
data pollution. 24 So, we have a reasonable starting point.
Here are some tips for creating an information cap-and-trade
system:
■ Baseline the desired amount of information per system,
department, and/or type t
of user. How much information do you currently have? How
much has value?
How much should you have? These are not easy questions to

answer, but even
rough calculations can make a big difference.
■ Create information volume targets or quotas, and allocate
them by business unit,
system, or user. This is the “cap” part of the system.
■ Calculate the fully loaded cost of a unit of information ,
and adopt it as a baseline
metric for the “trade” part of the system. Consider whether
annual e-discovery
costs can be allocated to this unit in a reasonable way.
■ Create an internal accounting system for tracking and
trading information units, s
or credits within the organization. Innovative departments will
be rewarded,
laggards will be motivated.
■ Get creative in what the credits can purchase. New
revenue-generating software?
Headcount?
“There’s not a person in a business anywhere who gets up
in the morning and

says, ‘Gee, I want to race into the offi ce to follow some
regulation.’ On the
other hand, if you say, ‘There’s an upside potential here, you’re
going to make
money,’ people do get up early and do drive hard around the
possibility of
fi nding themselves winners on this.”
—Dan Etsy, environmental policy professor at Yale University,
quoted
in Richard Conniff, “The Political History of Cap and Trade,”
Smithsonian Magazine (August 2009)
Future State: What Will the IG-Enabled Organization Look
Like?
When an organization is IG enabled, or “IG mature”—meaning
IG is infused into op-
erations throughout the enterprise and coordinated on an
organization-wide level—it

will look signifi cantly different from most organizations today.
Not only will the or-
ganization have a solid handle on the total cost of information;
not only will it have
shifted resources to capitalize on the opportunities of Big Data;
not only will it be
managing the deluge in a systematic, business-oriented way by
cutting out data debris
and leveraging information value; it will also look signifi cantly
different in key opera-
tional areas including legal, records and information
management (RIM), and IT.
In legal matters, the mature IG-enabled organization will be
better suited to ad-
dress litigation in a more effi cient way through a standardized
legal hold notifi cation
(LHN) process. Legal risk is reduced through improved IG,
which will manage infor-
mation privacy in accordance with applicable laws and
regulations. During litigation,
your legal team will be able to sort through information more
rapidly and effi ciently,
improving your legal posture, cutting e-discovery costs, and
allowing for attorney time

to be focused on strategy and to zero in on key issues. This
means attorneys should
have the technology tools to be more effective. Adherence to
retention schedules
means that records and documents can be discarded at the
earliest possible time, which
reduces the chances that some information could pose a legal
risk. Hard costs can be
saved by eliminating that approximately 69 percent of stored
information that no lon-
ger has business value. That cost savings may be the primary
rationale for the initial
IG program effort. By leveraging advanced technologies such as
predictive coding, the
organization can reduce the costs of e-discovery and better
utilize attorney time.
Your RIM functions will operate with more effi ciency and in
compliance with
laws and regulations. Appropriate retention periods will be
applied and enforced, and
authentic, original copies of business records will be easily
identifi able, so that manag-
ers are using current and accurate information on which to base
their decisions. Over

the long term, valuable information from projects, product
development, marketing
programs, and strategic initiatives will be retained in corporate
memory, reducing the
impact of turnover and providing distilled information and
knowledge to contribute to
a knowledge management (KM) program. KM programs can
facilitate innovation int
organizations, as a knowledge base is built, retained, expanded,
and leveraged.
In your IT operations, a focus on how IT can contribute to
business objectives will
bring about a new perspective. Using more of a business lens to
view IT projects will
help IT to contribute toward the achievement of business
objectives. IT will be work-
ing more closely with legal, RIM, risk, and other business units,
which should help
these groups to have their needs and issues better addressed by
IT solutions. Having a
standardized data governance program in place means cleaning
up corrupted or dupli-
cated data and providing users with clean, accurate data as a
basis for line-of-business

software applications and for decision support analytics in
business intelligence (BI)
applications. Better data is the basis for improved insights,
which can be gained by
leveraging BI and will improve management decision-making
capabilities and help
to provide better customer service, which can impact customer
retention. It costs a
lot more to gain a new customer than to retain an existing one,
and with better data
quality, the opportunities to cross-sell and upsell customers are
improved. This can
provide a sustainable competitive advantage. Standardizing the
use of business terms
will facilitate improved communications between IT and other
business units, which
PROGRAM 111
should lead to improved software applications that address user
needs. Adhering to
information life cycle management principles will help the

organization to apply the
proper level of IT resources to its high-value information while
decreasing costs by
managing information of declining value appropriately. IT
effectiveness and effi ciency
will be improved by using IT frameworks and standards, such as
CobiT 5 and ISO/
IEC 38500:2008, the international standard that provides high-
guidance for senior executives and directors, and those advising
them, for the effec-
tive and effi cient governance of IT. 25 Implementing a
master data management pro-
gram will help larger organizations with complex IT operations
to ensure that they are
working with consistent data from a single source. Improved
database security through
data masking, database activity monitoring, database auditing,
and other tools will help
guard the organization’s critical databases against the risk of
rogue attacks by hackers.
Deploying document life cycle security tools such as data loss
prevention and informa-
tion rights management will help secure your confi dential
information assets and keep

them from prying eyes. This helps to secure the organization’s
competitive position
and protect its valuable intellectual property.
By securing your electronic documents and data, not only
within the organization
but also for mobile use, and by monitoring and complying with
applicable privacy
laws, your confi dential information assets will be safeguarded,
your brand will be bet-
ter protected, and your employees will be able to be productive
without sacrifi cing the
security of your information assets.
Moving Forward
We are not very good at fi guring out what unstructured
information costs. The Big
Data deluge is upon us. If we hope to manage —and, more
important, to monetize—
this deluge, we must form cross-functional teams and challenge
the way our organi-
zations think about unstructured information. The fi rst and
most important step is
developing the ability to convincingly calculate what

unstructured information really
costs and then to discover ways we can recue those costs and
drive value. These are
foundational skills for information professionals in the new era
of Big Data. In this era,
information is currency—but a currency that has value only
when IG professionals
drive innovation and management rigor in the unstructured
information environment.
■ The business case for IG programs has historically been
diffi cult to justify.
■ It takes a commitment to the long view to develop a
successful IG program.
■ The problem of unstructured IG is growing faster than the
problem of data
volume itself.
■ IG professionals must be ready with new models that
calculate the risks of
storing too much of the wrong information and also the benefi ts

of clean,
reliable, accessible information.
(continued)dd
■ Key steps in driving information value are: (1) clean; (2)
build and maintain;
and (3) monetize.
■ The information calorie approach and information cap-and-
trade are two
new models for assisting in IG.
■ Legal risk is reduced through improved IG, and legal costs are
reduced.
■ Leveraging newer technologies like predictive coding can
improve the ef-
fi ciency of legal teams.
■ Adherence to retention schedules means that records and

documents can
be discarded at the earliest possible time, which reduces costs
by eliminating
unneeded information that no longer has business value.
■ RIM functions will operate with more effi ciency and in
compliance with laws
and regulations under a successful IG program.
■ A compliant RIM program helps to build the organization’s
corporate memo-
ry of essential “lessons learned,” which can foster a KM
program.
■ KM programs can facilitate innovation in organizations.
■ Focusing on business impact and customizing your IG
approach to meet
business objectives are key best practices for IG in the IT
department.
■ Effective data governance can yield bottom-line benefi ts
derived from new
insights, especially with the use of business intelligence
software.

strategy to deliver
business value.
■ Using IT frameworks like CobiT 5 can improve the ability of
senior manage-
ment to monitor IT value and processes.
■ Identifying sensitive information in your databases and
implementing data-
base security best practices help reduce organizational risk and
the cost of
compliance.
■ By securing your electronic documents and data, your
information assets will
be safeguarded and your organization can more easily comply
with privacy
laws and regulations.
■ We are not very good at fi guring out what unstructured
information costs. To
thrive in the era of Big Data requires challenging the way we
think about the

cost of managing unstructured information.
PROGRAM 113
Notes
1. International Data Corporation, “The 2011 Digital
Universe Study,” June 2011. www.emc.com/
leadership/programs/digital-universe.htm (accessed November
25, 2013).
2. Richard B. Schmidt, “The Cyber Suit: How Computers
Aided Lawyers In Diet-Pill Case,” Wall Street
Journal , October 8, 1999.
http://webreprints.djreprints.com/0000000000000000001255900
1.htmll
3. Nick Bilton, “At Davos, Discussions of a Global Data
Deluge,” New York Times , January 25, 2012,s
http://bits.blogs.nytimes.com/2012/01/25/at-davos-discussions-

of-a-global-data-deluge/; Alex Pent-
land, quoted by Edge.org in “Reinventing Society in the Wake
of Big Data,” August 8, 2012, www
.edge.org/conversation/reinventing-society-in-the-wake-of-big-
data; World Economic Forum, “Per-
sonal Data: The Emergence of a New Asset Class” (January
2011), http://www3.weforum.org/docs/
WEF_ITTC_PersonalDataNewAsset_Report_2011.pdf
4. James Manyika et al., “Big Data: The Next Frontier for
Innovation, Competitions, and Productivity,”
McKinsey Global Institute, May 2011,
www.mckinsey.com/insights/business_technology/big_data_
the_next_frontier_for_innovation
5. Janna Quitney Anderson and Lee Ranie, “Future of the
Internet: Big Data,” Pew Internet and American
Life Project, July 20, 2012,
http://pewinternet.org/~/media//Files/Reports/2012/PIP_Future_
of_
Internet_2012_Big_Data.pdf
6. Louis Columbus, “Roundup of Big Data Forecasts and
Market Estimates, 2012,” Forbes , August 16, s
2012,

www.forbes.com/sites/louiscolumbus/2012/08/16/roundup-of-
big-data-forecasts-and-market-
estimates-2012/
7. McKinsey Global Institute, “Big Data: The Next Frontier
for Innovation, Competitions, and produc-
tivity,” May 2011.
8. U.S. EPA, “Making Solid Waste Decisions with Full Cost
Accounting,” n.d., www.epa.gov/osw/
conserve/tools/fca/docs/primer.pdf (accessed November 25,
2013).
9. Nicholas M. Pace and Laura Zakaras, “Where the Money
Goes: Understanding Litigant Expenditures
for Producing Electronic Discovery,” RAND Institute for Civil
Justice, 2012. www.rand.org/content/
dam/rand/pubs/monographs/2012/RAND_MG1208.pdf (accessed
November 25, 2013).
10. Accounts Payable Network, “A Detailed Guide to
Imaging and Workfl ow ROI,” 2010.
11. Various sources. See, for example: Barclay T. Blair,
“Today’s PowerPoint Slide: The Origins of Informa-

tion Governance by the Numbers,” October 28, 2010.
http://barclaytblair.com/origins-of-information-
governance-powerpoint/ (accessed November 25, 2013).
12. Brooklyn Navy Yard Development Corporation, “The
History of Brooklyn Navy Yard,” www
.brooklynnavyyard.org/history.html (accessed November 25,
2013).
13. James Manyika et al., “Big Data.”
14. Barclay Blair and Barry Murphy, “Defi ning Information
Governance: Theory or Action? Results of the
2011 Information Governance Survey,” ViaLumina, eDiscovery
Journal (September 2011).l
15. Jaikumar Vijayan, “Finding the Business Value in Big
Data Is a Big Problem,” Computerworld , Septemberd
12, 2012,
www.computerworld.com/s/article/9231224/Finding_the_busine
ss_value_in_big_data_is_a_
big_problem
16. James Manyika et al., “Big Data.”
17. Economist Intelligence Unit, “Leveling the Playing Field:

How Companies Use Data to Create
Advantage” (January 2011), http://blogs.sap.com/wp-
content/blogs.dir/15/fi les/2012/02/EIU_
Levelling_The_Playing_Field_1.pdf
18. Genevieve Shaw Brown, “Mac Users My See Pricier
Options on Orbitz,” ABC Good Morn-
ing America , June 25, 2012,
http://abcnews.go.com/Travel/mac-users-higher-hotel-prices-
orbitz/
story?id=16650014#.UDlkVBqe7oV
19. “Health Care Bill Requires Calories on Menus at Chain
Restaurants,” USA Today , March 23, 2010,
http://usatoday30.usatoday.com/news/health/weightloss/2010-
03-23-calories-menus_N.htm
20. Sharon Beley, “As America’s Waistline Expands, Cost
Soar,” Reuters, April 30, 2012, www.reuters
.com/article/2012/04/30/us-obesity-idUSBRE83T0C820120430
21. Stephanie Rosenbloom, “Calorie Data to Be Posted at
Most Chains,” New York Times , March 23, 2010,s
www.nytimes.com/2010/03/24/business/24menu.html

22. James Surowiecki, “Downsizing Supersize,” New Yorker
, August 13, 2012, www.newyorker.com/talk/r
fi nancial/2012/08/13/120813ta_talk_surowiecki
23. Manyika et al., “Big Data.”
24. Blair and Murphy, “Defi ning Information Governance.”
38500:2008, Corporate governance of infor-
mation technology.
www.iso.org/iso/catalogue_detail?csnumber=51639 (accessed
November 25, 2013).
http://www.emc.com/leadership/programs/di gital-universe.htm
http://webreprints.djreprints.com/0000000000000000001255900
1.html
http://bits.blogs.nytimes.com/2012/01/25/at-davos-discussions-
of-a-global-data-deluge/
http://www.mckinsey.com/insights/business_technology/big_dat
a_the_next_frontier_for_innovation
of_Internet_2012_Big_Data.pdf

http://www.forbes.com/sites/louiscolumbus/2012/08/16/roundup
-of-big-data-forecasts-and-market-estimates-2012/
http://www.epa.gov/osw/conserve/tools/fca/docs/primer.pdf
http://www.rand.org/content/dam/rand/pubs/monographs/2012/R
AND_MG1208.pdf
http://barclaytblair.com/origins-of-information-governance-
powerpoint/
powerpoint/
powerpoint/
http://www.computerworld.com/s/article/9231224/Finding_the_
business_value_in_big_data_is_a_big_problem
http://blogs.sap.com/wp-
content/blogs.dir/15/files/2012/02/EIU_Levelling_The_Playing_
Field_1.pdf
orbitz/story?id=16650014#.UDlkVBqe7oV
http://usatoday30.usatoday.com/news/health/weightloss/2010-
03-23-calories-menus_N.htm
http://www.reuters.com/article/2012/04/30/us-obesity-

idUSBRE83T0C820120430
http://www.nytimes.com/2010/03/24/business/24menu.html
http://www.newyorker.com/talk/financial/2012/08/13/120813ta_
talk_surowiecki
http://www.emc.com/leadership/programs/digital-universe.htm
http://www.edge.org/conversation/reinventing-society-in-the-
wake-of-big-data
http://www.edge.org/conversation/reinventing-society-in-the-
wake-of-big-data
http://www.mckinsey.com/insights/business_technology/big_dat
a_the_next_frontier_for_innovation
of_Internet_2012_Big_Data.pdf
http://www.epa.gov/osw/conserve/tools/fca/docs/primer.pdf
http://www.rand.org/content/dam/rand/pubs/monographs/2012/R
AND_MG1208.pdf
http://www.computerworld.com/s/article/9231224/Finding_the_
business_value_in_big_data_is_a_big_problem
http://blogs.sap.com/wp-
content/blogs.dir/15/files/2012/02/EIU_Levelling_The_Playing_
Field_1.pdf

orbitz/story?id=16650014#.UDlkVBqe7oV
http://www.reuters.com/article/2012/04/30/us-obesity-
idUSBRE83T0C820120430
http://www.newyorker.com/talk/financial/2012/08/13/120813ta_
talk_surowiecki
http://www.brooklynnavyyard.org/history.html
http://www.brooklynnavyyard.org/history.html
115
By Robert Smallwood with Randy Kahn,
Esq. , and Barry Murphy
Information
Governance and Legal
Functions
C H A P T E R 8
P
erhaps the key functional area that information governance
(IG) impacts most is

legal functions, since legal requirements are paramount. Failure
to meet them can
literally put an organization out of business or land executives
in prison. Privacy,
security, records management, information technology (IT), and
business manage-
ment functions are important—very important—but the most
signifi cant aspect of all
of these functions relates to legality and regulatory compliance.
Key legal processes include electronic discovery (e-discovery)
readiness and as-
sociated business processes, information and record retention
policies, the legal hold
notifi cation (LHN) process, and legally defensible disposition
practices.
Some newer technologies have become viable to assist
organizations in imple-
menting their IG efforts, namely, predictive coding and g
technology-assisted review
(TAR; also known as computer-assisted review ). In this
chapter we explore the need ww
for leveraging IT in IG efforts aimed at defensible disposition,

the intersection be-
tween IG processes and legal functions, policy implications, and
some key enabling
technologies.
Introduction to e-Discovery: The Revised 2006 Federal Rules
of
Civil Procedure Changed Everything
Since 1938, the Federal Rules of Civil Procedure (FRCP)
“have governed the
discovery of evidence in lawsuits and other civil cases.” 1 In
law, discovery is an early y
phase of civil litigation where plaintiffs and defendants
investigate and exchange
evidence and testimony to better understand the facts of a case
and to make early
determinations of the strength of arguments on either side. Each
side must produce
evidence requested by the opposition or show the court why it is
unreasonable to pro-
duce the information.
The FRCP apply to U.S. district courts, which are the trial
courts of the fed-

eral court system. The district courts have jurisdiction (within
limits set by Congress
and the Constitution) to hear nearly all categories of federal
cases, including civil and
criminal matters. 2
The FRCP were amended in 2006, and some of the revisions
apply specifi cally to
the preservation and discovery of electronic records in the
litigation process. 3 These
changes were a long time coming, refl ecting the lag between
the state of technology
and the courts’ ability to catch up to the realities of
electronically generated and stored
information.
After years of applying traditional paper-based discovery rules
to e-discovery,
amendments to the FRCP were made to accommodate the
modern practice of discov-
ery of electronically stored information (ESI). ESI is any

information that is created
or stored in electronic format. The goal of the 2006 FRCP
amendments was to recog-
nize the importance of ESI and to respond to the increasingly
prohibitive costs of
document review and protection of privileged documents. These
amendments rein-
forced the importance of IG policies, processes, and controls in
the handling of ESI. 4
Organizations must produce requested ESI reasonably quickly,
and failure to do so, or
failure to do so within the prescribed time frame, can result in
sanctions. This require-
ment dictates that organizations put in place IG policies and
procedures to be able to
produce ESI accurately and in a timely fashion. 5
All types of litigation are covered under the FRCP, and all
types of e-documents—
most especially e-mail—are included, which can be created,
accessed, or stored in a
wide variety of methods, and on a wide variety of devices
beyond hard drives. The
FRCP apply to ESI held on all types of storage and
communications devices: thumb

drives, CDs/DVDs, smartphones, tablets, personal digital
assistants (PDAs), personal
computers, servers, zip drives, fl oppy disks, backup tapes, and
other storage media. ESI
content can include information from e-mail, reports, blogs,
social media posts (e.g.,
Twitter posts), voicemails, wikis, websites (internal and
external), word processing
documents, and spreadsheets, and includes the metadata
associated with the content
itself, which provides descriptive information. 6
Under the FRCP amendments, corporations must proactively
manage the
e-discovery process to avoid sanctions, unfavorable rulings, and
a loss of public trust.
Corporations must be prepared for early discussions on e-
discovery with all depart-
ments. Topics should include the form of production of ESI and
the methods for pres-
ervation of information. Records management and IT
departments must have made
available all relevant ESI for attorney review. 7
This new era of ESI preservation and production demands the

need for cross-
functional collaboration: records management, IT, and legal
teams particularly need to
work closely together. Legal teams, with assistance and input of
records management
staff, must identify relevant ESI, and IT teams must be mindful
of preserving and pro-
tecting the ESI to maintain its legal integrity and prove its
authenticity.
Legal functions are the most important area of IG impact.
ESI is any information that is created or stored in electronic
format.
INFORMATION GOVERNANCE AND LEGAL FUNCTIONS
117
Big Data Impact
Now throw in the Big Data effect: The average employee
creates roughly one giga-
byte of data annually (and growing), and data volumes are

expected to increase over
the next decade not 10-fold, or even 20-fold, but as much as 40
to 50 times what it
is today! 8 This underscores the fact that organizations must
meet legal requirements
while paring down the mountain of data debris they are holding
to reduce costs and
potential liabilities hidden in that monstrous amount of
information. There are also
costs associated with dark data— unknown or useless data,
such as old log fi les, that
takes up space and continues to grow and needs to be cleaned
up.
Some data is important and relevant, but distinctions must be
made by IG policy
to classify, prioritize, and schedule data for disposition and to
dispose of the majority of
it in a systematic, legally defensible way. If organizations do
not accomplish these critical
IG tasks they will be overburdened with storage and data
handling costs and will be
unable to meet legal obligations.
According to a recent survey, approximately 25 percent of

information stored in
organizations has real business value, while 5 percent must be
kept as business records
and about 1 percent is retained due to a litigation hold. 9
“This means that [about] 69 per-
cent of information in most companies has no business, legal, or
regulatory value. Companies
that are able to [identify and] dispose of this debris return more
profi t to sharehold-
ers, can use more of their IT budgets for strategic investments,
and can avoid excess
expense in legal and regulatory response” (emphasis added).
If organizations are not able to draw clear distinctions between
that roughly 30
percent of “high-value” business data, records, and that which is
on legal hold, their IT
department are tasked with the impossible job of managing all
data as if it is high value.
This “overmanaging” of information is a signifi cant waste of
IT resources. 10
More Details on the Revised FRCP Rules
Here we present a synopsis of the key points in FRCP rules that

apply to e-discovery.
FRCP 1—Scope and Purpose. This rule is simple and clear; its
aim is to “secure the
just, speedy, and inexpensive determination of every action.”11
Your discovery
effort and responses must be executed in a timely manner.
The amended FRCP reinforce the importance of IG. Only
about 25 percent of
business information has real value, and 5 percent are business
records.
The goal of the FRCP amendments is to recognize the
importance of ESI and
to respond to the increasingly prohibitive costs of document
review and pro-
tection of privileged documents.
FRCP 16—Pretrial Conferences; Scheduling; Management .
This rule provides guide-t

lines for preparing for and managing the e-discovery process;
the court expects
IT and network literacy on both sides, so that pretrial
conferences regarding
discoverable evidence are productive.
FRCP 26—Duty to Disclose; General Provisions Governing
Discovery. This rule pro-
tects litigants from costly and burdensome discovery requests,
given certain
guidelines.
FRCP 26(a)(1)(C): Requires that you make initial disclosures no
later than 14
days after the Rule 26(f) meet and confer, unless an objection or
another time
is set by stipulation or court order. If you have an objection,
now is the time
to voice it.
Rule 26(b)(2)(B): Introduced the concept of not reasonably
accessible ESI.
The concept of not reasonably accessible paper had not
existed. This rule pro-r
vides procedures for shifting the cost of accessing not

reasonably accessible
ESI to the requesting party.
FRCP 26(b)(5)(B): Gives courts a clear procedure for settling
claims
when you hand over ESI to the requesting party that you
shouldn’t have.
Rule 26(f): This is the meet and confer rule. This rule requires
all par-
ties to meet within 99 days of the lawsuit’s fi ling and at least
21 days before a
scheduled conference.
Rule 26(g): Requires an attorney to sign every e-discovery
request, re-
sponse, or objection.
FRCP 33—Interrogatories to Parties . This rule provides a defi
nition of business e-s
records that are discoverable and the right of opposing parties
to request and
access them.
FRCP 34—Producing Documents, Electronically Stored

Information, and Tangible
Things, or Entering onto Land, for Inspection and Other
Purposes . In disputes overs
document production, this rule outlines ways to resolve and
move forward.
Specifi cally, FRCP 34(b) addresses the format for requests and
requires that
e-records be accessible without undue diffi culty (i.e., the
records must be orga-
nized and identifi ed). The requesting party chooses the
preferred format, which
are usually native fi les (which also should contain metadata).
The key point is
that electronic fi les must be accessible, readable, and in a
standard format.
FRCP 37—Sanctions . Rule 37(e) is known as the safe harbor
rule. In principle, it s
keeps the court from imposing sanctions when ESI is damaged
or lost through
routine, “good faith” operations, although this has proven to be
a high standard
to meet. This rule underscores the need for a legally defensible
document man-
agement program under the umbrella of clear IG policies.

The Big Data trend underscores the need for defensible
deletion of data debris.
119
Landmark E-Discovery Case: Zubulake v. UBS Warburg
A landmark case in e-discovery arose from the opinions
rendered in Zubulake v. U.B.S.
Warburg , an employment discrimination case where the
plaintiff, Laura Zubulake, g
sought access to e-mail messages involving or naming her.
Although UBS produced
over 100 pages of evidence, it was shown that employees
intentionally deleted some
relevant e-mail messages. 12 The plaintiffs requested copies of
e-mail from backup
tapes, and the defendants refused to provide them, claiming it
would be too expensive
and burdensome to do so.

The judge ruled that U.B.S. had not taken proper care in
preserving the e-mail
evidence, and the judge ordered an adverse inference
(assumption that the evidence
was damaging) instruction against U.B.S. Ultimately, the jury
awarded Zubulake over
$29 million in total compensatory and punitive damages. “The
court looked at the
proportionality test of Rule 26(b)(2) of the Federal Rules of
Civil Procedure and
applied it to the electronic communication at issue. Any
electronic data that is as ac-
cessible as other documentation should have traditional
discovery rules applied.” 13
Although Zubulake’s award was later overturned on appeal, it is
clear the stakes are
huge in e-discovery and preservation of ESI.
E-Discovery Techniques
Current e-discovery techniques include online review, e-mail
message archive review,
and cyberforensics. Any and all other methods of seeking or
searching for ESI may be
employed in e-discovery. Expect capabilities for searching,

retrieving, and translating
ESI to improve, expanding the types of ESI that are
discoverable. Consider this
potential when evaluating and developing ESI management
practices and policies.14
E-Discovery Reference Model
The E-Discovery Reference Model is a visual planning tool
created by EDRM.net
to assist in identifying and clarifying the stages of the e-
discovery process. Figure 8.1
is the graphic depiction with accompanying detail on the
process steps.
Information Management. Getting your electronic house in
order to miti-
gate risk and expenses should e-discovery become an issue,
from initial cre-
ation of electronically stored information through its fi nal
disposition
Identifi cation. Locating potential sources of ESI and
determining their
scope, breadth, and depth

In the landmark case Zubulake v. U.B.S. Warburg , the
defendants were severelyg
punished by an adverse inference for deleting key e-mails and
not producing
copies on backup tapes.
Preservation. Ensuring that ESI is protected against
inappropriate altera-
tion or destruction
Collection. Gathering ESI for further use in the e-discovery
process (pro-
cessing, review, etc.)
Processing. Reducing the volume of ESI and converting it, if
necessary, to
forms more suitable for review and analysis
Review. Evaluating ESI for relevance and privilege
Analysis. Evaluating ESI for content and context, including key

patterns,
topics, people, and discussion
Production. Delivering ESI to others in appropriate forms, and
using ap-
propriate delivery mechanisms
SEVEN STEPS OF THE E-DISCOVERY PROCESS
In the e-discovery process, you must perform certain functions
for identifying
and preserving electronically stored (ESI), and meet
requirements regarding
conditions such as relevancy and privilege. Typically, you
follow this e-disco-
very process:
1. Create and retain ESI according to an enforceable
electronic records reten-
tion policy and electronic records management (ERM) program.
Enforce
the policy, and monitor compliance with it and the ERM
program.

2. Identify the relevant ESI, preserve any so it cannot be
altered or destroyed,
and collect all ESI for further review.
3. Process and fi lter the ESI to remove the excess and
duplicates. You reduce
costs by reducing the volume of ESI that moves to the next
stage in the
e-discovery process.
4. Review and analyze the fi ltered ESI for privilege because
privileged ESI is
not discoverable, unless some exception kicks in.
5. Produce the remaining ESI, after fi ltering out what’s
irrelevant, duplicated,
or privileged. Producing ESI in native format is common.
6. Clawback the ESI that you disclosed to the opposing party
that you should
have fi ltered out, but did not. Clawback is not unusual, but you
have to
work at getting clawback approved, and the court may deny it.
7. Present at trial if your case hasn’t settled. Judges have

little to no patience
with lawyers who appear before them not understanding e-
discovery and
the ESI of their clients or the opposing side.
Source: Linda Volonino and Ian Redpath, e -Discovery for
Dummies (Hoboken, NJ: John Wiley s
& Sons, 2010), http://www.dummies.com/how-
to/content/ediscovery-for-dummies-cheat-
sheet.html (accessed May 22, 2013). Used with permission.
http://www.dummies.com/how-to/content/ediscovery-for-
dummies-cheat-sheet.html
121
Presentation. Displaying ESI before audiences (at depositions,
hearings,
trials, etc.), especially in native and near-native forms, to elicit

further infor-
mation, validate existing facts or positions, or persuade an
audience15
The Electronic Discovery Reference Model can assist
organizations in focusing
and segmenting their efforts when planning e-discovery
initiatives.
Guidelines for E-Discovery Planning
1. Implement an IG program. The highest impact area to
focus are your legal
processes, particularly e-discovery. From risk assessment to
processes, com-
munications, training, controls, and auditing, fully implement
IG to improve
and measure compliance capabilities.
2. Inventory your ESI. File scanning and e-mail archiving
software can assist you.
You also will want to observe fi les and data fl ows by doing a
walk-through
beginning with centralized servers in the computer room and
moving out into

business areas. Then, using a prepared inventory form, you
should interview
users to fi nd out more detail. Be sure to inventory ESI based on
computer
systems or applications, and diagram it out.
3. Create and implement a comprehensive records retention
policy, and also include
an e-mail retention policy and retention schedules for major ESI
areas. This is
required since all things are potentially discoverable. You must
devise a
comprehensive retention and disposition policy that is legally
defensible.
Figure 8.1 Electronic Discovery Reference Model
Source: EDRM (edrm.net)
Information
Management
VOLUME RELEVANCE
Identification

Preservation
Processing
Review Production Presentation
Analysis
Electronic Discovery Reference Model/©2009/v2.0/edrm.net
Collection
The E-Discovery Reference Model is in a planning tool that
presents key
e-discovery process steps.
So, for instance, if your policy is to destroy all e-mail messages
that do
not have a legal hold (or are expected to) after 90 days and you
apply that

policy uniformly, you will be able to defend the practice in
court. Also,
implementing the retention policy reduces your storage burden
and costs
while cutting the risk of liability that might be buried in
obscure e-mail
messages.
4. As an extension of your retention policy, implement a legal
hold policy that is
enforceable, auditable, and legally defensible. Be sure to
include all potentially
discoverable ESI XE “litigation:e-discovery”. We discuss legal
holds in more
depth later in this chapter, but be sure to cast a wide net when
developing
retention policies so that you include all relevant electronic
records, such
as e-mail, e-documents and scanned documents, storage discs,
and backup
tapes.
5. Leverage technology. Bolster your e-discovery planning
and execution efforts
by deploying enabling technologies, such as e-mail archiving,

advanced enter-
prise search, TAR, and predictive coding.
6. Develop and execute your e-discovery plan. You may want
to begin from this point
forward with new cases, and bear in mind that starting small
and piloting is
usually the best course of action.
The Intersection of IG and E-Discovery
By Barry Murphy
Effective IG programs can alleviate e-discovery headaches by
reducing the amount
of information to process and review, allowing legal teams to
get to the facts of a case
quickly and effi ciently, and can even result in better case
outcomes. Table 8.1 shows the
impact of IG on e-discovery, by function.
Legal Hold Process
The legal hold process is a foundational element of IG.16 The
way the legal hold process

is supposed to work is that a formal system of polices,
processes, and controls is put
in place to notify key employees of a civil lawsuit (or
impending one) and the set of
documents that must put on legal hold. These documents, e-mail
messages, and other
relevant ESI must be preserved in place and no longer edited or
altered so that they
may be reviewed by attorneys during the discovery phase of the
litigation. But, in prac-
tice, this is not always what takes place. In fact, the opposite
can take place —employees
can quickly edit or even delete relevant e-documents that may
raise questions or even
Implementing IG, inventorying ESI, and leveraging
technology to implement
records retention and LHN policies are key steps in e-discovery
planning.
123

implicate them. This is possible only if proper IG controls are
not in place, monitored,
enforced, and audited.
Many organizations start with Legal Hold Notifi cation (LHN)
management as
a very discrete IG project. LHN management is arguably the
absolute minimum an orga-
nization should be doing in order to meet the guidelines
provided by court rules, com-g
mon law, and case law precedent. It is worth noting, though,
that the expectation is
that organizations should connect the notifi cation process to
the actual collection and
preservation of information in the long term.
Table 8.1 IG Impact on E-Discovery
Impact Function
Cost reduction Reduce downstream costs of processing and
review by
defensibly disposing of data according to corporate retention
policies

Reduce cost of collection by centralizing collection interface to
save time
Keep review costs down by prioritizing documents and
assigning to the right level associates (better resource
utilization)
Reduce cost of review by culling information with advanced
analytics
Risk management Reduce risk of sanctions by managing the
process of LHN
and the collection and preservation of potentially responsive
information
Better litigation win rates Optimize decision making (e.g.,
settling cases that can’t
be won) quickly with advanced analytics that prioritize hot
documents
Quickly fi nd the necessary information to win cases with
advanced searches and prioritized review
Strategic planning for matters
based on merit

Determine the merits of a matter quickly and decide if it is a
winnable case
Quickly route prioritized documents to the right reviewers via
advanced analytics (e.g., clustering)
Strategic planning for matters
based on cost
Quickly determine how much litigation will cost via early
access
to amount of potentially responsive information and prioritized
review to make decisions based on the economics of the matter
(e.g., settle for less than the cost of litigation)
Litigation budget optimization Minimize litigation budget by
only pursuing winnable cases
Minimize litigation budget by utilizing the lowest cost
resources
possible while putting high-cost resource on only the necessary
documents
Source: Barry Murphy, eDiscovery Journal

http://ediscoveryjournal.com/l
LHN management is the absolute minimum an organization
should imple-
ment to meet the guidelines, rules, and precedents.
http://ediscoveryjournal.com/
How to Kick-Start Legal Hold Notifi cation
Implementing an LHN program attacks some of the lower-
hanging fruit within an or-
ganization’s overall IG position. This part of the e-discovery
life cycle must not be outsourced. d
Retained counsel provides input, but the mechanics of LHN are
managed and owned
by internal corporate resources.
In preparing for a LHN implementation project, it is important
to fi rst lose the
perception that LHN tools are expensive and diffi cult to
deploy. It is true that some of

these tools cost considerably more than others and can be
complex to deploy; however,
that is because the tools in question go far beyond simple LHN
and reach into enter-
prise systems and also handle data mapping, collection, and
workfl ow processes. Other
options include Web-based hosted solutions, custom-developed
solutions, or process-
es using tools already in the toolbox (e.g., e-mail, spreadsheets,
word processing).
The most effective approach involves three basic steps:
1. Defi ne requirements.
2. Defi ne the ideal process.
3. Select the technology.
Defi ning both LHN requirements and processes should include
input from key
stakeholders—at a minimum—in legal, records management,
and IT. Be sure to take
into consideration the organization’s litigation profi le,
corporate culture, and available
resources as part of the requirements and process defi ning
exercise. Managing steps

1 and 2 thoroughly makes tool selection easier because defi
ning requirements and
processes creates the confi dence of knowing exactly what the
tool must accomplish.
IG and E-Discovery Readiness
Having a solid IG underpinning means that your organization
will be better prepared to
respond and execute key tasks when litigation and the e-
discovery process proceed. Your
policies will have supporting business processes, and clear lines
of responsibility and
accountability are drawn. The policies must be reviewed and fi
ne-tuned periodically, and
business processes must be streamlined and continue to aim for
improvement over time.
In order for legal hold or defensible deletion (discussed in
detail in the next
section—disposing of unneeded data, e-documents, and reports
based on set policy)
projects to deliver the promised benefi t to e-discovery, it is
important to avoid the very
real roadblocks that exist in most organization. To get the light

to turn green at the
intersection of e-discovery and IG, it is critical to:
■ Establish a culture that both values information and
recognizes the risks inherent in
it. Every organization must evolve its culture from one of
keeping everything
to one of information compliance. This kind of change requires
high-level ex-
ecutive support. It also requires constant training of employees
about how to
create, classify, and store information. While this advice may
seem trite, many
managers in leading organizations say that without this kind of
culture change,
IG projects tend to be dead on arrival.
■ Create a truly cross-functional IG team. Culture change is
not easy, but it can be
even harder if the organization does not bring all stakeholders
together when
setting requirements for IG. Stakeholders include: legal;
security and ethics; IT;

125
records management; internal audit; corporate governance;
human resources;
compliance; and business units and employees. That is a lot of
stakeholders. In
organizations that are successfully launching and executing IG
projects, many
have dedicated IG teams. Some of those IG teams are the next
generation of
records management departments, while others are newly
formed. The stake-
holders can be categorized into three areas: legal/risk, IT, and
the business.
The IG team can bring those areas together to ensure that any
projects meet
requirements of all stakeholders.
■ Use e-discovery as an IG proof of concept . Targeted
programs like e-discovery,t
compliance, and archiving have a history of return on
investment (ROI)
and an ability to get budget. These projects are also

challenging, but more
straightforward to implement and can address sub-sets of
information in ear-
ly phases (e.g., only those information assets that are reasonable
to account
for). The lessons learned from these targeted projects can then
be applied to
other IG initiatives.
■ Measure ROI on more than just cost savings . Yes, one of the
primary benefi ts of ad-s
dressing e-discovery via IG is cost reduction, but it is wise to
begin measuring
all e-discovery initiatives on how they impact the life cycle of
legal matters. The
effi ciencies gained in collecting information, for example, have
benefi ts that go
way beyond reduced cost; the IT time not wasted on reactive
collection is more
time available for innovative projects that drive revenue for
companies. And a
better litigation win rate will make any legal team happier.
Building on Legal Hold Programs to Launch Defensible
Disposition

By Barry Murphy
Defensible deletion programs can build on legal hold programs,
because legal hold
management is a necessary fi rst step before defensibly deleting
anything. The standard
is “reasonable effort” rather than “perfection.” Third-party
consultants or auditors can
support the diligence and reasonableness of these efforts.
Next, prioritize what information to delete and what
information the organiza-
tion is capably able to delete in a defensible manner. Very few
organizations are deleting
information across all systems. It can be overly daunting to try
to apply deletion to all en-
terprise information. Choosing the most important information
sources—e-mail, for
example—and attacking those fi rst may make for a reasonable
and tenable approach.
For most organizations, e-mail is the most common information
source to begin deleting. Why
e-mail? It is fairly easy for companies to put systematic rules on
e-mail because the

technology is already available to manage e-mail in a
sophisticated manner. Because
e-mail is such a critical data system, e-mail providers and e-
mail archiving providers
early on provided for systematic deletion or application of
retention rules. However, in
IG serves as the underpinning for effi cient e-discovery
processes.
non–e-mail systems, the retention and deletion features are less
sophisticated; there-
fore, organizations do not systematically delete across all
systems.
Once e-mail is under control, the organization can begin to
apply lessons learned
to other information sources and eventually have better IG
policies and processes that
treat information consistently based on content rather than on
the repository.

Destructive Retention of E-mail
A destructive retention program is an approach to e-mail
archiving where e-mail
messages are retained for a limited time (say, 90 days),
followed by the permanent
manual or automatic deletion of the messages from the
organization network, so long
as there is no litigation hold or the e-mail has not been declared
a record.
E-mail retention periods can vary from 90 days to as long as
seven years:
■ Osterman Research reports that “nearly one-quarter of
companies delete e-
mail after 90 days.” 17
■ Heavily regulated industries, including energy, technology,
communications,
and real estate, favor archiving for one year or more, according
to Fulbright
and Jaworski research.

■ The most common e-mail retention period traditionally has
been seven years;
however, some organizations are taking a hard-line approach
and stating that
e-mails will be kept for only 90 days or six months, unless it is
declared as
a record, classifi ed, and identifi ed with a classifi
cation/retention category and
tagged or moved to a repository where the integrity of the
record is protected
(i.e., the record cannot be altered and an audit trail on the
history of the re-
cord’s usage is maintained).
Newer Technologies That Can Assist in E-Discovery
Few newer technologies are viable for speeding the document
review process and im-
proving the ability to be responsive to court-mandated requests.
Here we introduce pre-
dictive coding and technology-assisted review (also known as
computer-assisted review),
the most signifi cant of new technology developments that can
assist in e-discovery.

For most organizations, e-mail is the most common
information source to
begin deleting according to established retention policies.
Destructive retention of e-mail is a method whereby e-mail
messages are re-
tained for a limited period and then destroyed.
127
Predictive Coding
During the early case assessment (ECA) phase of e-discovery,
t predictive coding is ag
“court-endorsed process” 18 utilized to perform document
review. It uses human exper-
tise and IT to facilitate analysis and sorting of documents.
Predictive coding software
leverages human analysis when experts review a subset of
documents to “teach” the
software what to look for, so it can apply this logic to the full
set of documents, 19 mak-

ing the sorting and culling process faster and more accurate
than solely using human
review or automated review.
Predictive coding uses a blend of several technologies that
work in concert:20 soft-
ware that performs machine learning (a type of g artifi cial
intelligence software that
“learns” and improves its accuracy, fostered by guidance from
human input and pro-
gressive ingestion of data sets—in this case documents); 21
workfl ow software, which w
routes the documents through a series of work steps to be
processed; and text analyt-
ics software, used to perform functions such as searching for
keywords (e.g., “asbestos”
in a case involving asbestos exposure). Then using keyword
search capabilities, or con-
cepts using s pattern search or meaning-based search, and
sifting through and sorting
documents into basic groups using fi ltering technologies,
based on document content,g
and sampling a portion of documents to fi nd patterns and to
review the accuracy of g
fi ltering and keyword search functions.

The goal of using predictive coding technology is to reduce the
total group of
documents a legal team needs to review manually (viewing and
analyzing them one
by one) by fi nding that gross set of documents that is most
likely to be relevant or
responsive (in legalese) to the case at hand. It does this by
automating, speeding up,
and improving the accuracy of the document review process to
locate and “digitally
categorize” documents that are responsive to a discovery
request. 22 Predictive coding,
when deployed properly, also reduces billable attorney and
paralegal time and there-
fore the costs of ECA. Faster and more accurate completion of
ECA can provide valu-
able time for legal teams to develop insights and strategies,
improving their odds for
success. Skeptics claim that the technology is not yet mature
enough to render more
accurate results than human review.
The fi rst state court ruling allowing the use of predictive
coding technology in-

stead of human review to cull through approximately 2 million
documents to “execute
a fi rst-pass review” was made in April 2012 by a Virginia state
judge.23 This was the
fi rst time a judge was asked to grant permission without the
two opposing sides fi rst
coming to an agreement. The case, Global Aerospace, Inc., et
al. v. Landow Aviation, LP,
et al., stemmed from an accident at Dulles Jet Center.
In an exhaustive 156-page memorandum, which included
dozens of pages
of legal analysis, the defendants made their case for the
reliability, cost-
effectiveness, and legal merits of predictive coding. At the core
of the memo
Predictive coding software leverages human analysis when
experts review a
subset of documents to “teach” the software what to look for, so
it can apply
this logic to the full set of documents.

was the argument that predictive coding “is capable of locating
upwards of
seventy-fi ve percent of the potentially relevant documents and
can be effec-
tively implemented at a fraction of the cost and in a fraction of
the time of
linear review and keyword searching.”24
This was the fi rst big legal win for predictive coding use in e -
discovery.
Basic Components of Predictive Coding
Here is a summary of the main foundational components of
predictive coding.
■ Human review. Human review is used to determine which
types of document
content will be legally responsive based on a case expert’s
review of a sampling
of documents. These sample documents are fed into the system
to provide a
seed set of examples. 25

■ Text analytics. This involves the ability to apply “keyword-
agnostic” (through a
thesaurus capability based on contextual meaning, not just
keywords) to locate
responsive documents and build create seed document sets.
■ Workfl ow. Software to route e-documents through the
processing steps auto-
matically to improve statistical reliability and streamlined
processing.
■ Machine learning. The software “learns” what it is looking
for and improves its
capabilities along the way through multiple, iterative passes.
■ Sampling. Sampling is best applied if it is integrated so that
testing for accuracy
is an ongoing process. This improves statistical reliability and
therefore defen-
sibility of the process in court.
Predictive Coding Is the Engine; Humans Are the Fuel
Predictive coding sounds wonderful, but it does not replace the
expertise of an attorney;
it merely helps leverage that knowledge and speed the review

process. It “takes all the
documents related to an issue, ranks and tags them so that a
human reviewer can look
over the documents to confi rm relevance.” So it cannot work
without human input to
let the software know what documents to keep and which ones
to discard, but it is an
emerging technology tool that will play an increasingly
important role in e-discovery.26
Technology-Assisted Review
TAR, also known as computer-assisted review, is not
predictive coding. TAR includest
aspects of the nonlinear review process, such as culling,
clustering and de-duplication,
but it does not meet the requirements for comprehensive
predictive coding.
Many technologies can help in making incremental reductions
in e-discovery
costs. Only fully integrated predictive coding, however, can
completely transform the economics
of e-discovery .

Mechanisms of Technology-Assisted Review
There are three main mechanisms, or methods, for using
technology to make legal
review faster, less costly, and generally smarter. 27
1. Rules driven. “I know what I am looking for and how to
profi le it.” In this sce-
nario, a case team creates a set of criteria, or rules, for
document review and
129
builds what is essentially a coding manual. The rules are fed
into the tool for
execution on the document set. For example, one rule might be
to “redact for
privilege any time XYZ term appears and add the term
‘redacted’ where the
data was removed.” This rule-driven approach requires iteration
to truly be
effective. The case team will likely have rules changes and
improvements as

the case goes on and more is learned about strategy and merit.
This approach
assumes that the case team knows the document set well and can
apply very
specifi c rules to the corpus in a reasonable fashion.
2. Facet driven. “I let the system show me the profi le groups
fi rst.” In this sce-
nario, a tool analyzes documents for potential items of interest
or groups
potentially similar items together so that reviewers can begin
applying
decisions. Reviewers typically utilize visual analytics that guide
them through
the process and take them to prioritized documents. This
mechanism can also
be called present and direct.
3. Propagation based. “I start making decisions and the
system looks for similar-
related items.” This type of TAR is about passing along, or
propagating, what
is known based on a sample set of documents to the rest of the
documents in
a corpus. In the market, this is often referred to as predictive

coding because
the system predicts whether documents will be responsive or
privileged based
on how other documents were coded by the review team.
Propagation-based
TAR comes in different fl avors, but all involve an element of
machine learning.
In some scenarios, a review team will have access to a seed set
of documents
that the team codes and then feeds into the system. The system
then mimics
the action of the review team as it codes the remainder of the
corpus. In other
scenarios, there is not a seed set; rather, the systems give
reviewers random
documents for coding and then create a model for relevance and
nonrelevance.
It is important to note that propagation-based TAR goes beyond
simple
mimicry; it is about creating a linguistic mathematical model
for what
relevance looks like.
These TAR mechanisms are not mutually exclusive. In fact,
combining the mecha-

nisms can help overcome the limitations of individual
approaches. For example, if a doc-
ument corpus is not rich (e.g., does not have a high enough
percentage of relevant documents), it
can be hard to create a seed set that will be a good training set
for the propagation-based system.
However, it is possible to use facet-based TAR—for example,
concept searching—to
more quickly fi nd the documents that are relevant so as to
create a model for relevance
that the propagation-based system can leverage. 28
It is important to be aware that these approaches require more
than just technology.
It is critical to have the right people in place to support the
technology and the work-
fl ow required to conduct TAR. Organizations looking to
exercise these mechanisms
of TAR will need:
■ Experts in the right tools and information retrieval. Software
is an important part
of TAR. The team executing TAR will need someone that can
program the tool
set with the rules necessary for the system to intelligently mark

documents.
Furthermore, information retrieval is a science unto itself,
blending linguistics,
statistics, and computer science. Anyone practicing TAR will
need the right
team of experts to ensure a defensible and measurable process.
■ Legal review team . While much of the chatter around TAR
centers on its ability
to cut lawyers out of the review process, the reality is that the
legal review team
will become more important than ever. The quality and
consistency of the deci-
sions this team makes will determine the effectiveness that any
tool can have in
applying those decisions to a document set.
■ Auditor. Much of the defensibility and acceptability of TAR
mechanisms will
rely on the statistics behind how certain the organization can be
that the out-

put of the TAR system matches the input specifi cation.
Accurate measures of
performance are important not only at the end of the TAR
process, but also
throughout the process in order to understand where efforts
need to be focused
in the next cycle or iteration. Anyone involved in setting or
performing mea-
surements should be trained in statistics.
For an organization to use a propagated approach, in addition
to people it may need
a “seed” set of known documents. Some systems use random
samples to create seed
sets while others enable users to supply small sets from the
early case investigations.
These documents are reviewed by the legal review team and
marked as relevant, privi-
leged, and the like. Then, the solution can learn from the seed
set and apply what it
learns to a larger collection of documents. Often this seed set is
not available, or the
seed set does not have enough positive data to be statistically
useful.

Professionals using TAR state that the practice has value, but it
requires a sophisticated
team of users (with expertise in information retrieval, statistics,
and law) who understand
the potential limitations and danger of false confi dence that can
arise from improper use. For
example, using a propagation-based approach with a seed set of
documents can have
issues when less than 10 percent of the seed set documents are
positive for relevance.
In contrast, rules driven and other systems can result in false
negative decisions when
based on narrow custodian example sets.
However TAR approaches and tools are used, they will only be
effective if usage
is anchored in a thought out, methodically sound process. This
requires a defi nition of
what to look for, searching for items that meet that defi nition,
measuring results, and
then refi ning those results on the basis of the measured results.
Such an end-to-end
plan will help to decide what methods and tools should be used
in a given case. 29

Defensible Disposal: The Only Real Way To Manage Terabytes
TT
and Petabytes
By Randy Kahn, Esq.
Records and information management (RIM) is not working. At
least, it is not working
well. Information growth and management complexity has
meant that the old records l
retention rules and the ways businesses apply them are no
longer able to address the
lifecycle of information. So the mountains of information grow
and grow and grow,
often unfettered.
Too much data has outlived its usefulness, and no one seems to
know how or is
willing to get rid of it. While most organizations need to right-
size their information
footprint by cleaning out the digital data debris, they are
stymied by the complexity
and enormity of the challenge.

131
Growth of Information
According to International Data Corporation (IDC), from now
until 2020, the digital
universe is expected by expand to more than 14 times its current
size. 30 One exabyte
is the data equivalent of about 50,000 years of DVD movies
running continuously.
With about 1,800 exabytes of new data created in 2011, 2840
exabytes in 2012, and
a predicted 6,120 exabytes in 2014, the volumes are truly
staggering. While the data
footprint grows signifi cantly each year, that says nothing of
what has already been cre-
ated and stored.
Contrary to what many say (especially hardware salespeople)
storage is not cheap.t
In fact, it is really becomes quite expensive when you add up
not only the hard-
ware costs but also maintenance, air conditioning and space
overhead, and the highly

skilled labor needed to keep it running. Many large companies
spend tens if not hun-
dreds of millions of dollars per year just to store data. This is
money that could go
straight to the bottom line if the unneeded data could be
discarded. When you con-
sider that most organizations’ information footprints are
growing at between 20 and
50 percent per year and the cost of storage is declining by a few
percentage points
per year, in real terms they are spending way more this year
than last to simply house
information.
Volumes Now Impact Effectiveness
The law of diminishing returns applies to information growth.
Assuming information
is an asset, at some point when there is so much data, its value
starts to decline. That is
not because the intrinsic value goes down (although many
would argue there is a lot of
idle chatter in the various communications technologies).
Rather the decline is related
to the inability to expeditiously fi nd or have access to needed

business information.
According the Council of Information Auto-Classifi cation
“Information Explosion”
Survey, there is now so much information that nearly 50 percent
of companies need
to re-create business records to run their business and protect
their legal interests
because they cannot fi nd the original retained record.31 It is a
poor business practice
to spend resources to retain information and then, when it
cannot be found, to spend
more to reconstitute it.
There is increasing regulatory pressure, enforcement, and
public scrutiny on all
of an organization’s data storage activities. Record sanctions
and fi nes, new regula-
tions, and stunning court decisions have converged to mandate
heightened controls
and accountability from government regulators, industry and
standards groups as well
as the public. When combined with the volume of data,
information privacy, security,
protection of trade secrets, and records compliance become
complex and critical, high-

risk business issues that only executive management can truly fi
x. However, executives
typical view records and information management (RIM) as a
low-importance cost
center activity, which means that the real problem does not get
solved.
In most companies, there is no clear path to classify electronic
records, to for-
mally manage offi cial records, or to ensure the ultimate
destruction of these records.
Vast stores of legacy data are unclassifi ed, and most data is
never touched again
shortly after creation. Further, traditional records retention
rules are too voluminous,
too complex, and too granular and do not work well with the
technology needed to
manage records.
Finally, it is clear that employees can no longer be expected to
pull the oars to

cut through the information ocean, let alone boil it down into
meaningful chunks of
good information. Increasingly, technology has to play a more
central role in manag-
ing information. Better use of technology will create business
value by reducing risk,
driving improvements in productivity, and facilitating the
exploitation and protection
of ungoverned corporate knowledge.
How Did This Happen?
Over the past several years, organizations have come to realize
that the exposure posed
by uncontrolled data growth requires emergency, reactive
action, as seemingly no oth-
er viable approach exists. Faced with massive amounts of
unknown unstructured data,
many organizations have chosen to adopt a risk-averse save-
everything policy. This
approach has brought with it immediate repercussions:
■ Inability to quickly locate needed business content buried
in ill-managed fi le
systems.

■ Sharply increased storage costs, with some companies
refusing to allocate any
more storage to the business. The users’ reaction, out of
necessity, is to store
data wherever they can fi nd a place for it. (Do not buy the
argument that stor-t
age is cheap—everyone is spending more on storing
unnecessary data, even if
the per-gigabyte media cost has gone down).
■ Soaring litigation and discovery costs, as organizations
have lost track of what
is where, who owns it, and how to collect, sort, and process it.
■ Buried intellectual property, trade secrets, personally
identifi able information,
and regulated content, which are subject to leakage and
unauthorized deletion,
and are a clear target for opposing counsel—or anyone who can
access them.
■ Lack of centralized policies and systems for the storage of
records, which re-
sults in hard-to-manage record sites spread throughout the

organization.
■ The lack of a clear strategy for managing records that have
long-term, rather
than short-term, business, legal, and research value.
Information Glut in Organizations
■ 71 percent of organizations surveyed have no idea of the
content in their stored
data.
■ 58 percent of organizations are keeping information indefi
nitely.
■ 79 percent of organizations say too much time and effort is
spent manually
searching and disposing information.
■ 58 percent of organizations still rely on employees to
decide how to apply cor-
porate policies. 32
What Is Defensible Disposition, and How Will It Help?
A solution to the unmitigated data sprawl is to defensibly

dispose of the business con-
tent that no longer has business or legal value to the
organization. In the old days
of records management, it was clear that courts and regulators
alike understood that
records came into being and eventually were destroyed in the
ordinary course of
business. It is good business practice to destroy unneeded
content, provided that the
133
rules on which those decisions are made consider legal
requirements and business
needs. Today, however, the good business practice of cleaning
house of old records has
somehow become taboo for some businesses. Now it needs to
start again.
An understanding of how technology can help defensibly
dispose and how meth-
odology and process help an organization achieve a thinner

information footprint is
critical for all companies overrun with outdated records that do
not know where to
start to address the issue. While no single approach is right for
every organization, re-
cords and legal teams need to take an informed approach,
looking at corporate culture,
risk tolerance, and litigation profi le.
A defensible disposition framework is an ecosystem of
technology, policies, proce-
dures, and management controls designed to ensure that records
are created, managed,
and disposed at the end of their life cycle.
New Technologies—New Information Custodians
Responsibility for records management and IG have changed
dramatically over time.
In the past, the responsibility rested primarily with the records
manager. However, the
nature of electronic information is such that its governance
today requires the partici-
pation of IT, which frequently has custody, control, or access to
such data, along with

guidance from the legal department. As a result, IT personnel
with no real connection
or ownership of the data may be responsible for the accuracy
and completeness of the
business-critical information being managed. See the problem?
For many organizations, advances in technology mixed with an
explosive growth
of data forced a reevaluation of core records management
processes. Many organi-
zations have deployed archiving, litigation, and e-discovery
point solutions with the
intent of providing record retention compliance and
responsiveness to litigation. Such
systems may be tactically useful but fail to strategically address
the heart of the matter:
too much information, poorly managed over years and years—if
not decades.
A better approach is for organizations to move away from a
reactive keep-
everything strategy to a proactive strategy that allows the
reasonable and reliable
identifi cation and deletion of records when retention
requirements are reached, absent

a preservation obligation. Companies develop retention
schedules and processes pre-
cisely for this reason; it is not misguided to apply them.
Why Users Cannot, Will Not—and Should Not—Make the Hard
Choices
Employees usually are not suffi ciently trained on records
management principles and
methods and have little incentive (or downside) to properly
manage or dispose of records.
Further, many companies today see that requiring users to
properly declare or man-
age records places an undue burden on them. The employees not
only do not provide a
A defensible disposition framework is an ecosystem of
technology, policies,
procedures, and management controls designed to ensure that
records are
created, managed, and disposed at the end of their life cycle.

reasonable solution to the huge data pile (which for some
companies may be petabytes of
data) but contribute to its growth by using more unsanctioned
technologies and parking
company information in unsanctioned locations. So the digital
landfi ll continues to grow.
Most organizations have programs that address paper records,
but these same
organizations commonly fail to develop similar programs for
electronic records and
other digital content.
Technology Is Essential to Manage Digital Records Properly
Having it all—but not being able to fi nd it—is like not having
it at all. t
While the content of a paper document is obvious, viewing the
content of an electron-
ic document depends on software and hardware. Further, the
content of electronic storage
media cannot be easily accessed without some clue as to its
structure and format. Conse-

quently, the proper indexing of digital content is fundamental
to its utility. Without an index,
retrieving electronic content is expensive and time consuming,
if it can be retrieved at all.
Search tools have become more robust, but they do not provide
a panacea for
fi nding electronic records when needed because there is too
much information spread
out across way too many information parking lots. Without
taxonomies and common
business terminology, accessing the one needed business record
may be akin to fi nding
the needle in a stadium-size haystack.
Technological advances can help solve the challenges
corporations face and ad-
dress the issues and burdens for legal, compliance, and
information governance. When
faced with hundreds of terabytes to petabytes of information, no
amount of user inter-
vention will begin to make sense of the information tsunami.
Auto-Classifi cation and Analytics Technologies

Increasingly companies are turning to new analytics and
classifi cation technologies
that can analyze information faster, better, and cheaper. These
technologies should
be considered essential for helping with defensible disposition,
but do not make the
mistake of underestimating their expense or complexity.
As discussed in the previous section by Barry Murphy, machine
learning tech-
nologies mean that software can “learn” and improve at the
tasks of clustering fi les
and assigning information (e.g., records, documents) to
different preselected topical
categories based on a statistical analysis of the data
characteristics. In essence,
classifi cation technology evaluates a set of data with known
classifi cation mappings
and attempts to map newly encountered data within the existing
classifi cations. This
type of technology should be on the list of considerations when
approaching defen-
sible disposition in large, uncontrolled data environments.
Can Technology Classify Information?

What is clear is that IT is better and faster than people in
classifying information. Period.
A better approach is for organizations to move away from a
reactive keep-
everything strategy to a proactive strategy of defensible
deletion.
135
Increasingly studies and court decisions make clear that, when
appropriate, com-
panies should not fear using enabling technologies to help
manage information.
For example, in the recent Da Silva Moore v. Publicis Groupe
case, Judge Andrew
Peck stated:
Computer-assisted review appears to be better than the
available alternatives,

and thus should be used in appropriate cases. While this Court
recognizes that
computer-assisted review is not perfect, the Federal Rules of
Civil Procedure
do not require perfection. . . . Counsel no longer have to worry
about being
the “fi rst” or “guinea pig” for judicial acceptance of computer
assisted review.
This work presents evidence supporting the contrary position:
that a
technology-assisted process, in which only a small fraction of
the document
collection is ever examined by humans, can yield higher recall
and/or preci-
sion than an exhaustive manual review process, in which the
entire document
collection is examined and coded by humans. 33
Moving Ahead by Cleaning Up the Past
Organizations can improve disposition and IG programs with a
systemized, repeatable,
and defensible approach that enables them to retain and dispose
of all data types in

compliance with the business and statutory rules governing the
business’s operations.
Generally, an organization is under no legal obligation to retain
every piece of in-
formation it generates in the course of its business. Its records
management process is
there to clean up the information junk in a consistent,
reasonable way. That said, what
should companies do if they have not been following disposal
rules, so information has
piled up and continues unabated? They need to clean up old
data. But how?
Manual intervention (by employees) will likely not work, due
to the sheer volumes
of data involved. Executives will not and should not have
employees abdicate their
regular jobs in favor of classifying and disposing of hundreds of
millions of old stored
fi les. (Many companies have billions of old fi les.) This
buildup necessitates leveraging tech-
nology, specifi cally, technologies that can discern the meaning
of stored unstructured content, in
a variety of formats, regardless of where it is stored.

Here is a starting point: Most likely, fi le shares, legacy e-mail
systems, and other
large repositories will prove the most target-rich environments,
while better-managed
document management, records management, or archival
systems will be in less need
of remediation. A good time to undertake a cleanup exercise is
when litigation will not
prevent action or when migrating to a new IT platform. (Trying
to conduct a compre-
hensive, document-level inventory and disposition is neither
reasonable nor practical.
In most cases, it will create limited results and even further
frustration.)
Technology choices should be able to withstand legal
challenges in court.
Sophisticated technologies available today should also look
beyond mere keyword
searches (as their defensibility may be called into question) and
should look to
Organizations can improve disposition and IG programs with a
systemized,

repeatable, and defensible approach.
advanced techniques such as automatic text classifi cation
(auto-classifi cation), concept
search, contextual analysis, and automated clustering. While
technology is imperfect,
it is better than what employees can do and will never be able to
accomplish—to man-
age terabytes of stored information and clean up big piles of
dead data.
Defensibility Is the Desired End State; Perfection Is Not
Defensible disposition is a way to take on huge piles of
information without personally
cracking each one open and evaluating it. Perhaps it is, in
essence, operationalizing a
retention schedule that is no longer viable in the electronic age.
Defensible disposition
is a must because most big companies have hundreds of millions
or billions of fi les,

which makes their individualized management all but
impossible.
As the list of eight steps to defensible disposition makes clear,
different chunks of data
will require different diligence and analysis levels. If you have
100,000 backup tapes from
20 years ago, minimal or cursory review may be required before
the whole lot of tapes can
be comfortably discarded. If, however, you have an active
shared drive with records and
information that is needed for ongoing litigation, there will
need to be deeper analysis
with analytics and/or classifi cation technologies that have
become much more powerful
and useful. In other words, the facts surrounding the
information will help inform if the
information can be properly disposed with minimal analysis or
if it requires deep diligence.
Kahn’s Eight Essential Steps to Defensible Disposition
1. Defi ne a reasonable diligence process to assess the business
needs and legal
requirements for continued information retention and/or

preservation, based
on the information at issue.
2. Select a practical information assessment and/or classifi
cation approach, given
information volumes, available resources, and risk profi le.
3. Develop and document the essential aspects of the
disposition program to
ensure quality, effi cacy, repeatability, auditability, and
integrity.
4. Develop a mechanism to modify, alter, or terminate
components of the dispo-
sition process when required for business or legal reasons.
5. Assess content for eligibility for disposition, based on
business need, record
retention requirements, and/or legal preservation obligations.
6. Test, validate, and refi ne as necessary the effi cacy of
content assessment and
disposition capability methods with actual data until desired
results have been
attained.

7. Apply disposition methodology to content as necessary,
understanding that
some content can be disposed with suffi cient diligence without
classifi cation.
8. On an ongoing basis, verify and document the effi cacy and
results of the dis-
position program and modify and/or augment the process as
necessary.
Source: “Chucking Daises: Ten Rules for Taking Control of
Your Organization’s Digital
Debris,” Randy Kahn, Esq., and Galena Datskovsky Ph.D., CRM
(ARMA International,
2013), Overland Park, KS.
Business Case around Defensible Disposition
What is clear is that defensible disposition can have signifi
cant ROI impact to a com-
pany’s fi nancial picture. This author has clients for whom we
have built the defensible

137
disposition business case, which saves them tens of millions of
dollars on a net basis but
also makes them a more effi cient business, reduces litigation
cost and risks, mitigates
the information security and privacy risk profi les, and makes
their work force more
productive, and so on.
However, remember auto-classifi cation technology is neither
simple nor inexpen-
sive, so be realistic and conservative when building the business
case. Often it is easiest
to simply use only hardware storage cost savings to make the
case because it is a hard
number and provides a conservative approach to justifying the
activities. Then you
can add on the additional benefi ts, which are more diffi cult to
calculate, and also the
intangible benefi ts of giving your employees a cleaner
information stack to search and
base decisions on.

Defensible Disposition Summary
Defensible disposition is a way to bring your records
management program into to-
day’s business reality—information growth makes management
at the record level all
but impossible. Defensible disposition should be about taking
simplifi ed retention
rules and applying them to both structured and unstructured
content with the least
amount of human involvement possible. While it can be a
daunting challenge, it is also
an opportunity to establish and promote operational excellence
through better IG
and to signifi cantly enhance an organization’s business
performance and competitive
advantage.
Retention Policies and Schedules
By Robert Smallwood, edited by Paula Lederman, MLS
With limited resources, today’s legal counsel, compliance
managers, and records man-

ager are faced with an onslaught of increasingly pressing and
complex compliance
and legal demands. At the core of these demands is the abil ity
of the organization to
demonstrate that it has legally defensible records management
practices that can hold
up in court.
Organizations can legally destroy records—but will have a
greater legal defensi-
bility if:
■ The authority to destroy the records is identifi ed on a
retention schedule.
■ The retention requirements have been met.
■ The records are slated for destruction in the normal course
of business.
■ There are no existing legal or fi nancial holds.
■ Al records of the same type are treated consistently and
systematically.
The foundation of legally defensible records management
practices is a solid IG
underpinning, where policies and processes, supported and
enforced by IT, help the

organization meet its externally mandated legal requirements
and internally mandated
IG requirements for handling and controlling information.
A complete, current, and documented records retention program
reduces stor-
age and handling costs and improves searchability for records
by making records
easier and faster to fi nd. This reduced search time and more
complete search
capability improves knowledge worker productivity. It also
reduces legal risk by
improving the ability to meet compliance demands while also
reducing e-discovery
costs and improving the ability to more effi ciently respond to
discovery requests
during litigation.
Most large organizations maintain records retention schedules
by business

unit, department, or functional area. Some organizations,
particularly smaller
ones, may establish organization-wide IG programs that call for
the developing,
updating, and improvement of an enterprise or master retention
schedule. This is
a tall order and is almost never accomplished—but it is possible
with a determined,
sustained effort. Developing enterprise-wide records retention
schedules requires
consultation with stakeholder groups that have valuable input to
contribute to the
overall development of the IG effort and to specifi c schedules
for retaining record
collections and their planned disposition. Consultation by the
records manage-
ment department, senior records offi cer , or records team must
take place with
representatives from the business units that create and own the
records as well
as with legal, compliance, risk management, IT, and other
relevant stakeholder
groups.
Meeting Legal Limitation Periods

A key consideration in developing retention schedules is
researching and determin-
ing the minimum time required to keep records that may be
demanded in legal
actions. “A limitation period is the length of time after which a
legal action cannot
be brought before the courts. Limitation periods are important
because they de-
termine the length of time records must be kept to support court
action [including
subsequent appeal periods]. It is important to be familiar with
the purpose, prin-
ciples, and special circumstances that affect limitation periods
and therefore records
retention.”34
Legal Requirements and Compliance Research
As stated at the beginning of this chapter, legal requirements
trump all others. The reten-
tion period for a particular records series must meet minimum
retention requirements
as mandated by law. Business needs and other considerations
are secondary. So, legal

research is required before determining retention periods.
Legally required retention
periods must be researched for each jurisdiction (state, country)
in which the business
operates, so that it complies with all applicable laws.
A limitation period is the length of time after which a legal
action cannot
be brought before the courts. Such a period must be factored
into retention
policies.
139
records retention citation
service, which publishes in electronic form all of the retention-
related citations. These
services usually are bought on a subscription basis, as citations
are updated on an an-

nual or more frequent basis as legislation and regulations
change.
using online or
operating in the
(CFR), the annual
edition of which:
is the codifi cation of the general and permanent rules
published in the Fed-
eral Register by the departments and agencies of the federal
government. It is
divided into 50 titles that represent broad areas subject to
federal regulation.
The 50 subject matter titles contain one or more individual
volumes, which
are updated once each calendar year, on a staggered basis. The
annual update
cycle is as follows: titles 1 to 16 are revised as of January 1;
titles 17 to 27 are
revised as of April 1; titles 28 to 41 are revised as of July 1, and
titles 42 to 50

are revised as of October 1. Each title is divided into chapters,
which usually
bear the name of the issuing agency. Each chapter is further
subdivided into
parts that cover specifi c regulatory areas. Large parts may be
subdivided into
subparts. All parts are organized in sections, and most citations
to the CFR
refer to material at the section level. 35
cial CFR but is
updated daily, the Electronic Code of Federal Regulations (e-
CFR) . “It is not an
offi cial legal edition of the CFR. The e-CFR is an editorial
compilation of CFR mate-
rial and Federal Register amendments produced by the National
Archives and Records
Administration’s Offi ce of the Federal Register (OFR) and the
Government Printing
Offi ce.”36 According to the gpoaccess.gov Web site:
The Administrative Committee of the Federal Register (ACFR)
has authorized
the National Archives and Records Administration’s (NARA)

Offi ce of the Fed-
eral Register (OFR) and the Government Printing Offi ce (GPO)
to develop
and maintain the e-CFR as an informational resource pending
ACFR action to
grant the e-CFR offi cial legal status. The OFR/GPO partnership
is committed
to presenting accurate and reliable regulatory information in the
e-CFR edito-
rial compilation with the objective of establishing it as an
ACFR sanctioned
publication in the future. While every effort has been made to
ensure that the
e-CFR on GPO Access is accurate, those relying on it for legal
research should
verify their results against the offi cial editions of the CFR,
Federal Register and
List of CFR Sections Affected (LSA), all available online at
www.gpoaccess.gov.
Until the ACFR grants it offi cial status, the e-CFR editorial
compilation does
not provide legal notice to the public or judicial notice to the
courts.
The OFR updates the material in the e-CFR on a daily basis.

Generally,
the e-CFR is current within two business days. The current
update status is
displayed at the top of all e-CFR web pages.
http://www.gpoaccess.gov
What Is a Records Retention Schedule?
A records retention schedule delineates how long a (business)
record series is
to be retained, and its disposition after its life cycle is complete
(e.g., destruc-
tion, transfer, archiving); the schedule also contains “lists of
records by name or
type that authorize the disposition of records.”37 Retention
schedules apply to all
records regardless of their format or media (e.g., physical or
electronic). Retention
schedules are developed for records not individually but rather
by records series, categories,
functions, or systems. Ideally, they include all of the record

series in an organization,
although they may be broken down into smaller subset
schedules, such as by busi-
ness unit.
Retention schedules may be maintained separately for electronic
records, or they
may be included in a combined schedule that includes both e-
records and paper or
other physical records.
Corporate records retention schedules are increasingly being
maintained online,
where users and also IT, legal, risk, and records management
personnel can view and
reference them. Electronic data and documents can easily
reference these schedules
and initiate a process based on a trigger event so that the life
cycle of the electronic
document can be automated and managed in a consistent
manner. Retention schedules
are basic tools that allow an organization to prove that it has a
legally defensible basis
on which to dispose records.

Retention schedules in large organizations typically are broken
down and by
business function. A functional retention schedule groups
record series based on
business functions, such as fi nancial, legal, product
management, or sales. Each func-
tion or grouping also is used for classifi cation. Rather than
detail every sequence of
records, these larger functional groups are less numerous and
are easier for users to
understand.
Some organizations are able to reach the ultimate retention
goal: to keep an
enterprise-wide master retention schedule, which includes the
retention and
Retention schedules are developed by records series,
category, function, or
system—not for individual records.
Retention schedules are basic tools that allow an
organization to prove that it
has a legally defensible basis on which to dispose records.

A complete, current, and documented records retention
program reduces
storage and handling costs and improves searchability for
records by making
records easier and faster to fi nd.
141
disposition requirements for records series that cross business
unit boundaries.
The master retention schedule contains all records series in the
entire enterprise.
An enterprise-wide retention schedule is preferable because it
eliminates the
possibility that different business units will follow confl icting
records retention
periods. For example, if one business unit is discarding a group
of records after
5 years, it would not make sense for another business unit to
keep the same records
for 10 years.

Benefi ts of a Retention Schedule
According to the U.S. National Archives and Records
Administration, developing and
maintaining a records retention schedule provides the following
benefi ts. The reten-
tion schedule: 38
1. Reduces legal risk and legal liability exposure.
2. Supports a legally defensible records management
program.
3. Improves IG by enforcing uniformity and standardization.
4. Improves search quality and reduces search time.
5. Provides higher-quality records information to improve
decision support for
knowledge workers.
6. Prevents inadvertent, malicious, or premature destruction
of records.
7. Improves accountability for life cycle management of
records on an enter-
prise-wide basis.
8. Improves security for confi dential records assets. 39
9. Reduces and minimizes costs for maintaining records.

10. Determines which records have historic value.
11. Saves hardware, utility, and labor costs by deleting
records after their life
span.
12. Optimizes use of online storage and access resources.
A formal approach to records management has been around
since the mid-1900s,
so a great deal of guidance is available before embarking on
developing or updating
your records retention program. Models and guides can be used
to assist in the devel-
opment of records retention schedules for your organization,
including the interna-
tional standard for records management, ISO 15489—Part 1 and
2:2001, “Information
and Documentation—Records Management”; the ISO 15489
standard was written
to address all kinds of records. Additional guidance may be
obtained by referencing
national standards, such as those in Canada, Europe, Australia,
and other countries. 40
Often, in the public sector, retention guidelines are published
by an authority such as

the offi ce of the national, state, or provincial archivist. Some
additional insights may
be gleaned from ISO 16175–1:2010, “Information and
Documentation—Principles
and Functional Requirements for Records in Electronic Offi ce
Environments—Part
1: Overview and Statement of Principles,” which establishes
fundamental principles
and functional requirements for software used to create and
manage digital records in
offi ce environments. 41
A records retention schedule is an essential part of an overall
IG program. Due
to the fact that a concerted IG program standardizes and
enforces uniformity and
control, the entire organization benefi ts in terms of
productivity, reduced risk, and
improved compliance and e-discovery processes. These
overarching goals and benefi ts

should be championed by senior management in words and
deeds. This means making
the IG effort visible and providing the proper budgetary
resources in terms of money
and employee time to achieve its aims.
More detail on retention schedules can be found in Chapter 9
on IG and RIM
functions.
The master retention schedule contains all records series in
the entire enterprise.
■ Legal functions are the most important area of IG impact.
■ IG serves as the underpinning for effi cient e-discovery
processes.
■ ESI is any information that is created or stored in electronic
format.
■ The goal of the FRCP amendments is to recognize the
importance of ESI and

to respond to the increasingly prohibitive costs of document
review and pro-
tection of privileged documents.
■ The amended FRCP reinforce the importance of IG. Only
about 25 percent of
business information has real value and 5 percent are business
records.
■ The Big Data trend underscores the need for defensible
deletion of data
debris.
■ In the landmark case Zubulake v. U.B.S. Warburg, the
defendants were se-g
verely punished by an adverse inference for deleting key e-
mails and not
producing copies on backup tapes.
■ The E-Discovery Reference Model is a planning tool that
depicts key
e-discovery process steps.
■ Implementing IG, inventorying ESI, and leveraging
technology to implement

records retention and LHN policies are key steps in e-discovery
planning.
■ LHN management is the absolute minimum an organization
should imple-
ment to meet the guidelines, rules, and precedents.
■ Predictive coding software leverages human analysis when
experts review a
subset of documents to “teach” the software what to look for, so
it can apply
this logic to the full set of documents.
143
■ Many technologies assist in making incremental reductions
in e-discovery
costs, but only fully integrated predictive coding is able to
completely trans-
form the economics of e-discovery.
■ TAR, also known as computer-assisted review, speeds the

review process by
leveraging IT tools.
■ In TAR, there are three main ways to use technology to
make legal review
faster, less costly, and generally smarter: rules driven, facet
driven, and propa-
gation based.
■ It is important to have the right people in place to support
the technology
and the work fl ow required to conduct TAR.
■ A defensible disposition framework is an ecosystem of
technology, policies,
procedures, and management controls designed to ensure that
records are
created, managed, and disposed of at the end of their life cycle.
■ A better approach is for organizations to move away from a
reactive “keep-
everything” strategy to a proactive strategy of defensible
deletion.y
■ Organizations can improve disposition and IG programs

with a systemized,
repeatable, and defensible approach.
■ A limitation period—the length of time after which a legal
action cannot be
brought before the courts—must be factored into retention
policies.
■ A complete, current, and documented records retention
program reduces
records by making
■ Retention schedules are developed by records series, not for
individual records.
■ Retention schedules are basic tools that allow an
organization to prove that it
has a legally defensible basis on which to dispose of records.
■ The master retention schedule contains all records series in
the entire
enterprise.

■ “Records retention” defi nes the length of time that records
are to be kept
and considers legal, regulatory, operational, and historical
requirements.
■ Disposition means not just destruction but can also mean
archiving and a
change in ownership and responsibility for the records.
■ For most organizations, e-mail is the most common
information source to
begin deleting according to established retention policies.
Notes
1. Linda Volonino and Ian Redpath, e-Discovery for Dummies
(Hoboken, NJ: John Wiley & Sons, 2010),s
p. 9. This material is reproduced with permission from John
Wiley & Sons, Inc.

2. “New Fed. Rules to Civil Procedure,”
www.uscourts.gov/FederalCourts/UnderstandingtheFederalCourt
s/
DistrictCourts.aspx; (accessed November 26, 2013).
3. Ibid.
4. Ibid.
5. Volonino and Redpath, e-Discovery for Dummies, p. 13.s
6. Ibid., p. 11.
7. “New Fed. Rules to Civil Procedure.”
www.uscourts.gov/FederalCourts/UnderstandingtheFederalCourt
s/
DistrictCourts.aspx; (accessed November 26, 2013).
8. “The Digital Universe Decade—Are You Ready?” IDC iView
(May 2010).
9. Deidra Paknad, “Defensible Disposal: You Can’t Keep All
Your Data Forever,” July 17, 2012, www.forbes
.com/sites/ciocentral/2012/07/17/defensible-disposal-you-cant-
keep-all-your-data-forever/
10. Sunil Soares, Selling Information Governance to the
Business (MC Press Online, Ketchum, ID, 2011), p. 229. s
11. All quotations from the FRCP are from Volonino and

Redpath, e-Discovery for Dummies , www.dummiess
.com/how-to/content/ediscovery-for-dummies-cheat-sheet.html
(accessed May 22, 2013).
12. Linda Volonino and Ian Redpath, e-Discovery for Dummies
(Hoboken, NJ: John Wiley & Sons, 2010), p. 13. s
13. Case Briefs, LLC, “Zubulake v. UBS Warburg LLC,”
www.casebriefs.com/blog/law/civil-procedure/
civil-procedure-keyed-to-friedenthal/pretrial-devices-of-
obtaining-information-depositions-and-dis-
covery-civil-procedure-keyed-to-friedenthal-civil-procedure-
law/zubulake-v-ubs-warburg-llc/2/ (ac-
cessed May 21, 2013).
14. Amy Girst, “E-discovery for Lawyers,” IMERGE
Consulting Report, 2008.
15. ECM2, “15-Minute Guide to eDiscovery and Early Case
Assessment,” www.emc.com/collateral/
15-min-guide/h9781-15-min-guide-ediscovery-eca-gde.pdf
(accessed May 21, 2013
16. Barry Murphy, telephone interview with author, April 12,
2013.
17. Email to author August 16, 2012.

18. Recommind, “What Is Predictive Coding?”
www.recommind.com/predictive-coding (accessed
May 7, 2013).
19. Michael LoPresti, “What Is Predictive Coding?: Including
eDiscovery Applications,” KMWorld,
January 14, 2013, www.kmworld.com/Articles/Editorial/What-
Is-…/What-is-Predictive-Coding-Including-
eDiscovery-Applications-87108.aspx
20. “Predictive Coding,” TechTarget.com,
http://searchcompliance.techtarget.com/defi nition/predictive-
coding, August 31, 2012 (accessed May 7, 2013).
21. “Machine Learning,” TechTarget.com
http://whatis.techtarget.com/defi nition/machine-learning,
accessed May 7, 2013.
22. “Predictive Coding.”
23. LoPresti, “What Is Predictive Coding?”
24. Ibid.
25. “What Does Predictive Coding Require?” Recommind
Corp., www.recommind.com/predictive-coding

(accessed May 24, 2013).
26. Ibid.
27. Barry Murphy, e-mail to author, May 10, 2013.
28. Ibid.
29. Ibid.
30. “The digital universe in 2020: Big Data, Bigger Digital
Shadows, and Biggest Grow in the Far East,”
www.emc.com/collateral/analyst-reports/idc-the-digital-
universe-in-2020.pdf (accessed November 26,
2013).
31. Council of Information Auto-Classifi cation, “Information
Explosion” survey, http://infoautoclassifi cation
.org/survey.php (accessed November 26, 2013).
32. Ibid.
33. Maura R. Grossman and Gordon V. Cormack, “Technology-
Assisted Review in E-Discovery Can Be
More Effective and More Effi cient Than Exhaustive Manual
Review.” http://delve.us/downloads/Tech-
nology-Assisted-Review-In-Ediscovery.pdf (accesssed
November 26, 2013).

34. Government of Alberta, “Developing Retention and
Disposition Schedules,” July 2004, p. 122, www
.rimp.gov.ab.ca/publications/pdf/SchedulingGuide.pdf
35. U.S. Government Printing Offi ce (GPO), “Code of Federal
Regulations,” www.gpo.gov/help/index
.html#about_code_of_federal_regulations.htm (accessed April
22, 2012).
http://www.uscourts.gov/FederalCourts/UnderstandingtheFedera
lCourts/DistrictCourts.aspx
http://www.forbes.com/sites/ciocentral/2012/07/17/defensi ble-
http://www.casebriefs.com/blog/law/civil-procedure/civil-
procedure-keyed-to-friedenthal/pretrial-devices-of-obtaining-
information-depositions-and-discovery-civil-procedure-keyed-
to-friedenthal-civil-procedure-law/zubulake-v-ubs-warburg-
llc/2/
http://www.emc.com/collateral/15-min-guide/h9781-15-min-
guide-ediscovery-eca-gde.pdf
http://www.recommind.com/predictive-coding

http://www.kmworld.com/Articles/Editorial/What-Is-
%E2%80%A6/What-is-Predictive-Coding-Including-
http://searchcompliance.techtarget.com/definition/predictive-
coding
http://whatis.techtarget.com/definition/machine-learning
http://www.recommind.com/predictive-coding
http://www.emc.com/collateral/analyst-reports/idc-the-digital-
universe-in-2020.pdf
http://infoautoclassification.org/survey.php
http://delve.us/downloads/Tech-nology-Assisted-Review-In-
Ediscovery.pdf
Ediscovery.pdf
Ediscovery.pdf
gulations.htm
http://www.uscourts.gov/FederalCourts/UnderstandingtheFeder a

http://www.casebriefs.com/blog/law/civil-procedure/civil-
procedure-keyed-to-friedenthal/pretrial-devices-of-obtaining-
information-depositions-and-discovery-civil-procedure-keyed-
to-friedenthal-civil-procedure-law/zubulake-v-ubs-warburg-
llc/2/
http://www.emc.com/collateral/15-min-guide/h9781-15-min-
guide-ediscovery-eca-gde.pdf
http://infoautoclassification.org/survey.php
gulations.htm
http://searchcompliance.techtarget.com/definition/predictive-
coding
http://www.rimp.gov.ab.ca/publications/pdf/SchedulingGuide.p
df
http://www.rimp.gov.ab.ca/publications/pdf/SchedulingGuide.p
df

145
36. National Archives and Records Administration, “Electronic
Code of Federal Regulations,” October 2, 2012
37. U.S. Department of Energy, Records Retention Schedule
Defi nition, https://commons.lbl.gov/display/
aro/Records+Retention+Schedule+Defi nition (accessed July 30,
2012).
38. National Archives, “Frequently Asked Questions about
Records Scheduling and Disposition,” updated
June 6, 2005, www.archives.gov/records-
mgmt/faqs/scheduling.html#whysched
Disposition Schedules.”
Records Scheduling and Disposition.”
41. International Organization for Standardization, ISO 16175-
1:2010, “Information and Documentation—

Principles and Functional Requirements for Records in
Electronic Offi ce Environments—Part 1:
Overview and Statement of Principles,”
www.iso.org/iso/catalogue_detail.htm?csnumber=55790
(accessed July 30, 2012).
https://commons.lbl.gov/display/aro/Records+Retention+Schedu
le+Definition
http://www.archives.gov/records-
mgmt/faqs/scheduling.html#whysched
http://www.iso.org/iso/catalogue_detail.htm?csnumber=55790
https://commons.lbl.gov/display/aro/Records+Retention+Schedu
le+Definition
147
R
ecords management (RM) is a key impact area of t information
governance
(IG)—so much so that in the RM space, IG is often thought of

as synonymous
with or a simple superset of RM. But IG is much more than that.
We delve into
the details of RM here—a sort of crash course on how to
identify and inventory re-
cords, conduct the necessary legal research, develop retention
and disposition sched-
ules, and more. Also, we identify the relationship and impact of
IG on the RM function
in an organization in this chapter.
The International Organization for Standardization (ISO) defi
nes (business)
records as “information created, received, and maintained as
evidence and informa-
tion by an organization or person, in pursuance of legal
obligations or in the transac-
tion of business.” 1 It further defi nes RM as “[the] fi eld of
management responsible
for the effi cient and systematic control of the creation, receipt,
maintenance, use, and
disposition of records, including the processes for capturing and
maintaining evidence
of and information about business activities and transactions in

the form of records.” 2
The U.S.-based Association of Records Managers and
Administrators (ARMA)
defi nes records as “evidence of what an organization does.
They capture its business
activities and transactions, such as contract negotiations,
business correspondence,
personnel fi les, and fi nancial statements.” 3
Records and information management (RIM) extends beyond
RM (although t
the terms are often used interchangeably) to include
information—that is, information
such as data, electronic documents, and reports. For this reason,
RIM professionals
must expand their reach and responsibilities to include policies
for retention and dis-
position of all legally discoverable forms of information, such
as e-mail, social media
posts, mobile data and documents held on portable devices,
cloud storage and applica-
tions, and other enterprise data and information.
Electronic records management (ERM) has moved to the

forefront of busi-t
ness issues with the increasing automation of business processes
and the vast growth
in the volume of electronic documents and records that
organizations create. These
Portions of this chapter are adapted from Chapters 1 , 5 ,
and 7 of Robert F. Smallwood, Managing Electronic
Records:
Methods, Best Practices, and Technologies , © John Wiley &
Sons, Inc., 2013. Reproduced with permission of John Wiley s
& Sons, Inc.
C H A P T E R 9
and Records and
Information
Management Functions
factors, coupled with expanded and tightened reporting laws and
compliance regula-

tions, have made ERM essential for most enterprises—
especially highly regulated and
public ones.
ERM follows generally the same principles as traditional paper -
based records
management: There are classifi cation and taxonomy needs to
group and organize y
the records, and there are retention and disposition schedules
to govern the length
of time a record is kept and its ultimate disposition (destruction,
transfer, or long-term
archiving) destruction or long-term archiving. Yet e-records
must be handled differ-
ently, and they contain more detailed data about their contents
and characteristics,
known as metadata. (For more detail on these topics see
Appendix A. )
E-records are also subject to changes in information technology
(IT) that may y
make them diffi cult to retrieve and view and therefore render
them obsolete. These is-
sues can be addressed through a sound ERM program that
includes long-term digital

preservation (LTDP) methods and technologies.
ERM is primarily the organization, management, control,
monitoring, and auditing
of formal business records that exist in electronic form. But
automated ERM systems also
track paper-based and other physical records. So ERM goes
beyond simply managing elec-
tronic records; it is the management of electronic records and
the electronic management of non-
electronic records (e.g., paper, CD/DVDs, magnetic tape, audio-
visual, and other physical records).
Most electronic records, or e-records, originally had an
equivalent in paper form,
such as memos (now e-mail), accounting documents (e.g.,
purchase orders, invoices),
personnel documents (e.g., job applications, resumes, tax
documents), contractual
documents, line-of-business documents (e.g., loan applications,
insurance claim forms,
health records), and required regulatory documents (e.g.,
material safety data sheets).
Before e-document and e-record software began to mature in the
1990s, many of these

documents were fi rst archived to microfi lm or
microform/microfi che.
Not all documents rise to the level of being declared a formal
business record that
needs to be retained; that defi nition depends on the specifi c
regulatory and legal re-
quirements imposed on the organization and the internal defi
nitions and requirements
the organization imposes on itself, through internal IG measures
and business policies.
IG is the policies, processes, and technologies used to manage
and control information through-
out the enterprise to meet internal business requirements and
external legal and compliance
demands.
E-records management has become much more critical to
enterprises with in-
creased compliance legislation and massively increasing
volumes of electronic
information.
ERM follows the same basic principles as paper-based
records management.

INFORMATION GOVERNANCE AND RECORDS 149
ERM is a component of enterprise content management (ECM),
just as document
management, Web content management, digital asset
management, enterprise report
management, and several other technology sets are components.
ECM encompasses
all an organization’s unstructured digital content, which means
it excludes structured l
data (i.e., databases). ECM includes the vast majority—over 90
percent—of an organi-
zation’s overall information that must be governed and
managed.
ERM extends ECM to provide control and to manage records
through their life
cycle—from creation to destruction. ERM is used to complete
the life cycle manage-
ment of information, documents, and records.
ERM adds the functionality to complete the management of

information and records by
applying business rules to manage the maintenance,
preservation, and disposition of records.
Both ERM and ECM systems aid in locating and managing the
records and infor-
mation needed to conduct business effi ciently, to comply with
legal and regulatory
requirements, and to effectively destroy (paper) and delete
(digital) records that have
met their retention policy time frame requirement, freeing up
valuable physical and
digital space and eliminating records that could be a liability if
kept.
Records Management Business Rationale
Historically, highly regulated industries, such as banking,
energy, and pharmaceuticals,
have had the greatest need to implement RM programs, due to
their compliance and
reporting requirements. 4 However, over the past decade or
so, increased regulation
and changes to legal statutes and rules have made RM a
business necessity for nearly
every enterprise (beyond very small businesses).

Notable industry drivers include:
■ Increased government oversight and industry regulation.
Government regulations
that require enhanced reporting and accountability were early
business drivers
that fueled the implementation of formal RM programs. This is
true at the
federal and state or provincial level. In the United States, the
Sarbanes–Oxley
Act of 2002 (SOX) created and enhanced standards of fi nancial
reporting and
transparency for the boards and executive management of public
corporations
and accounting fi rms. It also addressed auditor independence
and corporate
governance concerns. SOX imposes fi nes or imprisonment
penalties for non-
compliance and requires that senior offi cers sign off on the
veracity of fi nancial
statements. It states clearly that pertinent business records
cannot be destroyed
during litigation or compliance investigations. Since SOX was
enacted, Japan,

Australia, Germany, France, and India also have adopted stricter
“SOX-like”
governance and fi nancial reporting standards.
ERM includes the management of electronic and
nonelectronic records, such
as paper and other physical records.
■ Changes in legal procedures and requirements during civil
litigation. In 2006, the
need to amend the U.S. Federal Rules of Civil Procedure
(FRCP) to contain
specifi c rules for handling electronically generated evidence
was addressed.
The changes included processes and requirements for legal
discovery of elec-
tronically stored information (ESI) during civil litigation.
Today, e-mail is the
leading form of evidence requested in civil trials. The changes
to the U.S. FRCP
had a pervasive impact on American enterprises and required

them to gain
control over their ESI and implement formal RM and electronic
discovery
(e-discovery) programs to meet new requirements. Although
they have been
ahead of the United States in their development and maturity of
RM practic-
es, Canadian, British, and Australian law is closely tracking that
of the United
States in legal discovery. The United States is a more litigious
society, so this
is not unexpected.
■ IG awareness. IG, in short, is the set of rules, policies, and
business process-
es used to manage and control the totality of an organization’s
information.
Monitoring technologies are required to enforce and audit IG
compliance.
Beginning with SOX in 2002 and continuing with the massive
U.S. FRCP
changes in 2006, enterprises have become more IG aware and
have ramped up
efforts to control, manage, and secure their information. A
signifi cant component

of any IG program is implementing an RM program that specifi
es the retention periods
and disposition (e.g., destruction, transfer, archive) of formal
business records. This
program, for instance, allows enterprises to destroy records
once their required
retention period (based on external regulations, legal
requirements, and inter-
nal IG policies) has been met and allows them to legally destroy
records with
no negative impact or lingering liability.
■ Business continuity concerns. In the face of real disasters,
such as the 9/11 terror-
ist attacks, Hurricane Katrina, and Superstorm Sandy,
executives now realize that
disaster recovery and business resumption must be planned and
prepared for.
Disasters really happen, and businesses that are not well
prepared really go under.
The focus is on vital records that are necessary to resume
operations in the event
of a disaster, and managing those records is part of an overall
RM program.

Why Is Records Management So Challenging?
With these changes in the business environment and in
regulatory, legal, and IG infl u-
ences comes increased attention to RM as a driver for corporate
compliance. For
most organizations, a lack of defi ned policies and the enormous
and growing volumes
A number of factors provide the business rationale for
ERM, including
facilitating compliance, supporting IG, and providing backup
capabilities in
the event of a disaster.
of documents (e.g., e-mail messages) make implementing a
formal RM program chal-
lenging and costly. Some reasons for this include:
■ Changing and increasing regulations. Just when records and
compliance managers

have sorted through the compliance requirements of federal
regulations, new
ones at the state or provincial level are created or tightened
down.
■ Maturing IG requirements within the organization. As senior
managers become
increasingly aware of IG—the rules, policies, and processes that
control and
manage information—they promulgate more reporting and
auditing require-
ments for the management of formal business records.
■ Managing multiple retention and disposition schedules.
Depending on the type of record,
retention requirements vary, and they may vary for the same
type of record based
on state and federal regulations. Further, internal information
governance policies
may extend retention periods and may fl uctuate with
management changes.5
■ Compliance costs and requirements with limited staff. RM
and compliance depart-
ments are notoriously understaffed, since they do not generate

revenue. De-
partments responsible for executing and proving compliance
with new and
increasing regulatory requirements must do so expediently,
often with only
skeletal staffs. This leads to expensive outsourcing solutions or
staff increases.
The cost of compliance must be balanced with the risk of
maintaining a mini-
mum level of compliance.
■ Changing information delivery platforms. With cloud
computing, mobile com-
puting, Web 2.0, social media, and other changes to information
delivery and
storage platforms, records and compliance managers must stay
apprised of the
latest IT trends and provide records on multiple platforms all
while maintain-
ing the security and integrity of organizational records.
■ Security concerns. Protecting and preserving corporate
records is of paramount
importance, yet users must have reasonable access to offi cial
records to conduct

everyday business. “Organizations are struggling to balance the
need to provide
accessibility to critical corporate information with the need to
protect the in-
tegrity of corporate records.” 6
■ Dependence on the IT department or provider. Since tracking
and auditing use of
formal business records requires IT, and records and compliance
departments
typically are understaffed, those departments must rely on
assistance from the
IT department or outsourced IT provider—which often does not
have the
same perspective and priorities as the departments they serve.
■ User assistance and compliance. Users often go their own
way with regard to records,
ignoring directives from records managers to stop storing
shadow fi les of records
on their desktop (for their own convenience) and inconsistently
following directives
to classify records as they are created. Getting users across a
range of departments
in the enterprise to adhere uniformly with records and

compliance requirements is
a daunting and unending task that requires constant attention
and reinforcement. 7
Implementing ERM is challenging because it requires user
support and com-
pliance, adherence to changing laws, and support for new
information deliv-
ery platforms, such as mobile and cloud computing.
Benefi ts of Electronic Records Management
A number of business drivers and benefi ts combine to create a
strong case for imple-
menting an enterprise ERM program. Most are tactical, such as
cost savings, time
savings, and building space savings. But some drivers can be
thought of as strategic , in that c
they proactively give the enterprise an advantage. One example
may be the advantages
gained in litigation by having more control and ready access to

complete business
records, which yields more accurate results and more time for
corporate attorneys to
develop strategies while the opposition is wading through reams
of information, never
knowing if it has found the complete set of records it needs.
Another example is more
complete and better information for managers to base decisions
on.
Implementing ERM represents a signifi cant investment. An
investment in ERM is
an investment in business process automation and yields
document control, document integrity,
and security benefi ts. The volume of records in organizations
often exceeds employees’
ability to manage them. ERM systems do for the information
age what the assembly
line did for the industrial age. The cost/benefi t justifi cation
for ERM is sometimes
diffi cult to determine, although there are real labor and cost
savings. Also, many of the
benefi ts are intangible or diffi cult to calculate but help to
justify the capital investment.
There are many ways in which an organization can gain signifi

cant business benefi ts
with ERM.
More detail on business benefi ts is provided in Chapter 7 ,
but hard, calculable
benefi ts (when compared to storing paper fi les) include offi ce
space savings, offi ce
supplies savings, cutting wasted search time, and reduced offi
ce automation costs (e.g.,
fewer printers, copiers, cutting automated fi ling cabinets).
In addition, implementing ERM will provide the organization
with:
■ Improved capabilities for enforcing IG over business
documents and records
■ Improved, more complete, and more accurate searches
■ Improved knowledge worker productivity
■ Reduced risk of compliance actions or legal consequences
■ Improved records security
■ Improved ability to demonstrate legally defensible RM
practices
■ Increased working confi dence in making searches, which
should improve deci-

sion making
An investment in ERM is an investment in business
process automation and
yields document control, document integrity, and security
benefi ts.
ERM benefi ts are both tangible and intangible or diffi cult
to calculate.
Additional Intangible Benefi ts
The U.S. Environmental Protection Agency (EPA), a pioneer
and leader in e-records im-
plementation in the federal sector, lists some additional benefi
ts of implementing ERM:
1. To control the creation and growth of records. Despite
decades of using vari-
ous nonpaper storage media, the amount of paper in our offi ces
continues

to escalate. An effective records management program addresses
both cre-
ation control (limits the generation of records or copies not
required to
operate the business) and records retention (a system for
destroying useless
records or retiring inactive records), thus stabilizing the growth
of records
in all formats.
2. To assimilate new records management technologies. A
good records manage-
ment program provides an organization with the capability to
assimilate
new technologies and take advantage of their many benefi ts.
Investments
in new computer systems don’t solve fi ling problems unless
current manual
record-keeping systems are analyzed (and occasionally,
overhauled) before
automation is applied.
3. To safeguard vital information. Every organization,
public or private, needs
a comprehensive program for protecting its vital records and

information
from catastrophe or disaster, because every organization is
vulnerable to
loss. Operated as part of the overall records management
program, vital
records programs preserve the integrity and confi dentiality of
the most
important records and safeguard the vital information assets
according to a
“plan” to protect the records.
4. To preserve the corporate memory. An organization’s fi
les contain its institu-
tional memory, an irreplaceable asset that is often overlooked.
Every busi-
ness day, you create the records that could become background
data for
future management decisions and planning. These records
document the
activities of the agency that future scholars may use to research
the work-
ings of the Environmental Protection Agency.
5. To foster professionalism in running the business. A
business offi ce with fi les askew,

stacked on top of fi le cabinets and in boxes everywhere, creates
a poor working
environment. The perceptions of customers and the public, and
“image” and
“morale” of the staff, though hard to quantify in cost-benefi t
terms, may be
among the best reasons to establish a good records management
program.8
Thus, there are a variety of tangible and intangible benefi ts
derived from ERM
programs, and the business rationale that fi ts for your
organization depends on its
specifi c needs and business objectives.
Improved professionalism, preserving corporate memory,
and support for bet-
ter decision making are key intangible benefi ts of ERM.
Inventorying E-Records

According to the U.S. National Archives and Records
Administration (NARA), “In
records management, an t inventory is a descriptive listing of
each record series ory
system, together with an indication of location and other
pertinent data. It is not a list
of each document or each folder but rather of each series or
system ”9 (emphasis added).
Conducting an inventory of electronic records is more
challenging than perform-
ing a physical records inventory, but the purposes are the same:
to ferret out RM
problems and to use the inventory as the basis for developing
the retention schedule.
Some of the RM problems that may be uncovered
include inadequate documentation of offi cial actions, improper
applications
of record-keeping technology, defi cient fi ling systems and
maintenance prac-
tices, poor management of nonrecord materials, insuffi cient
identifi cation of
vital records, and inadequate records security practices. When
completed, the

inventory should include all offi ces, all records, and all
nonrecord materials.
An inventory that is incomplete or haphazard can only result in
an inadequate
schedule and loss of control over records. 10
The fi rst step in gaining control over an organization’s records
and imple-
menting IG measures to control and manage them is to complete
an inventory of
all groupings of business records, including electronic records,
11 at the system or fi le
series level.
The focus of this book is on IG and more granually e-records,
and when it comes
to e-records, NARA has a specifi c recommendation: Inventory
at the computer systems
level. This differs from advice given by experts in the past.
The records inventory is the basis for developing a records
retention schedule
that spells out how long different types of records are to be held
and how they will
be archived or disposed of at the end of their life cycle. But fi

rst you must determine
where business records reside, how they are stored, how many
exist, and how they are
used in the normal course of business.
There are a few things to keep in mind when approaching the e-
records invento-
rying process:
■ Those who create and work with the records themselves are
the best source
of information about how the records are used. They are your
most critical
resource in the inventorying process.
■ RM is something that everyone wants done but no one
wants to do (although
everyone will have an opinion on how to do it).
■ The people working in business units are touchy about
their records. It will
take some work to get them to trust a new RM approach. 12
NARA recommends that electronic records are inventoried
by information sys-

tem, not by record series.
These knowledge workers are your best resource and can be
your greatest allies or
worst enemies when it comes to gathering accurate inventory
data; developing a workable
fi le plan; and keeping the records declaration, retention, and
disposition process operating
effi ciently. A sound RM program will keep the records
inventory accurate and up to date.
Generally Accepted Recordkeeping Principles®
See Chapter 3 for more detail on applicable principles in IG.
To summarize: It may be useful
to use a model or framework to guide your records inventorying
efforts. Such frameworks
could be the D.I.R.K.S. (Designing and Implementing
Recordkeeping Systems) used in
Australia or the Generally Accepted Recordkeeping Principles®
(or “the Principles”) that

originated in the United States at ARMA International. The
Principles are a “framework
for managing records in a way that supports an organization’s
immediate and future regulatory,
legal, risk mitigation, environmental, and operational
requirements. ” 13
Special attention should be given to creating an accountable,
open inventorying
process that can demonstrate integrity. The result of the
inventory should help the or-
ganization adhere to records retention, disposition, availability,
protection, and com-
pliance aspects of The Principles.
The Generally Accepted Recordkeeping Principles were
created with the as-
sistance of ARMA International and legal and IT professionals
who reviewed
and distilled global best practice resources. These included the
international
records management standard ISO15489–1 from the American
National
Standards Institute and court case law. The principles were
vetted through a

public call-for-comment process involving the professional
records informa-
tion management . . . community. 14
E-Records Inventory Challenges
If your organization has received a legal summons for e-
records, and you do not have
an accurate inventory, the organization is already in a
compromising position: You do
not know where the requested records might be, how many
copies there might be, or
the process and cost of producing them. Inventorying must be
done sooner rather than
later and proactively rather than reactively.
E-records present challenges beyond those of paper of microfi
lmed records due to their (elec-
tronic) nature :
1. You cannot see or touch them without searching online, as
opposed to simply
thumbing through a fi ling cabinet or scrolling through a roll of
microfi lm.

What are The Principles? They are guidelines for
information management and
governance of record creation, organization, security,
maintenance, and other
activities used to effectively support the recordkeeping of an
organization.
2. They are not sitting in a central fi le room but rather may
be scattered about
on servers, shared network drives, or on storage attached to
mainframe or
minicomputers.
3. They have metadata attached to them that may distinguish
very similar-
looking records.
4. Additional “shadow” copies of the e-records may exist,
and it is diffi cult to
determine the true or original copy.15

Records Inventory Purposes
The completed records inventory contributes toward the pursuit
of an organization’s IG ob-
jectives in a number of ways : It supports the ownership,
management, and control of s
records; helps to organize and prepare for the discovery process
in litigation; reduces
exposure to business risk; and provides the foundation for a
disaster recovery/business
continuity plan.
Completing the records inventory offers at least eight additional
benefi ts:
1. It identifi es records ownership and sharing relationships,
both internal and
external.
2. It determines which records are physical, electronic, or a
combination of both.
3. It provides the basis for retention and disposition schedule
development.
4. It improves compliance capabilities.
5. It supports training objectives for those handling records.

6. It identifi es vital and sensitive records needing added
security and backup
measures.
7. It assesses the state of records storage, its quality and
appropriateness.
8. It supports the release of information for Freedom of
Information Act (FOIA),
Data Protection Act, and other mandated information release
requirements
for governmental agencies. 16
With respect to e-records, the purpose of the records inventory
should include the
following objectives:
■ Provide a survey of the existing electronic records
situation.
■ Locate and describe the organization’s electronic record
holdings.
■ Identify obsolete electronic records.
■ Determine storage needs for active and inactive electronic
records.
■ Identify vital and archival electronic records, indicating

need for their on-
going care.
■ Raise awareness within the organization of the importance
of electronic
records management.
■ Lead to electronic record keeping improvements that
increase effi ciency.
■ Lead to the development of a needs assessment for future
actions.
■ Provide the foundation of a written records management
plan with a de-
termination of priorities and stages of actions, ensuring the
continuing im-
provement of records management practices. 17
Records Inventorying Steps
NARA’s guidance on how to approach a records inventory

applies to both physical and
e-records.
The steps in the records inventory process are:
1. Defi ne the inventory’s goals. While the main goal is
gathering information for
scheduling purposes, other goals may include preparing for
conversion to
other media, or identifying particular records management
problems.
2. Defi ne the scope of the inventory; it should include all
records and other
materials.
3. Obtain top management’s support , preferably in the form
of a directive, and t
keep management and staff informed at every stage of the
inventory.
4. Decide on the information to be collected (the elements
of the inventory). Ma-d
terials should be located, described, and evaluated in terms of
use.

5. Prepare an inventory form , or use an existing one.
6. Decide who will conduct the inventory, and train them
properly.
7. Learn where the agency’s [or business’s] s fi les are
located , both physically and d
organizationally.
8. Conduct the inventory.
9. Verify and analyze the results. s 18
Goals of the Inventory Project
The goals of the inventorying project must be set and conveyed
to all stakeholders. At a
basic level, the primary goal can be simply to generate a
complete inventory for compli-
ance and reporting purposes. It may focus on a certain business
area or functional group or
on the enterprise as a whole. An enterprise approach requires
segmenting the effort into
smaller, logically sequenced work efforts, such as by busi ness
unit. Perhaps the organization
has a handle on its paper and microfi lmed records but e-records
have been growing exponentially

and spiraling out of control, without good policy guidelines or
IG controls. So a complete inventory
of records and e-records by system is needed, which may
include e-records generated by
application systems, residing in e-mail, created in offi ce
documents and spreadsheets, or
other potential business records. This is a tactical approach that
is limited in scope.
The goal of the inventorying process may be more ambitious:
to lay the ground-
work for the acquisition and implementation of an ERM system
that will manage
the retention, disposition, search, and retrieval of records. It
requires more business
The completed records inventory contributes toward the
pursuit of an organi-
zation’s IG objectives in a number of ways.
process analysis and redesign, some rethinking of business

classifi cation schemes or fi le
plans, and development of an enterprise-wide taxonomy. This
redesign will allow for
more sharing of information and records; faster, easier, and
more complete retrievals;
and a common language and approach for knowledge
professionals across the enter-
prise to declare, capture, and retrieve business records.
The plan may be still much greater in scope and involve more
challenging goals: That
is, the inventorying of records may be the fi rst step in the
process of implementing an orga-
nization-wide IG program to manage and control information by
rolling out ERM and IG
systems and new processes; to improve litigation readiness and
stand ready for e-discovery
requests; and to demonstrate compliance adherence with
business agility and confi dence.
Doing this involves an entire cultural shift in the organization
and a long-term approach.
Whatever the business goals for the inventorying effort, they
must be conveyed to all stake-
holders, and that message must be reinforced periodically and

consistently, and through multiple
means. It must be clearly spelled out in communications and
presented in meetings as
the overarching goal that will help the organization meet its
business objectives. The
scope of the inventory must be appropriate for the business
goals and objectives it targets.
Scoping the Inventory
“With senior-level support, the records manager must decide on
the scope of the re-
cords inventory. A single inventory could not describe every
electronic record in an
organization; an appropriate scope might enumerate the records
of a single program or divi-
sion, several functional series across divisions, or records that
fall within a certain time frame. ”
[emphasis added.] 19 Most organizations have not deployed an
enterprise-wide records
management system, which makes the e-records inventorying
process arduous and
time-consuming. It is not easy to fi nd where all the electronic
records reside—they
are scattered all over the place, and on different media. But

impending (and inevitable)
litigation and compliance demands require that it be done. And,
again, sooner has
been proven to be better than later. Since courts have ruled that
if lawsuits have been
fi led against your competitors over a certain (industry-specifi
c) issue, your organiza-
tion should anticipate and prepare for litigation—which means
conducting records
inventories and placing a litigation hold on documents that
might be relevant. Simply
doing nothing and waiting on a subpoena is an avoidable
business risk.
Whatever the business goals for the inventorying effort
are, they must be con-
veyed to all stakeholders, and that message must be reinforced
periodically
and consistently, and through multiple means.
An appropriate scope might enumerate the records of a
single program or
division, several functional series across divisions, or records
that fall within a
certain time frame.

A methodical, step-by-step approach must be taken—it is the
only way to ac-
complish the task. A plan that divides up the inventorying tasks
into smaller, ac-
complishable pieces is the only one that will work. It has been
said, “How do you
eat an elephant?” And the answer is “One bite at a time.” So
scope the inventorying
process into segments, such as a business unit, division, or
information system/
application.
Management Support: Executive Sponsor
It is crucial to have management support to drive the inventory
process to completion.
There is no substitute for an executive sponsor. Asking
employees to take time out
for yet another survey or administrative task without having an
executive sponsor will

likely not work. Employees are more time-pressed than ever,
and they will need a clear
directive from above, along with an understanding of what role
the inventorying pro-
cess plays in achieving a business goal for the enterprise, if
they are to take the time to
properly participate and contribute meaningfully to the effort.
Information/Elements for Collection
During the inventory you should collect the following
information at a
minimum:
■ What kind of record it is—contracts, fi nancial reports,
memoranda, etc.
■ What department owns it
■ What departments access it
■ What application created the record (e-mail, MS Word,
Acrobat PDF)
■ Where it is stored, both physically (tape, server) and
logically (network
share, folder)
■ Date created

■ Date last changed
■ Whether it is a vital record (mission-critical to the
organization)
■ Whether there are other forms of the record (for example, a
document
stored as a Word document, a PDF, and a paper copy) and which
of them
is considered the offi cial record
Removable media should have a unique identifi er and the
inventory r
should include a list of records on the particular volume as well
as the
characteristics of the volume, e.g., the brand, the recording
format, the
capacity and volume used, and the date of manufacture and date
of last
update.20 (Emphasis added.)
Additional information not included in inventories of
physical records must be
collected in any inventory of e-records.

IT Network Diagram
Laying out the overall topology of the IT infrastructure in the
form of a network
diagram is an exercise that is helpful in understanding where to
target efforts and to
map information fl ows. Creating this map of the IT
infrastructure is a crucial step in
inventorying e-records. It graphically depicts how and where
computers are connected
to each other and the software operating environments of
various applications that are
in use. This high-level diagram does not need to include every
device; rather, it should
indicate each type of device and how it is used.
The IT staff usually has a network diagram that can be used as
a reference; per-
haps after some simplifi cation it can be put into use as the
underpinning for inventory-
ing e-records. It does not need great detail, such as where
network bridges and routers
are located, but it should show which applications are utilizing

the cloud or hosted
applications to store and/or process documents and records.
In diagramming the IT infrastructure for purposes of the
inventory, it is easiest to
start in the central computer room where any mainframe or
other centralized servers
are located and then follow the connections out into the
departments and business unit
areas, where there may be multiple shared servers and drives
supported a network of
desktop personal computers or workstations.
Microsoft’s SharePoint® is a prevalent document and RM
portal platform, and
many organizations have SharePoint servers to house and
process e-documents and
records. Some utilities and tools may be available to assist in
the inventorying process
on SharePoint systems.
Mobile devices (e.g., tablets, smartphones, and other portable
devices) that are
processing documents and records should also be represented.
And any e-records re-

siding in cloud storage should also be included.
Creating a Records Inventory Survey Form
The record inventory survey form must suit its purpose. Do not
collect data that is ir-
relevant, but, in conducting the survey, be sure to collect all the
needed data elements.
You can use a standard form, but some customization is
recommended. The sample
records survey form in Figure 9.1 is wide ranging yet
succinct and has been used suc-
cessfully in practice.
If conducting the e-records portion of the inventory, the
sample form may be
somewhat modifi ed, as shown in Figure 9.2 .
Who Should Conduct the Inventory?
Typically, a RM project team is formed to conduct the survey,
often assisted by re-
sources outside of the business units. These may be RM and IT
staff members, business
analysts, members of the legal staff, outside specialized

consultants, or a combination
of these groups. The greater the cross-section from the
organization, the better, and
the more expertise brought to bear on the project, the more
likely it will be completed
thoroughly and on time.
Critical to the effort is that those conducting the inventory are
trained in the
survey methods and analysis, so that when challenging issues
arise, they will have the
resources and know-how to continue the effort and get the job
done.
Department Information
1. What is the reporting structure of the department?
2. Who is the department liaison for the records inventory?
3. Who is the IT or business analyst liaison?

Record Requirements
4. Are there any external agencies that impose guidelines,
standards or other requirements?
5. Are there specifi c legislative requirements for creating or
maintaining records? Please provide a copy.
6. Is there a departmental records retention schedule?
7. What are the business considerations that drive
recordkeeping? Regulatory requirements? Legal
requirements?
8. Does the department have an existing records management
policy? Guidelines? Procedures?
Please provide a copy.
9. Does the department provide guidance to employees on what
records are to be created?
10. How are policies, procedures and guidance disseminated to
the employees?

11. What is the current level of employees’ awareness of their
responsibilities for records
management?
12. How are nonrecords managed?
13. What is the process for ensuring compliance with policies,
procedures, and guidelines?
When an employee changes jobs/roles or is terminated?
14. Does the department have a classifi cation or fi le plans?
15. Are any records in the department confi dential or sensitive?
16. What information security controls does the department
have for confi dential or sensitive
records?
17. Does the department have records in sizes other than letter
(8½×11)?
18. What is the cutoff date for the records?
Fiscal Year Calendar Year Other

19. Have department vital records been identifi ed?
20. Is there an existing business or disaster recovery policy?
21. Is the department subject to audits? Internal? External? Who
conducts the audits?
22. Where and how are records stored?
Online? Near Line? Offl ine? On-site? Off-site? One location?
Multiple locations?
23. How does the department ensure that records will remain
accessible, readable, and useable
throughout their scheduled retention period?
Technology and Tools
24. Are any tools used to track active records? Spreadsheets,
word documents, databases, and so
forth?
25. Are any tools used to track inactive records? Spreadsheets,
word documents, databases, and so

forth?
26. Does the department use imaging, document management,
and so forth?
Disposition
27. Are there guidelines for destroying obsolete records?
Figure 9.1 Records Inventory Survey Form
(continued )
Identifying Information
1. Name of system.
2. Program or legal authority for system.
3. System identifi cation or control number.

4. Person responsible for administering the system. Include e-
mail, offi ce address, and phone
contact info.
5. Date system put in service.
6. Business unit or agency supported by system.
7. Description of system (what does the application software
do?).
8. Purpose of system.
System Inputs/Outputs
9. Primary sources of data inputs.
10. Major outputs of system (e.g., specifi c reports).
11. Informational content (all applicable): Description of data;
applicability of data (people, places,
things); geographic information; time span; update cycle;
applications the system supports; how
data are manipulated; key unit analysis for each fi le; public use
or not?

12. Hardware confi guration.
13. Software environment, including revision levels, operating
system, database, and so forth.
14. Indices or any classifi cation scheme/fi le plan that is in
place?
15. Duplicate records? Location and volume of any other
records containing the same information.
Record Requirements
16. Are there any external agencies that impose guidelines,
standards, or other requirements?
17. Are their specifi c legislative requirements for creating or
18. Is there a departmental records retention schedule?
19. What are the business considerations that drive
recordkeeping? Regulatory requirements? Legal
requirements?

20. Does the department have an existing records management
policy? Guidelines? Procedures? If
so, please provide a copy.
28. What disposition methods are authorized or required?
29. How does disposition occur? Paper? Electronic? Other?
30. What extent does the department rely on each individual to
destroy records? Paper? Electronic?
Other?
Records Holds
31. What principles govern decisions for determining the scope
of records that must be held or
frozen for an audit or investigations?
32. How is the hold or freeze communicated to employees?
33. How are records placed on hold protected?
Figure 9.2 Electronic Records Inventory Survey Form

Figure 9.1 (continued )
Source: Charmain Brooks, IMERGE Consulting, e-mail to
author, March 20, 2012.
Determine Where Records Are Located
The inventory process is, in fact, a surveying process, and it
involves going physically
out into the units where the records are created, used, and
stored. Mapping out where
the records are geographically is a basic necessity. Which
buildings are they located in?
Which offi ce locations? Computer rooms?
Also, the inventory team must look organizationally at where
the records reside (i.e., de-y
termine which departments and business units to target and
prioritize in the survey process).
Conduct the Inventory

Several approaches can be taken to conduct the inventory,
including three basic methods:
1. Distributing and collecting surveys
2. Conducting in-person interviews
3. Direct observation
21. How are nonrecords managed?
22. Are any records in the department confi dential or sensitive?
How are they indicated or set apart?
23. What information security controls does the department
have for confi dential or sensitive
records?
24. What is the cutoff date for the records?
25. Have department vital records been identifi ed?
26. Is there an existing business or disaster recovery policy?

27. Is the department subject to audits? Internal? External? Who
28. Where and how are records stored?
Online? Near line? Offl ine? On-site? Off-site? One location?
Multiple locations?
29. How does the department ensure that records will remain
accessible, readable, and useable
throughout their scheduled retention period?
Disposition
30. Are there guidelines for destroying obsolete records?
31. What disposition methods are authorized or required?
32. How does disposition occur? Are electronic deletions verifi
ed?
33. What extent does the department rely on each individual to
destroy e-records?
Records Holds

34. What principles govern decisions for determining the scope
of records that must be held or
frozen for an audit or investigations?
35. How is the hold or freeze communicated to employees?
36. How are records placed on hold protected?
Figure 9.2 (continued )
Source: Adapted from: www.archives.gov/records-
mgmt/faqs/inventories.html and Charmaine
Brooks, IMERGE Consulting.
http://www.archives.gov/records-mgmt/faqs/inventories.html
Creating and distributing a survey form is traditional and
proven way to collect
e-records inventory data. This is a relatively fast and
inexpensive way to gather the
inventory data. The challenge is getting the surveys completed

in a consistent fashion.
This is where a strong executive sponsor can assist. The sponsor
can make the survey a
priority and tie it to business objectives, making the survey
completion compulsory. The
survey is a good tool, and it can be used to cover more ground
in the data collection pro-
cess. If following up with interviews, the survey form is a good
starting point; responses
can be verifi ed and clarifi ed, and more detail can be gathered.
Some issues may not be entirely clear initially, so following up
with scheduled in-
person interviews can dig deeper into the business processes
where formal records are
create and used. A good approach is to have users walk you
through their typical day
and how they access, use, and create records—but be sure to
interview managers too,
as managers and users have differing needs and uses for
records. 21
You will need some direction to conduct formal observation,
likely from IT staff
or business analysts familiar with the recordkeeping systems

and associated business
processes. They will need to show you where business
documents and records are
created and stored. If there is an existing ERM system or other
automated search and
retrieval tools available, you may use them to speed the
inventorying process.
When observing and inventor ying e-records, starting in the
server room and
working outward toward the end user is a logical approach.
Begin by enumerating the
e-records created by enterprise software applications (such as
accounting, enterprise
resource planning, or customer relationship management
systems), and work your way
to the departmental or business unit applications, on to shared
network servers, then
fi nally out to individual desktop and laptop PCs and other
mobile devices. With to-
day’s smartphones, this can be a tricky area, due to the variety
of platforms, operating
systems, and capabilities. In a bring-your-own-device
environment, records should not
be stored on personal devices, but if they must be, they should

be protected with tech-
nologies like encryption or information rights management.
There are always going to be thorny areas when attempting to
inventory e-records to
determine what fi les series exist in the organization. Mobile
devices and removable media
may contain business records. These must be identifi ed and
isolated, and any records on
these media must be recorded for the inventory. Particularly
troublesome are thumb or
fl ash drives, which are compact yet can store 20 gigabytes of
data or more. If your IG
measures call for excluding these types of media, the ports they
use can be blocked on PCs,
tablets, smartphones, and other mobile computing devices. A
sound IG program will con-
sider the proper use of removable media and the potential
impact on your RM program.22
The best approach for conducting the inventory is to combine
the available inventorying
methods, where possible. Begin by observing, distribute
surveys, collect and analyze them,
and then target key personnel for follow-up interviews and

walk-throughs. Utilize
whatever automated tools are available along the way. This
approach is the most com-
plete. Bear in mind that the focus is not on individual electronic
fi les but rather, the fi le series
level for physical records and the fi le series or system level for
e-records (preferably the latter).
There are three ways to conduct the inventory: surveys,
interviews, and
observation. Combining these methods yields the best results.
Interviewing Programs/Service Staff
Interviews are a very good source of records inventory
information. Talking with actual
users will help the records lead or inventory team to better
understand how documents
and records are created and used in everyday operations. Users
can also report why they
are needed—an exercise that can uncover some obsolete or
unnecessary processes and

practices. This is helpful in determining where e-records reside
and how they are grouped
in records series or by system and ultimately, the proper length
of their retention period
and whether they should be archived or destroyed at the end of
their useful life. 23
Since interviewing is a time-intensive task, it is crucial that
some time is spent in
determining the key people to interview: Interviews not only
take your time but oth-
ers’ as well, and the surest way to lose momentum on an
inventorying project is to have
stakeholders believe you are wasting their time.
You need to interview representatives from all functional areas
and levels of
the program or service, including:
■ managers
■ supervisors
■ professional/technical staff
■ clerical/support staff
The people who work with the records can best describe to you

their use.
They will likely know where the records came from, whether
copies exist,
who needs the records, any computer systems that are used, how
long the
records are needed and other important information that you
need to know
to schedule the records.
Selecting Interviewees
As stated earlier, it is wise to include a cross-section of staff,
managers and frontline
employees to get a rounded view of how records are created and
used. Managers have
a different perspective and may not know how workers utilize
electronic records in
their everyday operations.
A good lens to use is to focus on those who make decisions
based on informa-
tion contained in the electronic records and to follow those
decision-based processes
through to completion, observing and interviewing at each
level.

For example, an application is received (mail room logs date
and time), checked
(clerk checks the application for completeness and enters into a
computer sys-
tem), verifi ed (clerk verifi es that the information on the
application is correct),
and approved (supervisor makes the decision to accept the
application). These
staff members may only be looking at specifi c pieces of the
record and making
decisions on those pieces.
Interview Scheduling and Tips
One rule to consider is this: Be considerate of other people’s
work time. Since they
are probably not getting compensated for participating in the
records inventory, the
time you take to interview them is time taken away from
compensated tasks they are
evaluated on. So, once the interviewees are identifi ed, provide

as much advance notice
as possible, follow up to confi rm appointments, and stay within
the scheduled time.
Interviews should be kept to 20 to 60 minutes. Most of all —
never be late!
Before starting any interviews, be sure to restate the goals and
objectives of the
inventorying process and how the resulting output will benefi t
people in their jobs.
In some cases, it may be advisable to conduct interviews in
small groups, not only
to save time but to generate a discussion of how records are
created, used, and stored.
Some new insights may be gained.
Try to schedule interviews that are as convenient as possible
for participants. That
means providing participants with questions in advance and
holding the interviews as
close to their work area as possible. Do not schedule interviews
back to back with no
time for a break between. You will need time to consolidate
your thoughts and notes,

and, at times, interviews may exceed their planned time if a
particularly enlightening
line of questioning takes place.
If you have some analysis from the initial collection of surveys,
share that with the
interviewees so they can validate or help clarify the preliminary
results. Provide it in
advance, so they have some time to think about it and discuss it
with their peers.
Sample Interview Questionnaire
You’ll need a guide to structure the interview process. A good
starting point is the
sample questions presented in the questionnaire shown in Figure
9.3 . It is a useful tool
that has been used successfully in actual records inventory
projects.
Analyze and Verify the Results
Once collected, some follow-up will be required to verify and
clarify responses. Often
this can be done over the telephone. For particularly complex
and important areas, a

follow-up in person visit can clarify the responses and gather
insights.
Once the inventory draft is completed, a good practice is to go
out into the
business units and/or system areas and verify what the fi ndings
of the survey are.
Once presented with fi ndings in black and white, key
stakeholders may have ad-
ditional insights that are relevant to consider before fi nalizing
the report. Do not
miss out on the opportunity to allow power users and other key
parties to provide
valuable input.
Be sure to tie the fi ndings in the fi nal report of the records
inventory to the business goals
that launched the effort. This helps to underscore the purpose
and importance of the
effort, and will help in getting that fi nal signoff from the
executive sponsor that states
the project is complete and there is no more work to do.
Depending on the magnitude of the project, it may (and should
) turn into a dd

formal IG program that methodically manages records in a
consistent fashion in
accordance with internal governance guidelines and external
compliance and legal
demands.
Be sure to tie the fi ndings in the fi nal report of the
records inventory to the
business goals that launched the effort.
What is the mandate of the offi ce?
What is the reporting structure of the department?
Who is the department liaison for the records inventory?
Are there any external agencies that impose guidelines,
standards, or other requirements?
Is there a departmental records retention schedule?

Are there specifi c legislative requirements for creating or
What are the business considerations that drives record
keeping? Regulatory requirements? Legal
requirements?
Does the department have an existing records management
policy? Guidelines? Procedures?
Please provide a copy.
Does the department provide guidance to employees on what
records are to be created?
What is the current level of awareness of employees their
responsibilities for records management?
How are nonrecords managed?
Does the department have a classifi cation or fi le plans?
What are the business drivers for creating and maintaining
records?

Where are records stored? Onsite? Offsite? One location?
Multiple locations?
Does the department have records in sizes other than letter (8
½×11)?
What is the cutoff date for the records?
Are any tools used to track active records? Excel, Access, and
so forth?
Does the department use imaging, document management, and
so forth?
Is the department subject to audits? Internal? External? Who
Are any records in the department confi dential or sensitive?
Are their guidelines for destroying obsolete records?
What disposition methods are authorized or required?

How does disposition occur? Paper? Electronic? Other?
What extent does the department rely on each individual to
destroy records?
Paper Electronic Other
What principles govern decisions for determining the scope of
records that must be held or frozen for
an audit or investigations?
How is the hold or freeze communicated to employees?
Figure 9.3 Sample Interview Questionnaire
Appraising the Value of Records
Part of the process of determining the retention and disposition
schedule of records
is to appraise their value. Records can have value in different
ways, which affects
retention decisions.
Records appraisal is an analysis of all records within an agency
[or business]
to determine their administrative, fi scal, historical, legal, or

other archival value.
The purpose of this process is to determine for how long, in
what format, and
Source: Charmaine Brooks, IMERGE Consulting, e-mail to
author, March 20, 2012.
under what conditions a record series ought to be preserved.
Records appraisal is
based upon the information contained in the records inventory.
Records series shall be
either preserved permanently or disposed of when no longer
required for the
current operations of an agency or department, depending upon:
■ Historical value or the usefulness of the records for
historical research, in-
cluding records that show an agency [or business] origin,
administrative
development, and present organizational structure.

■ Administrative value or the usefulness of the records for
carrying on [a busi-
ness or] an agency’s current and future work, and to document
the develop-
ment and operation of that agency over time.
■ Regulatory and statutory [value to meet] requirements.
■ Legal value or the usefulness of the records to document and
defi ne legally
enforceable rights or obligations of [business owners,
shareholders, or a]
government and/or citizens.
■ Fiscal value or the usefulness of the records to the
administration of [a busi-
ness or] an agency’s current fi nancial obligations, and to
document the de-
velopment and operation of that agency over time
■ Other archival value as determined by the State [or
corporate] Archivist. 24
(Emphasis added.)
Ensuring Adoption and Compliance of RM Policy

The inventorying process in not a one-shot deal: It is useful
only if the records inven-
tory is kept up to date, so it should be reviewed, at least
annually. A process should be
put in place so that business unit or agency heads notify the RM
head/lead if a new fi le
series or system has been put in place and new records
collections are created. 25
[Five] tips can help ensure that a records management program
achieves its goals:
1. Records management is everyone’s role. The volume
and diversity of business
records, from e-mails to reports to tweets, means that the person
who cre-
ates or receives a record is in the best [position] to classify it.
Everyone in
the organization needs to adopt the records management
program.
2. Don’t micro-classify. Having hundreds, or possibly
thousands, of records clas-
sifi cation categories may seem like a logical way to organize

the multitude
of different records in a company. However, the average
information
worker, whose available resources are already under pressure,
does not
want to spend any more time than necessary classifying records.
Having a
few broad classifi cations makes the decision process simpler
and faster.
Records appraisal is based on the information contained in
the records
inventory.
3. Talk the talk from the top on down. A culture of
compliance starts at the top.
Businesses should establish a senior-level steering committee
comprised
of executives from legal, compliance, and information
technology (IT). A
committee like this signals the company’s commitment to

compliant re-
cords management and ensures enterprise adoption.
4. Walk the walk, consistently. For compliance to become
second nature, it
needs to be clearly communicated to everyone in the
organization, and
policies and procedures must be accessible. Training should be
rigorous
and easily available, and organizations may consider rewarding
compliance
through fi nancial incentives, promotions and corporate-wide
recognition.
5. Measure the measurable. The ability to measure
adherence to policy and
adoption of procedures should be included in core business
operations and
audits. Conduct a compliance assessment, including a gap
analysis, at least
once a year, and prepare an action plan to close any identifi ed
holes.
The growth of data challenges a company’s ability to use and
store its records

in a compliant and cost-effective manner. Contrary to current
practices, the
solution is not to hire more vendors or to adopt multiple
technologies. The
key to compliance is consistency, with a unifi ed enterprise-
wide approach for
managing all records, regardless of their format or location. 26
So a steady and consistent IG approach that includes controls,
audits, and clear
communication is key to maintaining an accurate and current
records inventory.
General Principles of a Retention Scheduling
We discussed records retention briefl y in Chapter 8 , mostly
as it relates to legal research
and determining retention and limitation periods. In this section
we go more in depth.
A series of principles is common to all retention schedules: 27
■ The retention schedule must include all records.
■ Records scheduling includes all records, regardless of
media or location.28

■ All legal and regulatory requirements for records must be
refl ected in the records
scheduling process. For public entities, retention scheduling
fosters and enables
the agency to comply with information requests (e.g., FOIA in
the United States,
Freedom of Information Act 2000 in the United Kingdom,
Freedom of Informa-
tion and Protection of Privacy Act and the Health Information
Act in Canada,
and Freedom of Information Amendment [Reform] Act 2010 in
Australia).
■ Records scheduling is a “proactive” planning process,
where schedules are set
in place and standardized in advance.
■ Periodic review of the retention schedule must take place
when signifi cant leg-
islation, technology acquisitions, or other changes are being
considered; but in
any case this should be at least annually or biannually.
■ Records scheduling is a continuous process that needs

updating and amending,
based on legal, technology, or business changes over time.
■ Classifi cation and records scheduling are inextricably
linked.
Records retention defi nes the length of time that records
are to be kept and
considers legal, regulatory, operational, and historical
requirements. 31
■ File series with similar characteristics or value should be
assigned consistent
and appropriate retention periods.
■ Records of historical value must be preserved.
■ Records retention periods should refl ect the business
needs of users, the value
of the records, and any legal or compliance requirements. The
best way to

make these determinations is with a team that includes cross-
functional rep-
resentatives from RM, legal, risk, compliance, IT and business
unit representa-
tives, headed by an executive sponsor.
■ RM resource use is optimized, and costs are minimized by
keeping records a
minimum amount of time under a planned and controlled set of
processes.
■ Records must be retained in a repository (fi le room or
software system)
where the record is protected (e.g., made read-only and
monitored with an
audit trail) so that the integrity of the record is maintained in a
manner that
meets all evidence and legal admissibility standards if or when
litigation is
encountered.
■ Senior management must approve of and sign off on the
retention schedule and
will be legally accountable for compliance with the schedule.

■ Senior management must be able to readily review
retention schedules, policy
documentation, and audit information to ensure users are in
compliance with
the retention schedule.
■ Complete documentation of scheduling requirements and
activities must take
place so that future users and archivists can view and track
changes to the reten-
tion schedule. 29
Developing a Records Retention Schedule
A records retention schedule defi nes the length of time that
records are to be kept and
requirements. 30 The retention schedule
also includes direction as to how the length of time is calculated
(i.e., the event or
trigger that starts the clock [e.g., two years from completion of
contract]). Legal re-
search and opinions are required, along with consultation with
owners and users of
the records. Users typically overestimate the time they need to

keep records, as they
confuse the legal requirements with their own personal wishes.
Some hard question-
ing has to take place, since having these records or copies of
records lying around the
organization on hard drives, thumb drives, or in fi le cabinets
may create liabilities for
the organization.
Disposition means not just destruction but also can mean
archiving and trans-
fer and a change in ownership and responsibility for the records.
The processes of
archiving and preserving are an example where records may be
handed over to a his-
torical recordkeeping unit. At this time, the records may be
sampled and only selective
parts of the group of records may be retained.
A retention schedule allows for uniformity in the retention
and disposition

process, regardless of the media or location of the records.
Disposition means not just destruction but can also mean
archiving and a
Why Are Retention Schedules Needed?
A retention schedule allows for uniformity in the retention and
disposition process, regardless of
the media or location of the records. Further, it tracks, enforces,
and audits the retention and
disposition of records while optimizing the amount of records
kept to legal minimums,
which saves on capital and labor costs, and reduces liability (by
discarding unneeded re-
cords that carry legal risk). 32 The Generally Accepted
Recordkeeping Principles® state
the critical importance of having a retention schedule (see the
section “Generally Accepted
Recordkeeping Principles” in Chapter 3 for more details) and
provide guidelines for open
collaboration in developing one. In the public sector, holding
records that have passed
their legally required retention period also can have negative

ramifi cations and liabilities
in meeting information service requests made during litigation,
compliance actions, or, for
example, under the U.S. FOIA, or similar acts in other
countries.
Information Included on Retention Schedules
A retention schedule consists of these components:
■ Title of the record series
■ Descriptions of the records seriess
■ Offi ce responsible for the retention of the record (default is
usually the offi ce of origin)e
■ Disposal decision —destroy, transfer to the archives, or, in
exceptional circum-
stances, reconsider at a later (specifi ed) date
■ Timing of disposal —a minimum period for which the
records should be retainedll
in the offi ce or in an off-site store before disposal action is
undertaken
■ Event that triggers the disposal actions
■ Dates on which the schedule was agreed , signed, or modifi

ed d
■ Legal citations or a link to a citation that reference the
retention requirements of
that group of records
A sample of a simple records retention schedule is shown in
Figure 9.4 .
Steps in Developing a Records Retention Schedule
If you already have existing retention schedules but are
revising and updating them,
there may be useful information in those schedules that can
serve as a good reference
point—but be wary, as they may be out of date and may not
consider current legal
requirements and business needs.
According to the U.S. National Archives, some key steps are

involved in develop-
ing retention schedules:
1. Review the functions and recordkeeping requirements for
the [business unit
or] agency or the organizational component of the agency whose
records will
be included on the schedule
2. Inventory the records.
3. Determine the period of time the records are needed for
conducting [business
or] agency operations and meeting legal obligations
4. Draft disposition instructions including:
■ File cutoffs or fi le breaks (convenient points within a fi
ling plan/system
(end of a letter of the alphabet, end of year or month, etc.) at
which fi les
are separated for purposes of storage and/or disposition)
■ Retention periods for temporary records
■ Instructions for transferring permanent records to the
National Archives

of the United States [or corporate archive for businesses]
■ Instructions for sending inactive records to off-site storage
■ Organize the schedule and clear it internally
■ Obtain approval from [your corporate archivist or] NARA
[for federal
agencies], as well as from GAO if required by Title 8 of the
GAO, “Policy
and Procedures Manual for the Guidance of Federal Agencies.”
33
Records Retention Schedule ENVIRONMENTAL HEALTH
AND
SAFETY
December 10, 2015
Record Type Responsible
Department
Event Retention
Period
Accident/Injury Reports

Employee Medical Files
Includes:
Accidents
Diagnosis (Accident or Injury)
First aid reports
Injuries
Medical reviews
Occupational Health Incident
Treatment and Progress (Accident or Injury)
Work related accidents
Workers health information
Workers Compensation Claims
Includes:
Audiology
Lung Function
Return to Work Authorization
Related to:
Employee Files (Active)
Health and Safety Programs
Includes:
Health and Safety Committee

Health and Safety Reports
HR Date of Incident E+30
HR Termination E+30
Health and
Safety
CY+10
Figure 9.4 Sample Records Retention Schedule
Source: IMERGE Consulting, Inc.
What Records Do You Have to Schedule?
Inventory and Classifi cation
Inventory and classifi cation are prerequisites for compiling a
retention schedule. Be-
fore starting work, develop an information map that shows

where information is cre-
ated, where it resides, and the path it takes. What records are
created, who uses them,
and how is their disposition handled? Questions like these will
provide key insights in
the development of the retention schedule. 34 Confi rm that the
information map covers
all the uses of the records by all parts of the organization,
including use for account-
ability, audit, and reference purposes.
In the absence of a formal information map, at a minimum you
must compile a list of
all the different types of records in each business area. This list
should include information
about who created them and what they are used for (or record
provenance ), which
parts of the organization have used them subsequently and for
what purpose (its us-
age), and the actual content.t
In the absence of any existing documentation or records
inventory, you will need to conduct
a records inventory or survey to fi nd out what records the
business unit (or organization)

holds. Tools are available to scan e-records folders to expedite
the inventory process. A
retention schedule developed in this way will have a shorter
serviceable life than one
based on an information map because it will be based on
existing structures rather than
functions and will remain usable only as long as the
organizational structure remains
unchanged.
Once a records inventory or survey is complete, building a
records retention
schedule begins with classifi cation of records. 35
This basic classifi cation can be grouped into three areas:
1. Business functions and activities
2. Records series
3. Document types
Business functions are basic business units such as accounting,
legal, human re-
sources, and purchasing. (See Appendix A, Information
Organization and Classifi cation:
Taxonomies and Metadata, for details on the process of

developing classifi cations.) It
basically answers this question: What were you doing when you
created the record?
Tools are available to scan e-records folders to expedite
the inventory process.
An information map is a critical fi rst step in developing a
records retention
schedule. It shows where information is created, where it
resides, and who
uses it.
Business activities are the tasks performed to accomplish the
business function. d
Several activities may be associated with each function.
A records series is a group or unit of identical or related
records that are normally used
and fi led as a unit and that can be evaluated as a unit or
business function for scheduling t

purposes. 36
A document type is a term used by many software systems to
refer to a group-
ing of related records. When the records are all created by
similar processes, then
the document type is equivalent to the business functions or
activities mentioned
previously. However, “document type” often refers to the
format of the record (e.g.,
presentation, meeting minutes). In this case, there is not enough
information to
determine a retention period because it is ambiguous regarding
what type of work
was being done when that document was created. Retention
schedules require that
record series be defi ned by business function and activity, not
by record format or
display type.
Rationale for Records Groupings
Records are grouped together for fundamental reasons to
improve information orga-
nization and access. These reasons include:

■ Grouping by “similar theme” for improved completeness
■ Improving information search speed and completeness
■ Increasing organizational knowledge and memory by
providing the “context”
within which individual documents were grouped
■ Clearly identifying who the record owner or creator is and
assigning and track-
ing responsibility for a group of records
■ Grouping records with the same retention requirements for
consistent applica-
tion of disposition processes to records
Records Series Identifi cation and Classifi cation
After completing a records inventory including characterizing,
descriptive informa-
tion about the records such as their contents, use, fi le size, and
projected growth vol-
umes, you will need to interview staff in those target areas you
are working with to
determine more information about the specifi c organizational

structure, its business
functions, services, programs, and plans. 37
In the course of business, there are several different types of
records series. There
are case records , for example, which are characterized as
having a beginning and
After completing an inventory, developing a retention
schedule begins with
records classifi cation.
an end but are added to over time. Case records generally have
titles that include
names, dates, numbers, or places. These titles do not provide
insight into the nature
of the function of the record series. Examples of case records
include personnel fi les,
mortgage loan folders, contract and amendment/addendum
records, accident reports,
insurance claims, and other records that accumulate and expand

over time. Although
the contents of case fi les may be similar, you should break out
each type of case record
under a unique title.
Subject records (also referred to as topic or function records
) “contain infor-
mation relating to specifi c or general topics and that are
arranged according to their
informational content or by the function/activity/transaction
they pertain to.”38 These
types of records accumulate information on a particular topic or
function to be added
to the organization’s memory and make it easier for knowledge
workers to fi nd infor-
mation based on subject matter, topics, or business functions.
Records such as those on
the progression of relevant laws and statutes, policies, standard
operating procedures,
education and training have long-term reference value and
should be kept until they
are no longer relevant or are displaced by more current and
relevant records. In a
record retention schedule, the trigger event often is defi ned as
“superseded or obsolete.”

Records of this type that relate to “routine operations of a
[project], program or ser-
vice” do not have as much enduring value and should be
scheduled to be kept for a
shorter period.
Retention of E-Mail Records
Are e-mail messages records? This question has been debated
for years. The short an-
swer is no, not all e-mail messages constitute a record. But how
do you determine whether
certain messages are a business record or not? The general
answer is that a record
documents a transaction or business-related event that may have
legal ramifi cations
or historic value. Most important are business activities that
may relate to compliance
requirements or those that could possibly come into dispute in
litigation. Particular
consideration should be given to fi nancial transactions of any
type.
Certainly evidence that required governance oversight or
compliance activities

have been completed needs to be documented and becomes a
business record. Also,
business transactions, where there is an exchange of money or
the equivalent in
goods or services is documented are also business records.
Today, these transactions
are often documented by a quick e-mail. And, of course, any
contracts (and any pro-
gressively developed or edited versions) that are exchanged
through e-mail become
business records.
The form or format of a potential record is irrelevant in
determining whether
it should be classifi ed as a business record. For instance, if a
meeting of the board of
directors is recorded by a digital video recorder and saved to
DVD, it constitutes a
Not all e-mail messages are records; those that document a
business transac-
tion or progress toward it are clearly records and require
retention.

record. If photographs are taken of a ground-breaking ceremony
for a new manufac-
turing plant, the photos are records too. If the company’s
founders tape-recorded a
message to future generations of management on reel-to-reel
tape, it is a record also,
since it has historical value. But most records are going to be in
the form of paper,
microfi lm, or an electronic document.
Here are three guidelines for determining whether an e-mail
message should be
considered a business record:
1. The e-mail documents a transaction or the progress toward
an ultimate transaction
where anything of value is exchanged between two or more
parties. All parts or char-
acteristics of the transaction, including who (the parties to it),
what, when, how
much, and the composition of its components are parts of the
transaction. Often

seemingly minor parts of a transaction are found buried within
an e-mail mes-
sage. One example would be a last-minute discount offered by a
supplier based
on an order being placed or delivery being made within a specifi
ed time frame.
2. The e-mail documents or provides support of a business
activity occurring that pertains
to internal corporate governance policies or compliance to
externally mandated
regulations.
3. The e-mail message documents other business activities
that may possibly be disputed
in the future, whether it ultimately involves litigation or not.
(Most business
disputes actually are resolved without litigation, provided that
proof of your
organization’s position can be shown.) For instance, your
supplier may dispute
the discount you take that was offered in an e-mail message
and, once you
forward the e-mail thread to the supplier, it acquiesces.

Managing e-mail business records is challenging, even for
technology professionals.
According to an AIIM and ARMA survey, fully two-thirds of
records managers doubt that
their IT departments really understand the concept of electronic
records life cycle management.
That is despite the fact that 70 percent of companies rely on IT
professionals alone to manage
their electronic records.
Although the signifi cance of e-mail in civil litigation cannot
be overstated (it is the
leading piece of evidence requested at civil trials today), one -
third of IT managers state
that they would be incapable of locating and retrieving e-mails
that are more than one year old, d
according to Osterman Research. 39
How Long Should You Keep Old E-Mails?
There are different schools of thought on e-mail retention
periods and retention schedules.
The retention and deletion of your electronic business records
may be governed by laws or
regulations. Unless your organization’s e-mail and ESI records

are governed by law or regulations,
E-mail messages that document business activities,
especially those that may
be disputed in the future, should be retained as records.
your organization is free to determine the retention periods and
deletion schedules that are most
appropriate for your organization.40 If your organization’s e-
mail retention periods are not
specifi ed by law or regulation, consider keeping them for at
least as long as you retain
paper records. Many software providers provide automated
software that allows e-mail
messages to be moved to controlled repositories as they are
declared to be records.
Destructive Retention of E-Mail
(We repeat this short section from Chapter 8 for those who
are more focused on RIM

than on legal functions.)
A destructive retention program is an approach to e-mail
archiving where e-mail
messages are retained for a limited time (say, 90 days),
followed by the permanent
manual or automatic deletion of the messages from the
organization network, so long
as there is no litigation hold or the e-mail has not been declared
a record.
E-mail retention periods can vary from 90 days to as long as
seven years:
■ Osterman Research reports that “nearly one-quarter of
companies delete e-
mail after 90 days.” 41
■ Heavily regulated industries, including energy, technology,
communications,
and real estate, favor archiving for one year or more, according
to Fulbright
and Jaworski research. 42
■ The most common e-mail retention period traditionally has

been seven years; how-
ever, some organizations are taking a hard-line approach and
stating that e-mails
will be kept for only 90 days or six months, unless it is declared
as a record, classi-
fi ed, and identifi ed with a classifi cation/retention category
and tagged or moved to
a repository where the integrity of the record is protected (i.e.,
the record cannot be
altered and an audit trail on the history of the record’s usage is
maintained)
Long-Term Archival Records
Inactive records that are have historical value or are essential
for maintaining corporate
memory must be kept the longest. Although they are not needed
for present operations,
they still have some value to the organization and must be
preserved. When it comes to
preserving electronic records, this process can be complex and
technical. (See Chapter
17 for details.) If you have a corporate or agency archivist,
his or her input is critical.43

Meeting Legal Limitation Periods
(This short section is repeated from Chapter 8 for those who
are more focused on
RIM than on legal functions.)
Destructive retention of e-mail is a method whereby e-mail
messages are re-
tained for a limited period and then destroyed.
A key consideration in developing retention schedules is
researching and deter-
mining the minimum time required to keep records that may be
demanded in legal
actions. “A limitation period is the length of time after which
a legal action cannot be
brought before the courts. Limitation periods are important
because they determine
the length of time records must be kept to support court action
[including subsequent
appeal periods]. It is important to be familiar with the purpose,

principles, and special
circumstances that affect limitation periods and therefore
records retention.” 44
Legal Requirements and Compliance Research
(Note: This section also appears in Chapter 8 but is included
here for completeness.)
Legal requirements trump all others. The retention period for a
particular records
series must meet minimum retention requirements as mandated
by law. Business needs
and other considerations are secondary. So, legal research is
required before determin-
ing retention periods. Legally required retention periods must
be researched for each
jurisdiction (state, country) in which the business operates, so
that it complies with all
applicable laws.
records retention citation

service, which publishes in electronic form all of the retention-
related citations. These
services usually are bought on a subscription basis, as citations
are updated on an an-
nual or more frequent basis as legislation and regulations
change.
Figure 9.5 is an excerpt from a Canadian records retention
database product called
FILELAW®. In this case, the act, citation, and retention periods
are clearly identifi ed.
using online or
operating in the
(CFR), the annual RR
edition of which
is the codifi cation of the general and permanent rules published
in the Fed-
eral Register by the departments and agencies of the federal
government. It is
divided into 50 titles that represent broad areas subject to

federal regulation.
The 50 subject matter titles contain one or more individual
volumes, which
are updated once each calendar year, on a staggered basis. The
annual update
cycle is as follows: titles 1 to 16 are revised as of January 1;
titles 17 to 27 are
revised as of April 1; titles 28 to 41 are revised as of July 1, and
titles 42 to 50
are revised as of October 1. Each title is divided into chapters,
which usually
bear the name of the issuing agency. Each chapter is further
subdivided into
parts that cover specifi c regulatory areas. Large parts may be
subdivided into
subparts. All parts are organized in sections, and most citations
to the CFR
refer to material at the section level. 45
cial CFR but is up-
dated daily, the Electronic Code of Federal Regulations (e-
CFR) . “It is not an offi cial
legal edition of the CFR. The e-CFR is an editorial compilation
of CFR material and

Federal Register amendments produced by the National
Archives and Records Admin-
istration’s Offi ce of the Federal Register (OFR) and the
Government Printing Offi ce.” 46
Event-Based Retention Scheduling for Disposition of E-
Records
Event-based disposition is kicked off with the passage of an
event, such as hiring or
fi ring an employee, the end of a project, or the initiation of a
lawsuit.
Event-based disposition can have an associated retention
schedule, and the clock
starts running once the event occurs. The required retention
period begins only af-
ter the triggering event occurs. The length of the retention
period may be regulated
by law, or it may be determined by IG guidelines set internally
by the organization.

So, when an employee is terminated, and personnel fi les are
destroyed after (say) fi ve
years, the retention schedule entry would be “Termination + 5
years.”
One other defi nition of event-based disposition comes from
the U.S. e-records
standard, Department of Defense 5015.2, which states that a
disposition instruction
in which a record is eligible for the specifi ed disposition
(transfer or destroy) upon or
immediately after the specifi ed event occurs. No retention
period is applied and there
is no fi xed waiting period, as with “timed” or combination
“timed-event” dispositions.
Example: “Destroy when no longer needed for current
operations.” 47
Some hardware vendors, such as IBM and EMC, provide
solutions that assist in
executing event-based disposition with assistance from fi
rmware (fi xed instructions
on a microchip). The fi rmware-assisted solution should be
considered if your RM
or IG team aims to perform a complete and thorough retention

solution analysis.
These hardware-based solutions can potentially streamline the
event-based disposi-
tion process. 48
Event-based disposition begins with the passage of a
triggering event.
Figure 9.5 Excerpt from Canadian Records Retention
Database
Source: Ontario, Electricity Act, FILELAW database,
Thomson Publishers, May 2012.
Triggering events may be record-related, “such as supersession
or obsolescence.”
This is common to a policy statement. For example, if a group
of policies are to be
destroyed fi ve years after superseded or obsolete, the old
policy would be held for fi ve
years after the new policy has been created.

Sounds simple. But in an attempt to meet retention
requirements, organizations
handle event-based triggers in different ways, ways that often
are problematic. For in-
stance, the trigger events often are not captured electronically
and fed directly into the
retention scheduling software or records repository to start the
clock running, or the
event itself is not well documented in the retention schedule so
it is not consistently
being applied and tracked. In other cases, the organization
simply does not have the
ERM functionality it needs to manage event-based triggers.
This causes many organizations to simply over-retain and keep
the records indefi -
nitely, or until disk storage is full, which means that those
records are retained for an
incorrect—and indefensible—time. The period is either too long
or possibly too short,
but it always is always inconsistent. s And inconsistent means
legally indefensible.
The only prudent and defensible approach is to implement the
proper IG policies

to manage and control the implementation of event-based
disposition.
Prerequisites for Event-Based Disposition
Three key prerequisite tasks must be completed before event-
based disposition can be
implemented:
1. Clarify trigger events. Not all of the events that can trigger
the beginning of a
retention period are as clear as the date an employee is
terminated. For instance,
“contract completion date” could be the day a vendor fi nishes
work, when a fi nal
invoice is rendered, when the invoice is paid, or some other
period, such as 30
days following the payment of the fi nal invoice. These defi
nitions, depending on
the record series in question, may be regulated by law or
governed by IG policies.
What is needed is an agreement as to what the defi nition is, so
that the re-
tention period will be uniform among the record series in

question, providing
a defensible policy.
To gain this agreement on these blurry areas, the RM
lead/manager or team
will need to work with the relevant business unit
representatives, IT, compli-
ance, risk management, and any other stakeholders.
The event triggers must be clear and agreed on so that they may
kick off a
retention period and disposition process.
In a number of cases, the answer to these questions will rely on
trigger
points, such as one year after completion or four months after
the board of di-
rectors’ meeting. It is important to choose a trigger point that
you can implement.
For example, there is no point in saying that records should be
kept until an
individual dies, if you have no reliable way of knowing the
person is alive.
Instead, choose a trigger point based on the information you
have about the

individual; in this case, the 100th birthday might be a suitable
trigger point.
2. Automated capture of agreed-on trigger events must be
performed and sent to the
ERM. It is easy to know an employee’s termination date—most
human re-
sources management systems or payroll systems can supply it—
but other
types of events are not so easily captured and may require some
customiza-
tion in order that this information is fed into an ERM. The
metadata about
the event must be seamlessly entered into the ERM so that it
may launch the
beginning of the retention period. If systems external to the
ERM need to be
interfaced, a common locator (e.g., contract number) can link
the two.

3. The ERM systems must have complete retention and
disposition capabilities. In order
for the retention to start properly and run to fi nal disposition,
this tracking ca-
pability must be an inherent feature of the software. (In some
cases, organiza-
tions may use specialized retention and disposition software
that can perform
this task minimally without complete ERM functionality, but it
falls short of
the type of richness that a robust ERM system provides. What is
needed is the
ability to include the details or retention rules beyond simple
date calculations
(i.e., to store descriptive data or scope notes, and records series
code in addi-
tion to retention requirements, which are automatically
associated with the
retention rule, and to have a records hold and release
capability). If destruc-
tion is the fi nal disposition, then the system must be able to
perform a deletion
of the record (so long as there is no preservation or legal hold)
with no traces
that can allow reconstruction of it, and this process must be

verifi able.
To accomplish clarity and agreement on event-based triggers
requires close
consultation and collaboration among RM staff, business units,
IT, legal, com-
pliance, risk management, and other stakeholders, as relevant.
Final Disposition and Closure Criteria
After completing the records values analysis and legislative
and legal research, you must
determine the closure criteria and fi nal disposition (e.g.,
destroy, transfer, archive) for each
records series. To minimize costs and litigation risk, retention
periods should be kept as
short as possible while meeting all applicable regulatory, legal,
and business requirements.49
Retention Periods: Online versus Offl ine
For e-records, retention periods may be segmented into active
and inactive, or online and
offl ine. Offl ine may be segmented further into on-site and off-
site or archival storage.

Going back and combing through records retrieval requests and
usage logs may
provide helpful insights as to the needs of records users—but
bear in mind that these
logs may be misleading as users may have (in the past, before a
formal IG program was
implemented) kept shadow copies of fi les on their local hard
drives or backed up to
fl ash drives or other storage devices.
Closure Dates
A clear closure start date is required to kick off a retention
period for any record,
whether the retention is scheduled for on- or off-site. Calendar
or fi scal year-ends are
typical and practical closure dates for subject or topical records.
The date used to indi-
cate the start year is usually the date the fi le closed or the date
of last use or update. In a
university setting, school year-end may be more logical. Still, a
reasoned analysis is re-
quired to determine the best closure start date for subject
records in your organization.

Case records are different; logically, their closure date is set
when a case record is
completed (e.g., the date when an employee resigns, retires, or
is terminated).
Future dates may be used, such as an employee promotion date,
student gradua-
tion, or project completion. After consulting those who create
and handle the records
series you are analyzing, apply good business judgment and
common sense when de-
termining closure dates. 50
Retaining Records Indefi nitely
There may be some vital, historical, or other critical records
that, in the best interests
of the organization, need to be retained permanently. This is
rare, and storing records
long term must be scrutinized heavily. If certain electronic

records are to be retained
indefi nitely or permanently, then LTDP policies and techniques
must be used. (See
Chapter 17 for more details.)
Retaining Transitory Records
Transitory documents usually do not rise to the level of
becoming a record; they are
temporary and are useful only in the short term, such as direct
mail or e-mail adver-
tising (brochures, price lists, etc.), draft documents (although
not all are transitory,
and some may need longer retention periods, such as draft
contracts) and work in
progress, duplicates, external publications (e.g., magazines,
journals, newspapers, etc.),
and temporary notices (e.g., company picnic, holiday party, or
football pool). You must
consider transitory records in your master records retention
schedule.
Implementation of the Retention Schedule
and Disposal of Records

Automated programs that interpret these retention periods are
the best way to ensure
that records are disposed of at the correct time and that an audit
trail of the disposition
is maintained.
Getting Acceptance and Formal Sign-off of the Retention
Schedule
Upon completion of the records retention schedule, project
management best prac-
tices dictate that it be signed off by an executive or project
sponsor, to indicate it has
been completed and there is no more work to be done on that
phase of the project. In
addition, you may want to gain the sign-off and acceptance by
other key stakehold-
ers, such as senior representatives from legal, IT, the board of
directors or executive
committee, and perhaps audit and information governance. The
schedule should be
updated when new record types are introduced and, in any case,
at least annually.
Disposition Timing: Records Disposal

It is much easier to time or schedule the disposal of e-records
than of paper or physical
records, but true and complete destruction of all traces of a
record cannot be done
by hitting a simple “delete” key. There must be a process in
place to verify the total
destruction of all copies of the record. (See Chapter 17 for
more details.) Records
destruction can occur daily, routinely, or be scheduled at
intervals (i.e., monthly or
quarterly).
Automating Retention/Disposal Actions
ERM systems typically are capable of automatically executing a
record deletion when
a record has reached the end of its life cycle. Often these
systems have a safety fea-
ture that allows an operator who has the authority to review

deletions before they are
performed.
Disposal Date Changes
To make a retention schedule change, such as extending the life
of a record series, IG
controls must be in place. So, usually, ERM systems require
that a person of higher
authority than the system operator make these approvals. Every
subsequent delay in
destroying the records often requires an escalation in approval
period to extend the
time that records are kept past the destruction date.
Proving Record Destruction
In some environments, especially in the public sector, a certifi
cate of destruction or
other documentation is required to prove that a record and all its
copies have been
completely deleted (including its metadata—although at times it
is benefi cial to retain
metadata longer than the record itself; see Appendix A,
“Information Organization

and Classifi cation,” for more details). ERM systems can be
confi gured to keep an audit
trail and prove that destruction has occurred.
Ongoing Maintenance of the Retention Schedule
Records series are not static; they change, are added to, and are
amended. New record
functions emerge, based on changes in business, acquisitions,
and divestitures. So it
is necessary for organizations to review and update—at least
annually—their records
retention schedule.
In addition, retention requirements change as legislation
changes, lawsuits are
fi led, and the organization refi nes and improves its IG
policies. Development of a re-
cords retention schedule is not a one-time project; it requires
attention, maintenance,
and updating on a regular schedule, and using a controlled
change process.
Audit to Manage Compliance with the Retention Schedule

Once your organization establishes records retention schedules
for business units, or a
master retention schedule, there must be IG policies in place to
audit and ensure that
policies are being followed. This is a key requirement of
maintaining a legally defensible
retention schedule that will hold up to legal challenges.
■ According to ISO, a record is “information created,
received, and maintained
as evidence and information by an organization or person, in
pursuance of
legal obligations or in the transaction of business.”
■ RM is “[the] fi eld of management responsible for the effi
cient and system-
atic control of the creation, receipt, maintenance, use, and
disposition
of records, including the processes for capturing and

maintaining evidence
of and information about business activities and transactions in
the form of
records.”
■ ERM includes the management of electronic and
nonelectronic records, such
as paper and other physical records.
■ ERM has become much more critical to enterprises with
increased compli-
ance legislation and massively increasing volumes of electronic
information.
■ ERM follows the same basic principles as paper-based records
management.
■ A number of factors provide the business rationale for
ERM, including facilitat-
ing compliance, supporting IG, and providing backup
capabilities in the event
of a disaster.
■ Implementing ERM is challenging since it requires user
support and compli-

ance, adherence to changing laws, and support for new
information delivery
platforms like mobile and cloud computing.
■ ERM benefi ts are both tangible and intangible or diffi cult to
calculate.
■ Improved professionalism, preserving corporate memory,
support for better
decision making, and safeguarding vital records are key
intangible benefi ts
of ERM.
■ NARA recommends that e-records are inventoried by
information system
rather than fi le series, which is the traditional approach for
physical records.
■ Generally Accepted Recordkeeping Principles® are
“information management
and governance of record creation, organization, security,
maintenance and
other activities used to effectively support recordkeeping of an
organization.”

■ It may be helpful to use a record-keeping methodology such
as the Principles
or D.I.R.K.S. to guide inventorying efforts.
■ Perhaps the organization has a handle on their paper and
microfi lmed records,
but e-records have been growing exponentially and spiraling out
of control.
■ Whatever the business goals for the inventorying effort are,
they must be con-
veyed to all stakeholders, and that message must be reinforced
periodically
and consistently, and through multiple means.
■ An appropriate scope might enumerate the records of a
single program or
division, several functional series across divisions, or records
that fall within a
certain time frame versus an entire enterprise.

■ The completed records inventory contributes toward the
pursuit of an orga-
nization’s IG objectives in a number of ways.
■ There are basic three ways to conduct the inventory: surveys,
interviews, and
observation. Combining these methods yields the best results.
■ Additional information not included in inventories of
physical records must
be collected in any inventory of e-records.
■ Be sure to tie the fi ndings in the fi nal report of the records
inventory to the
business goals that launched the effort.
■ Records appraisal is based on the information contained in the
records inventory.
■ Records can have different types of value to organizations:
historical, ad-
ministrative, regulatory and statutory, legal, fi scal, or other
archival value as
determined by an archivist.

■ Consistency in managing records across an enterprise,
regardless of media,
format, or location, is the key to compliance.
■ A complete, current, and documented records retention
program reduces
records by making
■ Retention schedules are developed by records series—not for
individual records.
■ Retention schedules are basic tools that allow an organization
to prove that it
has a legally defensible basis on which to dispose records.
■ The master retention schedule contains all records series in
the entire enterprise.
■ Records retention defi nes the length of time that records are
to be kept and
requirements.

■ “Disposition” means not just destruction but can also mean
archiving and a
■ An information map is a critical fi rst step in developing a
records retention sched-
ule. It shows where information is created, where it resides, and
who uses it.
■ After inventorying, developing a retention schedule begins
with records
classifi cation.
■ All e-mail messages are not records; those that document a
business transac-
tion, or progress toward it, are clearly records and require
retention.
■ E-mail messages that document business activities, especially
those that may
be disputed in the future, should be retained as records.
(continued)dd

■ Destructive retention of e-mail is a method whereby e-mail
messages are
retained for a limited period and then destroyed.
■ Tools are available to scan e-records folders to expedite the
inventorying
process.
■ Assessing the relative value of records is key to
determining their retention
periods and disposition path.
■ Records have different types of value, such as fi nancial,
legal, technical, and
administrative/operational.
■ Event-based disposition begins with a triggering event.
■ Retention schedules, once established, must be maintained
and updated to

add new records series, as appropriate, and to comply with new
or changed
legislation and regulatory requirements.
■ Auditing to ensure compliance with established retention
policies is key to
maintaining a legally defensible records retention program.
Notes
15489-1: 2001 Information and Documentation—
Records Management. Part 1: General (Geneva: ISO, 2001),
section 3.15. l
2. Ibid., section 3.16
3. ARMA.org, “What Is Records Management?” 2009,
www.arma.org/pdf/WhatIsRIM.pdf. (accessed
December 2, 2013).
4. Microsoft White Paper, “Records Management with Offi ce
SharePoint Server,” 2007, www.microsoft

.com/en-us/download/details.aspx?id=15932, Used with
permission from Microsoft. (accessed
December 2, 2013).
5. Ibid.
6. Ibid.
7. Ibid.
8. U.S. Environmental Protection Agency, “Why Records
Management? Ten Business Reasons,” updated
March 8, 2012, www.epa.gov/records/what/quest1.htm.
9. U.S. National Archives and Records Administration
,Disposition of Federal Records: A Records Management
Handbook , 2000, Web edition, www.archives.gov/records-
mgmt/publications/disposition-of-federal-
records/chapter-3.html.
10. Ibid.
11. State and Consumer Services Agency Department of
General Services, Electronic Records Management
Handbook , State of California Records Management Program
(February 2002), www.documents.dgs
.ca.gov/osp/recs/ermhbkall.pdf .

12. U.S. Environmental Protection Agency, “Six Steps to
Better Files,” updated March 8, 2012, www.epa
.gov/records/tools/toolkits/6s tep/6step-02.htm .
13. Margaret Rouse, “Generally Accepted Recordkeeping
Principles,” updated March 2011, http://
searchcompliance.techtarget.com/defi nition/Generally-
Accepted-Recordkeeping-Principles-GARP
http://www.arma.org/pdf/WhatIsRIM.pdf
http://www.microsoft.com/en-
us/download/details.aspx?id=15932
http://www.epa.gov/records/what/quest1.htm
http://www.archives.gov/records-mgmt/publications/disposition-
of-federal-records/chapter-3.html
http://www.documents.dgs.ca.gov/osp/recs/ermhbkall.pdf
http://www.epa.gov/records/tools/toolkits/6step/6step-02.htm
http://searchcompliance.techtarget.com/definition/Generally-

http://www.microsoft.com/en-
us/download/details.aspx?id=15932
http://www.documents.dgs.ca.gov/osp/recs/ermhbkall.pdf
http://www.epa.gov/records/tools/toolkits/6step/6step-02.htm
http://searchcompliance.techtarget.com/definition/Generally-
14. Ibid.
15. Ibid.
16. Public Record Offi ce, “ Guidance for an Inventory of
Electronic Record Collections: A Toolkit,”
September 2000,
www.humanrightsinitiative.org/programs/ai/rti/implementation/
general/guidance_
for_inventory_elect_rec_collection.pdf, pp. 5–6.
17. Ibid. (accessed December 2, 2013).
Records Inventories,” updated October 27, 2000,
www.archives.gov/records-mgmt/faqs/inventories.html .

19. William Saffady, “Managing Electronic Records, 4th
ed.,” Journal of the Medical Library Association , 2009,
www.ncbi.nlm.nih.gov/pmc/articles/PMC2947138/ .
20. Jesse Wilkins, “The First Step: Inventory Your Electronic
Records,” http://pr1vacy.blogspot
.mx/2005/11/fi rst-step-inventory-your-electronic.html
(accessed October 11, 2012).
21. Ibid.
22. Ibid.
23. Quotes in this section are from Government of Alberta,
Records and Information Management, www
.im.gov.ab.ca/index.cfm?page=imtopics/Records.html. (accessed
December 2, 2013).
24. Maryland State Archives, “Retention Schedule
Preparation,” June 1, 2012, www.msa.md.gov/msa/
intromsa/html/record_mgmt/retention_schedule.html .
25. National Health Service, “Connecting for Health,”
www.connectingforhealth.nhs.uk/ (accessed
April 10, 2012).
26. Wortzman Nickle Professional Corporation, “Effective

Records Management—Part 4—Ensuring
Adoption and Compliance of RM Policy,” 2009,
www.wortzmannickle.com/ediscovery-blog/2011/12/14/
rmpart4/ (accessed April 12, 2012).
28. National Archives, “Disposition of Federal Records.”
31. Ibid.
32. University of Edinburgh, Records Management Section,
July 5, 2012, www.recordsmanagement.ed.ac
.uk/InfoStaff/RMstaff/Retention/Retention.htm.
Records Scheduling and Disposition.” http://
www.archives.gov/records-mgmt/faqs/scheduling.html#steps
accessed December 2, 2013.
34. University of Edinburgh, Records Management Section.

36. University of Toronto Archives, “Glossary,”
www.library.utoronto.ca/utarms/info/glossary.html
(accessed September 10, 2012).
38. Ibid.
39. Marty Foltyn, “Getting Up to Speed on FRCP,” June 29,
2007, www.enterprisestorageforum.com/
continuity/features/article.php/3686491/Getting-Up-To-Speed-
On-FRCP.htm.
40. Nancy Flynn, The E-Policy Handbook (New York:
AMACOM, 2009), pp. 24–25.
41. ArcMail Blog http://arcmail.com/blog/archiving-rules-
the-dangers-of-destructive-retention/ (accessed
Dec. 2, 2013).
42. Mary Flood, “Survey: They see a more litigious future,”
October 18, 2010, http://blog.chron.com/
houstonlegal/2010/10/survey-they-see-a-more-litigious-future/
(accessed Dec. 2, 2013).
43. Ibid., pp. 127.

Disposition Schedules,” p. 122.
45. U.S. Government Printing Offi ce, Code of Federal
Regulations , www.gpo.gov/help/index.html#about_s
code_of_federal_regulations.htm (accessed April 22, 2012).
46. U.S. National Archives and Records Administration,
“Electronic Code of Federal Regulations,”
October 2, 2012, http://ecfr.gpoaccess.gov/cgi/t/text/text-
idx?c=ecfr&tpl=%2Findex.tpl.
47. Department of Defense, “Design Criteria Standard for
Electronic Records Management Software
Applications,” July 19, 2002,
http://jitc.fhu.disa.mil/cgi/rma/downloads/p50152s2.doc.
48. Craig Rhinehart, IBM, e-mail to author, July 30, 2012.
49. Government of Alberta, “Records and Information
Management.”
50. Ibid., p. 125.
http://www.humanrightsinitiative.org/programs/ai/rti/implement
ation/general/guidance_for_inventory_elect_rec_collection.pdf
http://www.archives.gov/records-mgmt/faqs/inventories.html
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2947138/

http://pr1vacy.blogspot.mx/2005/11/first-step-inventory-your-
electronic.html
http://www.msa.md.gov/msa/intromsa/html/record_mgmt/retenti
on_schedule.html
http://www.connectingforhealth.nhs.uk/
http://www.wortzmannickle.com/ediscovery-
blog/2011/12/14/rmpart4/
http://www.recordsmanagement.ed.ac.uk/InfoStaff/RMstaff/Rete
ntion/Retention.htm
mgmt/faqs/scheduling.html#steps
mgmt/faqs/scheduling.html#steps
http://www.library.utoronto.ca/utarms/info/glossary.html
http://www.enterprisestorageforum.com/continuity/features/artic
le.php/3686491/Getting-Up-To-Speed-On-FRCP.htm
http://arcmail.com/blog/archiving-rules-the-dangers-of-
destructive-retention/
http://blog.chron.com/houstonlegal/2010/10/survey-they-see-a-
more-litigious-future/
gulations.htm
http://jitc.fhu.disa.mil/cgi/rma/downloads/p50152s2.doc

http://www.humanrightsinitiative.org/programs/ai/rti/implement
ation/general/guidance_for_inventory_elect_rec_collection.pdf
http://pr1vacy.blogspot.mx/2005/11/first-step-inventory-your-
electronic.html
http://www.im.gov.ab.ca/index.cfm?page=imtopics/Records.htm
l
http://www.im.gov.ab.ca/index.cfm?page=imtopics/Records.htm
l
http://www.msa.md.gov/msa/intromsa/html/record_mgmt/retenti
on_schedule.html
http://www.wortzmannickle.com/ediscovery-
blog/2011/12/14/rmpart4/
http://www.recordsmanagement.ed.ac.uk/InfoStaff/RMstaff/Rete
ntion/Retention.htm
http://www.enterprisestorageforum.com/continuity/features/artic
le.php/3686491/Getting-Up-To-Speed-On-FRCP.htm
http://blog.chron.com/houstonlegal/201 0/10/survey-they-see-a-
more-litigious-future/
gulations.htm
189

C H A P T E R 10
Information
Governance and
Information Technology
Functions
I
nformation technology (IT) is a core function impacted by
information gover-y
nance (IG) efforts. IT departments typically have been charged
with keeping the
“plumbing” of IT intact—the network, servers, applications, and
data—but although
the output of IT is in their custody, they have not been held to
account for it; that
is, the information, reports, and databases they generate have
long been held to be
owned by users in business units. This has left a gap of
responsibility for governing
the information that is being generated and managing it in
accordance with legal and
regulatory requirements, standards, and best practices.

Certainly, on the IT side, shared responsibility for IG means
the IT department
itself must take a closer look at IT processes and activities with
an eye to IG. A
focus on improving IT effi ciency, software development
processes, and data quality
will help contribute to the overall IG program effort. IT is an
integral piece of the
program.
Debra Logan, vice president and distinguished analyst at
Gartner, states:
Information governance is the only way to comply with
regulations, both cur-
rent and future, and responsibility for it lies with the CIO and
the chief legal
offi cer. When organizations suffer high-profi le data losses,
especially involv-
ing violations of the privacy of citizens or consumers, they
suffer serious repu-
tational damage and often incur fi nes or other sanctions. IT
leaders will have
to take at least part of the blame for these incidents. 1

Gartner predicts that the need to implement IG is so critical
that, by 2016, fully
one in fi ve chief information offi cers (CIOs) will be
terminated for their inability to
implement IG successfully.
Aaron Zornes, chief research offi cer at the MDM (Master Data
Management)
Institute, stated: “While most organizations’ information
governance efforts have fo-
cused on IT metrics and mechanics such as duplicate
merge/purge rates, they tend to
ignore the industry- and business-metrics orientation that is
required to ensure the
economic success of their programs.” 2
Four IG best practices in this area can help CIOs and IT leaders
to be successful
in delivering business value as a result of IG efforts:
1. Don’t focus on technology, focus on business impact

Technology often enthralls those in IT—to the point of
obfuscating the
reason that technologies are leveraged in the fi rst place: to
deliver business
benefi t. So IT needs to reorient its language, its vernacular, its
very focus
when implementing IG programs. IT needs to become more
business savvy,
more businesslike, more focused on delivering business benefi
ts that can help
the organization to meet its business goals and achieve its
business objectives.
“Business leaders want to know why they should invest in an
information gov-
ernance program based on the potential resulting business
outcomes, which
manifest as increased revenues, lower costs and reduced risk.”
3
2. Customize your IG approach for your specifi c business,
folding in any industry-specifi c
best practices possible.
You cannot simply take a boilerplate IG plan, implement it in

your orga-
nization, and expect it to be successful. Sure, there are
components that are
common to all industries, but tailoring your approach to your
organization is
the only way to deliver real business value and results. That
means embarking
on an earnest effort to develop and sharpen your business goals,
establish-
ing business objectives that consider your current state and
capabilities and
external business environment and legal factors unique to your
organization.
It also means developing a communications and training plan
that fi ts with
your corporate culture. And it means developing meaningful
metrics to mea-
sure your progress and the impact of the IG program, to allow
for continued
refi nement and improvement.
3. Make the business case for IG by tying it to business
objectives
To garner the resources and time needed to implement an IG
program, you

must develop a business case in real, measureable terms. The
business case
must be presented in order to gain executive sponsorship, which
is an essential
component of any IG effort. Without executive sponsorship, the
IG effort will
fail. Making the business case and having metrics to measure
progress and
success toward meeting business objectives are absolute musts.
4. Standardize use of business terms
IG requires a cross-functional effort, so you must be speaking
the same
language, which means the business terms you use in your
organization must
be standardized. This is the very minimum to get the
conversation started.
But IG efforts will delve much more deeply into information
organization and
seek to standardize the taxonomy for organizing documents and
records and
even the metadata fi elds that describe in detail those document
and records

across the enterprise.
Overall, being able to articulate the business benefi ts of your
planned IG program
will help you recruit an executive sponsor, help the program
gain traction and support,
and help you implement the program successfully. 4
Several key foundational programs should support your IG
effort in IT, includ-
ing data governance, master data management (MDM), and
implementing accepted
IT standards and best practices. We will now delve into these
concepts in more detail.
INFORMATION GOVERNANCE AND INFORMATION
TECHNOLOGY FUNCTIONS 191
Data Governance
We touched on data governance in Chapter 2 . Data is big,
data is growing, data is valu-
able, and the insights that can be gained by analyzing clean,

reliable data with the latest
analytic tools are a sort of new currency. There are nuggets of
gold in those mountains
of data. And leveraging those discoveries can provide a
sustainable competitive advan-
tage in areas such as customer acquisition, customer retention,
and customer service.
The challenge is largely in garnering control over data and in
cleaning, secur-
ing and protecting it; doing so requires effective data
governance strategies. But data
governance is not only about cleaning and securing data; it is
also about delivering
it to the right people at the right time (sometimes this means in
realtime) to provide
strategic insights and opportunities. If a data governance
program is successful, it can
add profi ts directly to the bottom line. 5
Data governance involves processes and controls to ensure
that information at
the data level—raw data that the organization is gathering and
inputting—is true and
accurate, and unique (not redundant). It involves data cleansing

( or data scrubbing) gg
to strip out corrupted, inaccurate, or extraneous data and de-
duplication to eliminate
redundant occurrences of data.
Data governance focuses on information quality from the
ground up (at the low-y
est or root level), so that subsequent reports, analyses and
conclusions are based on
clean, reliable, trusted data (or records) in database tables. Data
governance is the most
fundamental level at which to implement IG. Data governance
efforts seek to ensure
that formal management controls—systems, processes, and
accountable employees
who are stewards and custodians of the data—are implemented
to govern critical data
assets to improve data quality and to avoid negative downstream
effects of poor data.
Data governance is a newer, hybrid quality control discipline
that includes elements
of data quality, data management, IG policy development,
business process improve-
ment, and compliance and risk management.

Good data governance programs should extend beyond the
enterprise to include
external stakeholders (suppliers, customers) so an organization
has its fi nger on the
pulse of its extended operations. In other words, enforcing data
governance at the ear-
liest possible point of entry—even external to the
organization—can yield signifi cant
effi ciencies and business benefi ts downstream. And combining
data governance with
real-time analytics and business intelligence (BI) software not
only can yield insights
into signifi cant and emerging trends but also can provide solid
information for deci-
sion makers to use in times of crisis—or opportunity.
Focusing on business impact and customizing your IG approach
to meet
department.
Effective data governance can yield bottom-line benefi ts
derived from new
insights.

Steps to Governing Data Effectively
Nine key steps you can take to govern data effectively are
listed next. The fi rst fi ve are
based on recommendations by Steven Adler in CIO Magazine:
1. Recruit a strong executive sponsor. As in broader IG
efforts, data governance re-
quires cross-functional collaboration with a variety of
stakeholders. To drive
and facilitate this sometimes contentious conversation, a strong
executive
sponsor is required. This is not an easy task since executives
generally do not
want to deal with the minutia at the data level. You must focus
on the realiz-
able business benefi ts of improved data governance (i.e.,
specifi c applications
that can assist in customer retention, revenue generation, and
cost cutting).

2. Assess your current state. Survey the organization to see
where the data reposi-
tories or silos of data are, what problems related to data exist,
and where some
opportunities to improve lie. Document where your data
governance program
stands today and then map out your road to improvement in
fundamental steps.
3. Set the ideal state vision and strategy. Create a realistic
vision of where your
organization wants to go in its data governance efforts, and
clearly articulate
the business benefi ts of getting there. Articulate a measureable
impact. Track
your progress with metrics and milestones.
4. Compute the value of your data. Try to put some hard
numbers to it. Calculate
some internal numbers on how much value data—good data—
can add to
specifi c business units. Data is unlike other assets that you can
see or touch
(cash, buildings, equipment, etc.), and it changes daily, but it

has real value.
5. Assess risks. What is the likelihood and potential cost of a
data breach? A
major breach? What factors come into play and how might you
combat these
potential threats? Perform a risk assessment to rank and
prioritize threats and
assign probabilities to those threats so you may fashion
appropriate strategies
to counter them.
6. Implement a going-forward strategy. It is a signifi cantly
greater task to try to
improve data governance across the enterprise for existing data,
versus a
smaller business unit. 6 Remember, you may be trying to fi x
years if not decades
of bad behavior, mismanagement, and lack of governance.
Taking an “incre-
mental approach with an eye to the future” provides for a clean
starting point
and can substantially reduce the pain required to implement. A
strategy where
new data governance policies for handling data are implemented

beginning
on a certain future date is a proven best practice.
7. Assign accountability for data quality to business units, not
IT. Typically, IT has
had responsibility for data quality, yet the data generation is
mostly not under
that department’s control, since most is created out in the
business units. A
pointed effort must be made to push responsibility and
ownership for data to
the business units that create and use the data.
8. Manage the change. Educate, educate, educate. People
must be trained to
understand why the data governance program is being
implemented and how
it will benefi t the business. The new policies represent a
cultural change, and
supportive program messages and training are required to make
the shift.
9. Monitor your data governance program. See where
shortfalls might be, and con-
tinue to fi ne-tune the program. 7

From a risk management perspective, data governance is a
critical activity that
supports decision makers and can mean the difference between
retaining a customer
and losing one. Protecting your data is protecting the lifeblood
of your business, and
improving the quality of the data will improve decision making,
foster compliance
efforts, and yield competitive advantages.
Data Governance Framework
The Data Governance Institute has created a data governance
framework, a visualk
model to help guide planning efforts and a “logical structure for
classifying, organiz-
ing, and communicating complex activities involved in making
decisions about and
taking action on enterprise data.” 8 (See Figure 10.1 .) The

framework applies more to
Good data governance ensures that downstream negative effects
of poor data
are avoided and that subsequent reports, analyses, and
conclusions are based
on reliable, trusted data.
Figure 10.1 DGI Data Governance Framework™
Source: The Data Governance Institute (datagovernance.com).
larger organizations, which have greater complexity, greater
internal requirements,
and greater, more complex regulatory demands. It allows for a
conceptual look at data
governance processes, rules, and people requirements.
Information Management
Information management is a principal function of IT. It is
complex and spans a t

number of subdisciplines but can be defi ned as the “application
of management tech-
niques to collect information, communicate it within and
outside the organization,
and process it to enable managers to make quicker and better
decisions.” 9 It is about
managing information, which is more than just collecting and
processing data from
varying sources and distributing it to various user audiences. It
includes a number of
subcomponent tasks, including these four:
1. Master data management (MDM) is a key process for
IG success in the IT de-t
partment, which extends to involved business units. An
emerging discipline,
MDM came into prominence around 2010 to 2012, coinciding
with the Big
Data trend. The goal of MDM is to ensure that reliable, accurate
data from a
single source is leveraged across business units. That is, a key
aim is to establish
a “single version of the truth”10 and eliminate multiple,
inconsistent versions
of data sets, which are more common than most might think,

especially in
larger organizations with physically distributed operations and
large numbers
of servers and databases. 11 MDM gets to the core of data
integrity issues, es-y
sentially asking “Is this data true and accurate? Is thi s the best
and only, fi nal
version?” MDM grew from the need to create a standardized,
“discrete disci-
pline” to ensure there was a single version to base BI analyses
on and to base
decisions on. 12 According to Gartner, MDM is a technology-
enabled disci-
pline in which business and IT work together to ensure the
uniformity, accu-
racy, stewardship, semantic consistency and accountability of
the enterprise’s
offi cial shared master data assets. Master data is the consistent
and uniform set
of identifi ers and extended attributes that describes the core
entities of the en-
terprise, including customers, prospects, citizens, suppliers,
sites, hierarchies
and chart of accounts. 13

What is the business impact? How are operations enhanced and
how
does that contribute to business goals? One set of reliable, clean
data is
critical to delivering quality customer service, reducing
redundant efforts
and therefore operational costs, improving decision making, and
even po-
tentially lowering product and marketi ng costs. “A unifi ed
view of custom-
ers, products, or other data elements is critical to turning these
business
goals into reality.” 14
Again, the larger the organization, the greater the need for
MDM.
Master data management is a key IG process in IT.
2. Information lifecycle management (ILM) is managing

information appropriately t
and optimally at different stages of its useful life, from creation
through
distribution and use, including meeting legal and regulatory
requirements,
and through its fi nal disposition, which can be destruction,
archiving, or
transfer to another entity. Organizations historically over -retain
informa-
tion; however, studies show that information quickly loses its
value and that
once data has aged 10 to 15 days, the likelihood it will be used
again is around
1 percent. 15 Based on its use characteristics, differing
storage management
strategies are appropriate. It defi es business logic to manage
information
that has little value with as much IT resource as information
that is high
value. Doing so is a misuse of resources . To execute ILM
properly, the value of s
certain data sets and records must be appraised and policies
must be formed
to manage it, recognizing that information value changes over
the life cycle,

which requires varying strategies and resource levels.16 ILM
conceptually
includes and can begin with MDM and is linked to compliance
require-
ments and capabilities.
3. Data architecture refers to the “design of structured and
unstructured infor-
mation systems” 17 in an effort to optimize data fl ow
between applications
and systems so that they are able to process data effi ciently.
Further, data
architecture uses data modeling, standards, IG policies, and
rules for gov-
erning data and how it populates databases and how those
databases and
applications are structured.18 Some key issues to uncover
when researching
data architecture and design include data structure, or schema ,
which da-
tabases are used (e.g., Oracle Database 11g, DB2, SQL Server),
methods of
query and access (e.g., SQL), the operating systems the
databases operate
on, and even their hardware (which can affect data architecture

features and
capabilities).
4. Data modeling can be complex, yet it is an important step
in overall IG for g
the IT department. It “illustrates the relationships between
data.” Data
modeling is an application software design process whereby
data processes
and fl ows between applications are diagrammed graphically in
a type of
fl owchart that formally depicts where data is stored, which
applications
share it, where it moves, and the interactions regarding data
movement
between applications. “Data modeling techniques and tools
capture and
translate complex system designs into easily understood
representations of
the data fl ows and processes, creating a blueprint for
construction and/
or re-engineering.” 19 Good data models allow for
troubleshooting before
applications are written and implemented.

The importance of data modeling as a foundation for the
application devel-
opment process is depicted in Figure 10.2 .
Once the data model is developed, business rules and logic can
be applied
through application development. A user interface is
constructed for the appli-
cation, followed by movement of data or e-documents through
work steps us-
ing work fl ow capabilities, and then integration with existing
applications (e.g.,
enterprise resource planning or customer relationship
management systems).
Typically this is accomplished through an application
programming inter-
face, a sort of connector that allows interaction with other
applications and
databases.
There are six approaches to data modeling:

1. Conceptual. The conceptual approach merely diagrams
data relationships at
the “highest level” 20 showing the storage, warehousing, and
movement of data
between applications.
2. Enterprise. The enterprise approach is a more business-
oriented version of
conceptual data modeling that includes specifi c requirements
for an enter-
prise or business unit.
3. Logical. Pertinent to the design and architecture of physical
storage, logical
data modeling “illustrates the specifi c entities, attributes and
relationships in-
volved in a business function.”
4. Physical. The physical approach depicts the
“implementation of a logical data
model” relative to a specifi c application and database system.
5. Data integration. This approach is just what it says; it
involves merging

data from two or more sources, processing the data, and moving
it into a
database. “This category includes Extract, Transform, and Load
(ETL)
capabilities.” 21
6. Reference data management. This approach often is
confused with MDM,
although they do have interdependencies. Reference data is a
way to refer to
data in categories (e.g., having lookup tables— standard
industry classifi cation
or SIC codes) to insert values, 22 and is used only to
“categorize other data
found in a database, or solely for relating data in a database to
information
beyond the boundaries of the enterprise.” 23 So reference data
is not your
actual data itself but a reference to categorize data.
Figure 10.3 shows different categories of data.
IT Governance
As introduced in Chapter 2 , IT governance is about effi

ciency and value creation.
IT governance is the primary way that stakeholders can ensure
that investments in IT create
Figure 10.2 Key Steps from Data Modeling to Integration
Source: Reproduced from Orangescape.com (
www.orangescape.com/wp-content/uploads/2010/10/
Application-Development-Lifecycle-OrangeScape.png ).
Data Model Business Logic
User Interface
Work Flows Integration
http://www.orangescape.com/wp-
content/uploads/2010/10/Application-Development-Lifecycle-
OrangeScape.png
http://www.orangescape.com/wp-
content/uploads/2010/10/Application-Development-Lifecycle-
OrangeScape.png

business value and contribute toward meeting business
objectives.24 This strategic align-
ment of IT with the business is challenging yet essential. IT
governance programs
go further and aim to “improve IT performance, deliver
optimum business value and
ensure regulatory compliance.” 25
Although the CIO typically has line responsibility for
implementing IT gover-
nance, the chief executive offi cer and board of directors must
receive reports and up-
dates to discharge their responsibilities for IT governance and
to see that the program
is functioning well and providing business benefi ts.
The focus of governance in IT is on the actual software
development and mainte-
nance activities of the IT department or function, and IT
governance efforts focus on
making IT effi cient and effective. That means minimizing costs
by following proven
software development methodologies and best practices,
principles of data governance

and information quality, and project management best practices
while aligning IT
efforts with the business objectives of the organization.
IT Governance Frameworks
Several IT governance frameworks can be used as a guide to
implementing an IT
governance program.
Although frameworks and guidance like CobiT® and T ITIL
have been widely
adopted, there is no absolute standard IT governance
framework; the combination
that works best for your organization depends on business
factors, corporate culture,
IT maturity, and staffi ng capability. The level of
implementation of these frameworks
will also vary by organization.
Figure 10.3 Categories of Data
Source: http://www.information-
management.com/issues/20060401/1051002-1.html?zkPrintable
=1&nopagination=1

Increasing:
DATABASE
Semantic content Metadata
Most relevant
to design
Most relevant
to outside world
Most relevant
to business
Most relevant
to technology
Reference Data
Master Data
Enterprise Structure Data
Transaction Activity Data

Transaction Audit Data
Data quality importance
Volume of data
Rates of update
Population later in time
Shorter life span
IT governance seeks to align business objectives with IT
strategy to deliver
business value.
http://www.information-
management.com/issues/20060401/1051002-
1.html?zkPrintable=1&nopagination=1
management.com/issues/20060401/1051002-
1.html?zkPrintable=1&nopagination=1

CobiT®
CobiT (Control Objectives for Information and related
Technology) is a process-T
based IT governance framework that represents a consensus of
experts worldwide. It
was codeveloped by the IT Governance Institute and ISACA.
CobiT addresses busi-
ness risks, control requirements, compliance, and technical
issues.26
CobiT offers IT controls that:
■ Cut IT risks while gaining business value from IT under an
umbrella of a glob-
ally accepted framework.
■ Assist in meeting regulatory compliance requirements.
■ Utilize a structured approach for improved reporting and
management deci-
sion making.
■ Provide solutions to control assessments and project
implementations to

improve IT and information asset control. 27
CobiT consists of detailed descriptions of processes required in
IT and tools to
measure progress toward maturity of the IT governance
program. It is industry agnos-
tic and can be applied across all vertical industry sectors, and it
continues to be revised
and refi ned. 28
CobiT is broken into three basic organizational levels and their
responsibilities:
(1) board of directors and executive management; (2) IT and
business management;
and (3) line-level governance, security, and control knowledge
workers.29
The CobiT model draws on the traditional “plan, build, run,
monitor” paradigm
of traditional IT management, only with variations in semantics.
There are four IT
domains in the COBIT framework, which contain 34 IT
processes and 210 control
objectives that map to the four specifi c IT processes of:

1. Plan and organize.
2. Acquire and implement.
3. Deliver and support.
4. Monitor and evaluate.
Specifi c goals and metrics are assigned, and responsibilities
and accountabilities are
delineated.
The CobiT framework maps to ISO 17799 of the International
Organization for
Standardization and is compatible with Information Technology
Infrastructure
Library (ITIL) and other accepted practices in IT development
and operations. 30
COBIT 5
Released in 2012, CobiT 5 is the latest version of the business
framework for the gov-
ernance of IT from ISACA. CobiT 5
builds and expands on COBIT 4.1 by integrating other major
frameworks,

standards and resources, including ISACA’s Val IT and Risk IT,
Information
Technology Infrastructure Library (ITIL®) and related
standards from the
International Organization for Standardization (ISO). 31
Key Principles and Enablers
“CobiT 5 is based on fi ve key principles for governance and
management of
enterprise IT:
■ Principle 1: Meeting Stakeholder Needs
■ Principle 2: Covering the Enterprise End-to- End
■ Principle 3: Applying a Single, Integrated Framework
■ Principle 4: Enabling a Holistic Approach
■ Principle 5: Separating Governance From Management
The CobiT 5 framework describes seven categories of enablers:
■ Principles, policies and frameworks are the vehicle to

translate the desired
behavior into practical guidance for day-to-day management.
■ Processes describe an organized set of practices and
activities to achieve cer-
tain objectives and produce a set of outputs in support of
achieving overall
IT-related goals.
■ Organizational structures are the key decision-making
entities in an
enterprise.
■ Culture, ethics and behavior of individuals and of the
enterprise are very oftenr
underestimated as a success factor in governance and
management activities.
■ Information is required for keeping the organization running
and well gov-
erned, but at the operational level, information is very often the
key product of
the enterprise itself.
■ Services, infrastructure and applications include the

infrastructure, technol-
ogy and applications that provide the enterprise with
information technology
processing and services.
People, skills and competencies are required for successful
completion of all activi-
ties, and for making correct decisions and taking corrective
actions.” 32
ValIT®
ValIT is a newer value-oriented framework that is compatible
with and complemen-
tary to CobiT. Its principles and best practices focus is on
leveraging IT investments
to gain maximum value. Forty key ValIT essential management
practices (analogous
to CobiT’s control objectives) support three main processes:
value governance, port-
folio management, and investment management. ValIT and
CobiT “provide a full
framework and supporting tool set to help managers develop
policies to manage

CobiT 5 is the latest version of the business framework for the
governance of
IT. It has just fi ve principles and seven enablers.
business risks and deliver business value while addressing
technical issues and meeting
control objectives in a structured, methodic way.” 33
ValIT Integrated with CobiT 5
The ValIT framework has been folded into the CobiT 5
framework. 34 For more de-
tails, you may download free or acquire publications and
operational tools on this and
related topics at isaca.org.
Key functions of ValIT include:
■ Defi ne the relationship between IT and the business and
those functions in
the organization with governance responsibilities;

■ Manage an organization’s portfolio of IT-enabled business
investments;
■ Maximize the quality of business cases for IT-enabled
business investments
with particular emphasis on the defi nition of key fi nancial
indicators, the
quantifi cation of “soft” benefi ts and the comprehensive
appraisal of the
downside risk.
Val IT addresses assumptions, costs, risks and outcomes related
to a balanced
portfolio of IT-enabled business investments. It also provides
benchmarking
capability and allows enterprises to exchange experiences on
best practices for
value management. 35
ITIL
ITIL is a set of process-oriented best practices and guidance
originally developed
in the United Kingdom to standardize delivery of IT service

management. ITIL is
applicable to both the private and public sectors and is the
“most widely accepted ap-
proach to IT service management in the world.” 36 As with
other IT governance frame-
works, ITIL provides essential guidance for delivering business
value through IT, and
it “provides guidance to organizations on how to use IT as a
tool to facilitate business
change, transformation and growth.” 37
ITIL best practices form the foundation for ISO/IEC 20000
(previously
BS 15000), the International Service Management Standard for
organizational
certifi cation and compliance. 38 ITIL 2011 is the latest
revision (as of this writing).
CobiT is process-oriented and has been widely adopted as an IT
governance
framework. ValIT is value-oriented and compatible and
complementary with
The Val IT framework has been folded into the COBIT 5

framework.
It consists of fi ve core published volumes that map the IT
service cycle in a
systematic way:
1. ITIL Service Strategy
2. ITIL Service Design
3. ITIL Service Transition
4. ITIL Service Operation
5. ITIL Continual Service Improvement
ISO 38500
high-level principles
and guidance for senior executives and directors, and those
advising them, for the effec-
tive and effi cient use of IT. 39 Based primarily on AS 8015,
the Australian IT governance

standard, it “applies to the governance of management
processes” performed at the IT
service level, but the guidance assists executives in monitoring
IT and ethically discharg-
ing their duties with respect to legal and regulatory compliance
of IT activities.
which were:
■ Acquire validly
standards, and em-

braces the same methods and approaches.40
CobiT is process oriented and has been widely adopted as an IT
governance
framework. ValIT is value oriented and compatible and
complementary with
ITIL is the “most widely accepted approach to IT service
management in the
world.”
IG Best Practices for Database Security and Compliance
Although security is a topic primarily for Chapter 11 , it is a
technical topic that we
address here as well. Best practices have been developed over
the past few years and
can prevent leakage of structured data from databases and Web
services due to SQL
injections (where hackers attack SQL databases) and other types

of attacks.
An organization and its data needs to be connected to its
stakeholders—employees,
customers, suppliers, and strategic partners. In this
interconnected world that keeps ex-
panding (e.g., cloud, mobile devices) proprietary data is
exposed to a variety of threats.
It is critical to protect the sensitive information assets that
reside in your databases. 41
Perimeter security often is easily penetrated. Web apps are
vulnerable to attacks
such as SQL injection (a favorite among malicious approaches).
Hackers also can gain
access by spear phishing (very specifi c phishing attacks that
include personal informa-
tion) to glean employee login credentials in order to get access
to databases.
Streamlining your approach to database security by
implementing a uniform set
of policies and processes helps in compliance efforts and
reduces costs. Here are some
proven database security best practices:

■ Inventory and document. You must fi rst identify where your
sensitive data and
databases reside in order to secure them. So a discovery and
mapping process
must take place. You can begin with staff interviews but also
use tools such
as data loss prevention to map out data fl ows. Include all
locations, includ-
ing legacy applications, and intellectual property such as price
lists, marketing
and strategic plans, product designs, and the like. This
inventorying/discovery
process must be done on a regular basis with the assistance of
automated tools,
since the location of data can migrate and change.
■ Assess exposure/weaknesses. Look for security holes,
missing updates and patches,
and any irregularities on a regular basis, using
standard checklists such as the CIS Database Server
Benchmarks and
the DISA Security Technical Implementation Guides (STIGs).
Do not

forget to check OS-level parameters such as fi le privileges for
database
confi guration fi les and database confi guration options such as
roles and
permissions, or how many failed logins result in a locked
account (these
types of database-specifi c checks are typically not performed
by network
vulnerability assessment scanners).
■ Shore up the database. Based on your evaluation of potential
vulnerabilities, take
proper steps and also be sure to that used database functions are
disabled.
■ Monitor. On a regular basis, monitor and document any
confi guration changes,
and make sure the “gold” confi guration is stable and
unchanged. “Use change
auditing tools that compare confi guration snapshots and
immediately alert
whenever a change is made that affects your security posture.”
42
ISO 38500 is an international standard that provides high-level

principles and
governance.
■ Deploy monitoring/auditing tools . Deploy these tools to
immediately detect
intrusions or suspicious activity, use your database’s database
activity
monitoring (DAM) and database auditing tools continuously
and in real
time. Note any anomalies, such as usually large numbers of
records being
downloaded even by authorized users—this could indicate, for
instance, a
rogue employee gathering information. But also higher-level
“privileged
users—such as database administrators (DBAs), developers and
outsourced
personnel” must be monitored to comply with certain
regulations. Watch

for attackers who have gained access through authorized
credentials. DAM
creates an audit trail generated in real time that can be the
forensic smoking
gun in investigations after attacks have occurred. Also, monitor
the applica-
tion layer, as
well-designed DAM solutions associate specifi c database
transactions
performed by the application with specifi c end-user IDs, in
order to
deterministically identify individuals violating corporate
policies. In ad-
dition, combining database auditing information with OS
[operating
system] and network logs via a security information and event
manage-
ment . . . system to see everything that a user has done can also
provide
critical information for forensic investigations.
■ Verify privileged access . In your audit process, peri odically
review the list of privi-s
leged users and entitlement reports to ensure that superusers and

those with
access to sensitive information are still authorized.
■ Protect sensitive data . Known sensitive data should be
encrypted, so that even
if attackers gain access, it is unreadable. “File-level encryption
at the OS lay-
er, combined with granular real-time monitoring and access
control at the
database layer, is typically accepted as a practical alternative to
column-level
encryption and a compensating control for Requirement 3.3 of
PCI-DSS.” 43
■ Deploy masking. Hide your live production data by masking
test data. “Masking
is a key database security technology that de-identifi es live
production data,
replacing it with realistic but fi ctional data that can then be
used for testing,
training and development purposes, because it is contextually
appropriate to
the production data it has replaced.”
■ Integrate and automate standardized security processes. To

pass compliance audits,
you need to show that processes and system are in place to
reduce risks and
detect potential intrusions, attacks, and unauthorized use.
Standardizing and
automating these tasks as much as possible helps minimize
compliance costs
while protecting the organization’s data.
Implementing these best practices will help keep sensitive data
in your databases
secure.
Identifying sensitive information in your databases and
implementing database
security best practices help reduce organizational risk and the
cost of compliance.
Tying It All Together
Multiple frameworks and standards can be applied to the IT

process to more effectively
govern it and focus the processes on business impact. Beginning
with a robust data
governance program, organizations can ensure, at the more
fundamental level, that
the information they are using to base decisions on is clean,
reliable, and accurate.
Implementing an MDM program will help larger organizations
with complex IT
operations ensure that they are working with consistent data
from a single source.
Implementing the CobiT 5 business framework for delivering IT
results will help
support a more effi cient IT operation and include other major
frameworks, standards,
and best practices. Leveraging the use of the ISO 38500
standard will help senior
executives to better manage and govern IT operations, and
employing database
security best practices will help guard against outside threats.
■ Focusing on business impact and customizing your IG
approach to meet
department.

■ Effective data governance can yield bottom-line benefi ts
derived from new
insights.
■ Good data governance ensures that downstream negative
effects of poor
data are avoided and that subsequent reports, analyses, and
conclusions are
based on reliable, trusted data.
■ Master data management is a key IG process in IT.
strategy to deliver
business value.
■ CobiT 5 is the latest version of the business framework for
the governance of
IT. It has just fi ve principles and seven enablers.
■ CobiT is process oriented and has been widely adopted as
an IT governance
framework. ValIT is value oriented and compatible and
complementary with

■ ValIT is a framework that focuses on delivering IT vale. It
is folded into CobiT 5.
■ ITIL is the “most widely accepted approach to IT service
management in the
world.”
governance
■ Identifying sensitive information in your databases and
implementing data-
base security best practices help reduce organizational risk and
the cost of
compliance.

Notes
1. Ibid. Gartner Says Master Data Management Is Critical to
Achieving Effective Information Gover-
nance, www.gartner.com/newsroom/id/1898914 (accessed on
January 19, 2012).
2. IBM, “Selling Information Governance to Business
Leaders,” www.information-management.com/
newsletters/governance-ROI-BI-business-rules-GRC-10021663-
1.html (accessed June 3, 2013).
3. Ibid.
4. Ibid.
5. Steven Adler, “Six Steps to Data Governance Success,”
May 31, 2007, www.cio.com/article/114750/Six_
Steps_to_Data_Governance_Success .
6. “New Trends and Best Practices for Data Governance
Success,” SeachDataManagement.com e-book,

46/Talend_sDM_SO_32247_EB-
ook_1104.pdf (accessed March 11, 2013).
7. Ibid.
8. “The DGI Data Governance Framework,”
DataGovernance.com, www.datagovernance.com/fw_the_
DGI_data_governance_framework.html (accessed June 4,
2013).
9. “Information Management,” BusinessDictionary.com,
www.businessdictionary.com/definition/
information-management.html (accessed June 4, 2013).
10. Sunil Soares, Selling Information Governance to the
Business (Ketcham, ID: MC Press, 2011), p. 4. s
11. Daniel Teachey, “The Year of Master Data Management,”
May 1, 2012, http://tdwi.org/articles/2012/05/01/
lesson-2012-the-year-of-master-data-management.aspx .
12. Andrew White, “We Are Only Half Pregnant with MDM,”
April 17, 2013, http://blogs.gartner.com/
andrew_white/2013/04/17/we-are-only-half-pregnant-with-
master-data-management/
13. Gartner IT Glossary, “Master Data Management,”

www.gartner.com/it-glossary/master-data-management-
mdm/ (accessed June 11, 2013).
14. Teachey, “Year of Master Data Management.”
15. Bill Tolson, “Information Governance 101,” May 21,
2013, http://informationgovernance101.
com/2013/05/21/the-lifecycle-of-information/.
16. Gartner IT Glossary, “Information Lifecycle
Management,” www.gartner.com/it-glossary/information-
life-cycle-management-ilm (accessed June 11, 2013).
17. Soares, Selling Information Governance to the Business.
s
18. “Data Architecture,” BusinessDictionary.com,
www.businessdictionary.com/defi nition/data-architecture
.html (accessed June 11, 2013).
19. “Data Modeling,” TechTarget,
http://searchdatamanagement.techtarget.com/defi nition/data-
model-
ing (accessed June 11, 2013).Ibid.
20. Ibid .
21. Soares, Selling Information Governance to the Business.

s
22. Ibid.
23. Malcolm Chisholm, “Master Data Versus Reference
Data,” Information Management , April 1, 2006, t
www.information-management.com/issues/20060401/1051002-
1.html .
24. M. N. Kooper, R. Maes, and E.E.O. Roos Lindgreen, “On
the Governance of Information: Introducing a
New Concept of Governance to Support the Manageme nt of
Information,” International Journal of Information
Management 31 (2011): 195–20,
www.sciencedirect.com/science/article/pii/S0268401210000708
.t
25. Nick Robinson, “The Many Faces of IT Governance:
Crafting an IT Governance Architecture,”
ISACA Journal 1 (2007), www.isaca.org/Journal/Past-
Issues/2007/Volume-1/Pages/The-Many-Faces-l
of-IT-Governance-Crafting-an-IT-Governance-
Architecture.aspx.
26. Bryn Phillips, “IT Governance for CEOs and Members of
the Board,” 2012, p. 26.

27. IBM Global Business Services—Public Sector, “Control
Objectives for Information and related Technol-
ogy (CobiT®) Internationally Accepted Gold Standard for IT
Controls and Governance,” 2008, http://
www-304.ibm.com/industries/publicsector/fi
leserve?contentid=187551 (accessed March 11, 2013).
28. Phillips, “IT Governance for CEOs and Members of the
Board.”
29. IBM Global Business Services—Public Sector, “CobiT®.”
30. Ibid.
31. “COBIT 5: A Business Framework for the Governance and
Management of Enterprise IT,” www.isaca
.org/COBIT/Pages/default.aspx (accessed December 8, 2013).
32. Ibid.
33. IBM Global Business Services—Public Sector, “CobiT®.”
34. IASCA, “Val IT Framework for Business Technology
Management,” www.isaca.org/Knowledge-Center/
Val-IT-IT-Value-Delivery-/Pages/Val-
IT1.aspx?utm_source=multiple&utm_medium=multiple&utm_
content=friendly&utm_campaign=valit (accessed June 12,
2013).

http://www.gartner.com/newsroom/id/1898914
management.com/newsletters/governance-ROI-BI-business-
rules-GRC-10021663-1.html
http://www.cio.com/article/114750/Six_Steps_to_Data_Governa
nce_Success
http://viewer.media.bitpipe.com/1216309501_94/12889 90195_9
http://www.datagovernance.com/fw_the_DGI_data_governance_
framework.html
http://www.businessdictionary.com/definition/information-
management.html
http://tdwi.org/articles/2012/05/01/lesson-2012-the-year-of-
master-data-management.aspx
http://blogs.gartner.com/andrew_white/2013/04/17/we-are-only-
half-pregnant-with-master-data-management/
http://www.gartner.com/it-glossary/master-data-management-
mdm/
mdm/

mdm/
http://informationgovernance101.com/2013/05/21/the-lifecycle-
of-information/
http://www.gartner.com/it-glossary/information-life-cycle-
management-ilm
management-ilm
management-ilm
http://www.businessdictionary.com/definition/data-
architecture.html
http://searchdatamanagement.techtarget.com/definition/data-
modeling
management.com/issues/20060401/1051002-1.html
http://www.sciencedirect.com/science/article/pii/S02684012100
00708
304.ibm.com/industries/publicsec tor/fileserve?contentid=18755
1
1
http://www.isaca.org/COBIT/Pages/default.aspx

http://www.isaca.org/Knowledge-Center/Val-IT-IT-Value-
Delivery-/Pages/Val-
IT1.aspx?utm_source=multiple&utm_medium=multiple&utm_co
ntent=friendly&utm_campaign=valit
management.com/newsletters/governance-ROI-BI-business-
rules-GRC-10021663-1.html
http://www.cio.com/article/114750/Six_Steps_to_Data_Governa
nce_Success
http://www.datagovernance.com/fw_the_DGI_data_governance_
framework.html
http://www.businessdictionary.com/definition/information-
management.html
http://tdwi.org/articles/2012/05/01/lesson-2012-the-year-of-
master-data-management.aspx
http://blogs.gartner.com/andrew_white/2013/04/17/we-are-only-
half-pregnant-with-master-data-management/
http://informationgovernance101.com/2013/05/21/the-lifecycle-
of-information/
http://www.businessdictionary.com/definition/data-
architecture.html
http://searchdatamanagement.techtarget.com/definition/ data-
modeling

http://www.isaca.org/COBIT/Pages/default.aspx
35. Ibid.
36. ITIL, “Welcome to the Official ITIL® Website,”
www.itil-officialsite.com/ (accessed
March 12, 2013).
37. ITIL, “What Is ITIL?” www.itil-offi
cialsite.com/AboutITIL/WhatisITIL.aspx (accessed March 12,

2013).
38. Ibid.
39. ISO, “ISO/IEC 38500:2008: Corporate Governance of
Information Technology,” www.iso.org/iso/
catalogue_detail?csnumber=51639 (accessed March 12, 2013).
40. “ISO 38500 IT Governance Standard” (2008),
www.38500.org/ (accessed March 12, 2013).
41. The following discussion and quotes are from Phil Neray,
“Beating the Breach: 10 Best Practices
for Database Security and Compliance,” November 3, 2011,
http://datasafestorage.wordpress
.com/2011/11/15/beating-the-breach-10-best-practices-for-
database-security-and-compliance/.
42. Ibid
43. Ibid
http://www.itil-officialsite.com/
http://www.itil-officialsite.com/AboutITIL/WhatisITIL.aspx
http://datasafestorage.wordpress.com/2011/11/15/beating-the-
breach-10-best-practices-for-database-security-and-compliance/

http://datasafestorage.wordpress.com/2011/11/15/beating-the-
breach-10-best-practices-for-database-security-and-compliance/
207
P
rivacy and security go hand in hand. Privacy cannot be
protected without imple-
menting proper security controls and technologies. Organization
must make not
only reasonable efforts to protect privacy of data, but they must
go much further
as privacy breaches are damaging to its customers, reputation,
and potentially, could
put the company out of business.
Breaches are increasingly being carried out by malicious
attacks, but also a sig-
nifi cant source of breaches is internal mistakes caused by poor
information gover-
nance (IG) practices, software bugs, and carelessness. The
average cost of a data breach

in 2013 was over $5 million dollars, according to the Ponemon
Institute, 1 but some
spectacular breaches have occurred, such as the $45 million in
fraudulent automated
teller machine cash withdrawals in New York City within hours
in early 2013, and the
110 million customer records breached at giant retailer Target
in late 2013. Millions
of breaches occur each year: There were an estimated 354
million privacy breaches
between 2005 and 2010 in the United States alone.
Cyberattacks Proliferate
Online attacks and snooping continue at an increasing rate.
Organizations must be
vigilant about securing their internal, confi dential documents
and e-mail messages. In
2011, security experts at Intel/McAfee “discovered an
unprecedented series of cyber
attacks on the networks of 72 organizations globally, including
the United Nations,
governments and corporations, over a fi ve-year period.” 2
Dmitri Alperovitch of
McAfee described the incident as “ the biggest transfer of

wealth in terms of intellectual“
property in history.”3 The level of intrusion is ominous.
The targeted victims included governments, including the
United States, Canada,
India, and others; corporations, including high-tech companies
and defense contrac-
tors; the International Olympic Committee; and the United
Nations. “In the case of
the United Nations, the hackers broke into the computer system
of its secretariat in
Information
Governance and
Privacy and Security
Functions
C H A P T E R 11
Portions of this chapter are adapted from Chapters 11 and
12, Robert F. Smallwood, Safeguarding Critical E-Documents:
Implementing a Program for Securing Confi dential Information
Assets , © John Wiley & Sons, Inc., 2012. Reproduced with s
permission of John Wiley & Sons, Inc.

Geneva in 2008, hid there for nearly two years, and quietly
combed through reams
of secret data, according to McAfee.” 4 Attacks can be
occurring in organizations for years
before they are uncovered—if they are discovered at all. This
means that an organization
may be covertly monitored by criminals or competitors for
extended periods of time.
And they are not the only ones spying—look no further than the
U.S. National
Security Agency (NSA) scandal of 2013. With Edward
Snowden’s revelations, it is clear
that governments are accessing, monitoring, and storing massive
amounts of private data.
Where this stolen information is going and how it will be used
is yet to be
determined. But it is clear that possessing this competitive
intelligence could give a
government or company a huge advantage economically,

competitively, diplomatically,
and militarily.
The information assets of companies and government agencies
are at risk
globally. Some are invaded and eroded daily, without detection.
The victims are losing
economic advantage and national secrets to unscrupulous rivals,
so it is imperative that
IG policies are formed, followed, enforced, tested, and audited.
It is also imperative to
use the best available technology to counter or avoid such
attacks. 5
Insider Threat: Malicious or Not
Ibas, a global supplier of data recovery and computer forensics,
conducted a survey of
400 business professionals about their attitudes toward
intellectual property (IP) theft:
■ Nearly 70 percent of employees have engaged in IP theft,
taking corporate
property upon (voluntary or involuntary) termination.

■ Almost one-third have taken valuable customer contact
information, databases,
or other client data.
■ Most employees send e-documents to their personal e-mail
accounts when pil-
fering the information.
■ Almost 60 percent of surveyed employees believe such
actions are acceptable.
■ Those who steal IP often feel that they are entitled to
partial ownership rights,
especially if they had a hand in creating the fi les. 6
These survey statistics are alarming, and by all accounts the
trend continuing to worsen
today. Clearly, organizations have serious cultural challenges
to combat prevailing
attitudes toward IP theft. A strong and continuous program of
IG aimed at secur-
ing confi dential information assets can educate employees,
raise their IP security
Attacks can continue in organizations for years before they

are uncovered—if
they are discovered at all.
The average cost of a data breach in 2013 was over $5
million.
INFORMATION GOVERNANCE AND PRIVACY AND
SECURITY FUNCTIONS 209
awareness, and train them on techniques to help secure valuable
IP. And the change
needs to be driven from the top: from the CEO and boardroom.
However, the mag-
nitude of the problem in any organization cannot be accurately
known or measured.
Without the necessary IG monitoring and enforcement tools,
executives cannot know
the extent of the erosion of information assets and the real cost
in cash and intangible
terms over the long term.
Countering the Insider Threat

Frequently ignored, the insider has increasingly become the
main threat—more than
the external threats outside of the perimeter. Insider threat
breaches can be more costly
than outsider breaches. Most of the insider incidents go
unnoticed or unreported.7
Companies have been spending a lot of time and effort
protecting their perimeters
from outside attacks. In recent years, most companies have
realized that the insider
threat is something that needs to be taken more seriously.
Malicious Insider
Malicious insiders and saboteurs comprise a very small
minority of employees. A dis-
gruntled employee or sometimes an outright spy can cause a lot
of damage. Malicious
insiders have many methods at their disposal to harm the
organization by destroying
equipment, gaining unsanctioned access to IP, or removing
sensitive information by
USB drive, e-mail, or other methods.

Nonmalicious Insider
Fifty-eight percent of Wall Street workers say they would take
data from their company
if they were terminated, and believed they could get away with
it, according to a recent
survey by security fi rm CyberArk.8 Frequently, they do this
without malice. The majority
of users indicated having sent out documents accidentally via
e-mail. So, clearly it is easy
to leak documents without meaning to do any harm, and that is
the cause of most leaks.

® CrossMark ELSEVIER Available online at www.science

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® CrossMark ELSEVIER Available online at www.science