Should Your Bucket Have Holes in It? Part 2 – Plugging the Holes John Montaña Montaña &...

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Should Your Bucket Have Holes in It?

Part 2 – Plugging the Holes

John Montaña

Montaña & Associates

1

The Tension

You want as few buckets as possible

Legal requirements or other considerations will force more buckets on you

System configuration limitations may limit your ability to accommodate this tension

You may find that you’re stuck with sub-optimal strategies

2

Some Well-Known Issues:

You’re likely to have at least a few of these

3

System Architecture Inconsistent with Legal Requirements

System locations conflict with privacy or location laws

Data silos within systems result in very long retention periods

4

Data Growth

Big buckets = long retention periods = geometric growth of data sets

Over time the IT budget is blown away by growth in storage costs

Downstream costs (e.g., discovery) grow proportionally

5

That Big Ol’ Pile of Paper

Big buckets = long retention = big storage bill

Over time the box storage budget is blown away by growth

Downstream costs (e.g., discovery) grow proportionally

6

Retention Schedule as Index and Finding Aid

Bigger Buckets = less information about their contents

7

Long-term Business NeedsTrending – Data Mining

Often focused on very granular data sets

Often restricted to very occasional use

8

Different Growth Rates in the Data Set

The big bucket works for most of its contents

One silo within it grows much more quickly than the rest

The conservative retention period drives up storage costs massively

The silo driving costs doesn’t require a long retention period

9

System Architecture, Case 1.Servers in the Wrong Country

Lots of countries have rules about where you can keep records

Many forbid keeping data outside the country Tax and accounting PII PHI PCI

10

What to Do?

Country-based exception and technology re-configuration

Duplicate electronic copies in-country

Paper is still legal everywhere – maybe you use it

Any way, you’ve just created a new bucket

11

System Architecture, Case 2.That Doggone Salesman in Russia

75 year retention of payroll records

Permanent retention of many other accounting, personnel and other records records

Putin gets to look in your computer system

12

Paper v. Electronic

Many electronic systems REQUIRE big buckets It’s big buckets or no buckets

Well-organized paper systems can be managed on a granular basis Small buckets with shorter retention periods

Can you have a granular paper-based schedule with shorter retention periods, and a big-bucket schedule for e-records with longer ones?

13

Sure!

Both must comply with legal requirements

Both must be regular course of business, etc. etc.

Understand the downside issues: Discovery Explaining why you have two schedules Administrative overhead

If the cost-benefit equation justifies it, ther is no reason it can’t be done

14

Trending and Data Mining

They think they need everything They don’t

They think they need it all for a very long period of time They don’t

They want a massive dataset retained forever, regardless of cost They can’t have it

15

Negotiate!

The longer they need it, the less they can have

The really long-term stuff needs to be in it’s own silo with that long retention period

16

Bottom Line

Big buckets have the inherent downside of long retention periods

Choosing buckets poorly can aggravate this problem badly

Failure to understand the data that has the potential to aggravate the problem is key

When possible, buckets must be carved to avoid these data types

That data winds up in separate buckets

17

QuestionsQuestions

??

18