e-Records for Compliance

Presented by:

Bruce Miller

The role of electronic recordkeeping in a compliance setting

e-Records for Compliance

Bruce Miller

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations

CSFB BankerQuattrone Resigns Star During Tech Boom Now Facing Investigations of Document HandlingBrooke A. Masters--Washington Post Staff WriterMarch 5, 2003; Page E1 Frank P. Quattrone, the Credit Suisse First Boston Corp. banker who became a star during the Internet boom, quit today in the face allegations that he destroyed documents to obstruct an investigation. New York state Attorney General Eliot L. Spitzer and U.S. Attorney James B. Comey of the Southern District of New York are expected to complete their investigations of Quattrone within weeks, sources familiar with the probes said. Both are looking at…

CSFB BankerQuattrone Resigns Star During Tech Boom Now Facing Investigations of Document HandlingBrooke A. Masters--Washington Post Staff WriterMarch 5, 2003; Page E1 Frank P. Quattrone, the Credit Suisse First Boston Corp. banker who became a star during the Internet boom, quit today in the face allegations that he destroyed documents to obstruct an investigation. New York state Attorney General Eliot L. Spitzer and U.S. Attorney James B. Comey of the Southern District of New York are expected to complete their investigations of Quattrone within weeks, sources familiar with the probes said. Both are looking at…

Think Records Management is Just “Nice to Have?”

…Think Again !!!

E-Mails Reveal Shuttle ConcernsNASA Engineers In Va. Fretted About InactionR. Jeffrey Smith--Washington Post Staff WriterFebruary 22, 2003; Page A1 NASA engineers at the Langley Research Center in Virginia expressed frustration during and shortly after the space shuttle Columbia's disastrous flight that the space agency failed to investigate thoroughly whether it had been seriously damaged by debris during launch, according to a series of internal e-mails disclosed yesterday. In one e-mail sent three days before the shuttle disintegrated on Feb. 1 as it hit the atmosphere, a Langley…

E-Mails Reveal Shuttle ConcernsNASA Engineers In Va. Fretted About InactionR. Jeffrey Smith--Washington Post Staff WriterFebruary 22, 2003; Page A1 NASA engineers at the Langley Research Center in Virginia expressed frustration during and shortly after the space shuttle Columbia's disastrous flight that the space agency failed to investigate thoroughly whether it had been seriously damaged by debris during launch, according to a series of internal e-mails disclosed yesterday. In one e-mail sent three days before the shuttle disintegrated on Feb. 1 as it hit the atmosphere, a Langley…

Credit Suisse Puts Banker On Leave E-Mail Suggests He Was Aware of ProbesBrooke A. Masters--Washington Post Staff WriterFebruary 4, 2003; Page E1 Credit Suisse First Boston Corp. put star investment banker Frank Quattrone on administrative leave yesterday after discovering e-mails that suggest he knew about ongoing criminal and regulatory probes when he and a subordinate advised employees to "clean up those files," sources familiar with the matter said. The U.S. attorney's office in Manhattan opened a probe into the e-mails after receiving copies of the information from CSFB on Friday…

Credit Suisse Puts Banker On Leave E-Mail Suggests He Was Aware of ProbesBrooke A. Masters--Washington Post Staff WriterFebruary 4, 2003; Page E1 Credit Suisse First Boston Corp. put star investment banker Frank Quattrone on administrative leave yesterday after discovering e-mails that suggest he knew about ongoing criminal and regulatory probes when he and a subordinate advised employees to "clean up those files," sources familiar with the matter said. The U.S. attorney's office in Manhattan opened a probe into the e-mails after receiving copies of the information from CSFB on Friday…E-Mail Evidence Allowed in J.P. Morgan Case Official's Messages May Bolster Claim That Company Helped Enron Hide DebtPeter Behr--Washington Post Staff WriterDecember 24, 2002; Page E2 A federal judge ruled yesterday that e-mails from a J.P. Morgan Chase & Co. official referring to "disguised loans" may be entered as evidence in a civil trial, supporting allegations that the company helped Enron Corp. conceal its growing debt before its collapse. U.S. District Judge Jed S. Rakoff had initially kept the memos by Chase Vice Chairman Donald Layton to others within the financial giant away from the jury, saying their impact could be…

E-Mail Evidence Allowed in J.P. Morgan Case Official's Messages May Bolster Claim That Company Helped Enron Hide DebtPeter Behr--Washington Post Staff WriterDecember 24, 2002; Page E2 A federal judge ruled yesterday that e-mails from a J.P. Morgan Chase & Co. official referring to "disguised loans" may be entered as evidence in a civil trial, supporting allegations that the company helped Enron Corp. conceal its growing debt before its collapse. U.S. District Judge Jed S. Rakoff had initially kept the memos by Chase Vice Chairman Donald Layton to others within the financial giant away from the jury, saying their impact could be…

5 Firms To Pay for E-Mail Lapses $1.65 Million Fines, Promises to ImproveBen White--Washington Post Staff WriterDecember 4, 2002; Page E1 Five Wall Street firms agreed today to pay $1.65 million each to settle allegations that they failed to properly save e-mail. The fines, levied by the Securities and Exchange Commission and the securities industry's two self-regulatory bodies, the New York Stock Exchange and NASD, are separate from the much larger amounts a dozen Wall Street firms are expected to pay as part of a proposed "global settlement" to end several conflict-of-interest investigations…

5 Firms To Pay for E-Mail Lapses $1.65 Million Fines, Promises to ImproveBen White--Washington Post Staff WriterDecember 4, 2002; Page E1 Five Wall Street firms agreed today to pay $1.65 million each to settle allegations that they failed to properly save e-mail. The fines, levied by the Securities and Exchange Commission and the securities industry's two self-regulatory bodies, the New York Stock Exchange and NASD, are separate from the much larger amounts a dozen Wall Street firms are expected to pay as part of a proposed "global settlement" to end several conflict-of-interest investigations…

INS Under Pile of Backlogged Paper Agency Reveals It Shuffled 2 Million Documents to Warehouse in the MidwestChristopher Newton--Associated PressAugust 3, 2002; Page A8 More than 2 million documents filed by foreigners, from change-of-address forms to requests for benefits, have been piling up for years and only now are being reviewed by the government, senior U.S. officials said yesterday. Immigrant advocates said that means some foreigners deported secretly after Sept. 11 might have been in compliance with laws they were expelled for breaking. The government has not revealed previously the extent to which…

INS Under Pile of Backlogged Paper Agency Reveals It Shuffled 2 Million Documents to Warehouse in the MidwestChristopher Newton--Associated PressAugust 3, 2002; Page A8 More than 2 million documents filed by foreigners, from change-of-address forms to requests for benefits, have been piling up for years and only now are being reviewed by the government, senior U.S. officials said yesterday. Immigrant advocates said that means some foreigners deported secretly after Sept. 11 might have been in compliance with laws they were expelled for breaking. The government has not revealed previously the extent to which…

Lawmakers Ask Stewart For More DocumentsBen White--Washington Post Staff WriterAugust 7, 2002; Page E1 A congressional committee today requested more documents regarding the sale of ImClone Systems Inc. stock by high-profile media company owner Martha Stewart. Rep. W.J. "Billy" Tauzin (R-La.), chairman of the House Energy and Commerce Committee, chastised Stewart and her attorneys in a sharply worded letter for not moving fast enough to explain why she sold her ImClone shares Dec. 27, the day before the company announced that the Food and Drug Administration had refused an…

Lawmakers Ask Stewart For More DocumentsBen White--Washington Post Staff WriterAugust 7, 2002; Page E1 A congressional committee today requested more documents regarding the sale of ImClone Systems Inc. stock by high-profile media company owner Martha Stewart. Rep. W.J. "Billy" Tauzin (R-La.), chairman of the House Energy and Commerce Committee, chastised Stewart and her attorneys in a sharply worded letter for not moving fast enough to explain why she sold her ImClone shares Dec. 27, the day before the company announced that the Food and Drug Administration had refused an…Federal Court

Subpoenas United Way Financial DataCharity Asked for Documents Dating to 1997Peter Whoriskey--Washington Post Staff WriterJuly 17, 2002; Page B1 FBI agents delivered a subpoena yesterday to the United Way of the National Capital Area, requesting the charity's financial records, board membership lists and other documents. The grand jury subpoena was delivered to Norman O. Taylor, chief executive of the group, and called for documents dating to 1997, according to Irving Kator, the attorney for the charity. The federal inquiry follows a year of allegations of financial mismanagement at the…

Federal Court Subpoenas United Way Financial DataCharity Asked for Documents Dating to 1997Peter Whoriskey--Washington Post Staff WriterJuly 17, 2002; Page B1 FBI agents delivered a subpoena yesterday to the United Way of the National Capital Area, requesting the charity's financial records, board membership lists and other documents. The grand jury subpoena was delivered to Norman O. Taylor, chief executive of the group, and called for documents dating to 1997, according to Irving Kator, the attorney for the charity. The federal inquiry follows a year of allegations of financial mismanagement at the…

Getting in Trouble Without e-Records Who Incident Consequence Cost

GM Tax return Audit Unexpected tax hit $M’s

MicrosoftEmail About Netscape Strategy

Loss of AntiTrust Suit $100M’s

Anderson &Enron Document Shredding SEC Litigation Bankruptcy

US Defense Gulf War Syndrome Litigation $1B

Enron’s Law Firm SEC Charge Replaced all hard drives $800K

FordTire Replacement Program

Loss of Reputation, reduced profit

$500K

Exxon/Mobil MergingDocument deletion dis-allowed for 18 months

$M’s

1. To stay out of legal trouble• Risk of Litigation/Embarrassment– Enron, Microsoft, DoD

2. To Prove Compliance with regulations– SEC, EPA, Privacy, HIPAA, etc.

3. Because they are forced to• Government Mandates• USA (DoD), Canada (RDIMS), UK (PRO), Australia (VERS),

EU (MoREQ) have mandated e-Records

4. To Save $$$• Downstream Cost Avoidance– Cost of litigation (discovery), cost of major mistakes

Why Businesses need e-Records

e-Records as a Contribution to Market Requirements

USA(5015.2)

United Kingdom(PRO)

Australia(VERS)

e-Recordse-Records

e-Records

•Doc Search•GUI

Regulatory Compliance

Financial Svc(SEC)

Pharma(21 CFR 11)

HeathCare(HIPAA)

e-Records

e-Records

e-Records

•WORM Storage•Surveillance•Duplication•Email Capture•Search/Retrieve

•Privacy•Digital Rights•Security

•Privacy•Digital Rights•Security

Mandated Govt. Standards

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations

RecordKeeping for Compliance

• Avg. Acquisition size Approaching 10,000 users– Ability to scale up = key!

• Significant Buyer Skepticism– Many failed pilots.– Poor user acceptance.– Deployment capability = key!

• IT Managers, not Records Managers, = Buyer– Records people in support role only.

What You Need to Know About the Market

• Solutions Must Scale Up– Average implementation size approaching 10,000 users

and up– Requires advanced, web-based technology

• e-Records for ALL Business Processes– Users do not want a desktop application for e-records– Need a way to records-enable all the business processes

• Market is Lacking RM Understanding and Skills– Buyers and Sellers Do not know RM and its

implications– Shortage of Recordkeeping Skills

Major Market Trends

62

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations

RecordKeeping for Compliance

Compliance

What does ROI Mean?

Reduced

Odds

of

Incarceration

A Strategic View of the Emerging Compliance Marketplace

1. Compliance has several forms and meanings

2. A mix of technologies is required for solutions

3. Two “foundation” technologies are common to all compliance

requirements

4. Technology must be accompanied by tremendous industry

knowledge

5. The technology must “snap to” a proper business framework

A Prescription for Compliance

EvaluateRegulations

RiskAssessment

EstablishFramework

Foundation•Setup

•Capture•Classify

•Pilot•Metrics•Monitor

•Optimize

Snap-InCompliance

Get Ready

Foundation

Compliance

The Major Regulations Affecting Many Enterprises

Major Regulations Intent Applicability

SEC/NASD Prevent Securities Fraud All financial institutions and companies regulated by the SEC

Sarbanes Oxley Ensure Accountability for Public Firms

All Public Companies trading on a US Exchange

HIPAA Privacy/Accountability for Healthcare Providers/Insurers

HealthCare providers/insurers. Human and veterinarian

US DoD 5015.2 Electronic Recordkeeping US Government, particularly DoD

21CFR 11 Approval Accountability Pharma manufacturers and regulators, related parties

Many additional smaller, contributing regulations

What you do determines which Regulations Apply

SEC/NASD Sarbanes Oxley

SEC/NASD+

SarbanesOxley

TradingIn

Securities

A PublicCompany

A Public Company (Sarbanes Oxley applies) trading in Securities (SEC/NASD applies)

Translating Requirements to TechnologyExample SEC/NASD Requirements

Requirement Met By

Capture all correspondence (unmodified) [17a-4(f)(3)(v)] Capture in/out Email before reaching user(s)

Store in Non-rewritable, non-erasable format [17a-4(f)(2)(ii)(A)] WORM storage of all email, all documents

Verify automatically recording quality and accuracy [17a-4(f)(2)(ii)(B)] Validated storage to magnetic, worm.

Duplicate data and index storage[17a-4(f)(3)(iii)] Mirrored or duplicate storage servers

Enforce Retention Periods on all stored data and indexes[17a-4(f)(3)(iv)(c)]

Structured Records management

Search/Retrieve all stored data and indexes[17a-4(f)(2)(ii)(D)] High-performance search/retrieval

The Functionality/Capabilities RequiredEight Distinct Technologies

• Records Management (e-records)– Controlled, process-driven Document Retention and Destruction

• Content Management– Document Storage, high-performance search/retrieval, Version Management

• Storage Management– Duplicate/triplicate, non-erasable, disaster recovery– Contextual metadata (index data)

• BI/CPM– Business Intelligence/Corporate Performance Monitoring– Identify and report on key financial performance indicators

• Supervision– Monitor/review/intercept trading correspondence (email/IM/other)

• Email/IM Capture & Management– Intercept email/IM, store & review/retrieve

• Collaboration– Sharing, production of audit review documents– Audit process controls

• Digital Rights Management/Privacy– Digital Signatures/Authorization– Access/Rights Management

Translating Requirements to Technology

5015.2 SEC/NASD 21CFR11 HIPAA Sarbanes/Oxley

e-Rec

ords

Content M

anag

emen

t

Stora

ge M

anag

emen

t

BI/CPM

Supervi

sion

Emai

l/IM

Man

agem

ent

Collabora

tion

Rights

Man

agem

ent

To Deliver Solutions Against these Requirements, Vendors Must;

• Deliver the appropriate mix of technologies required to meet the requirements

• Carefully and thoughtfully integrate the various technologies into a seamless solution

• Incorporate strong knowledge of the particular industry’s requirements into the solution

• The solution must be “snapped to” a business’s internal framework of policies and processes that reflect the requirements

Two Foundation Technologies

ECM

e-Records

Supervisionof

Trading

Non-ErasableData Duplication

Email/IM Collection

BusinessPerformance Management

Audit Processes& Controls

DocumentCollaboration

Tools

Sarbanes Oxley

Rights ManagementRights Management

E-Records

SEC/NASD

US DoD 5015.2

21CFR11HIPAA

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations

RecordKeeping for Compliance

Records Management – A Fresh Approach

Retention/Disposition Scheduling

Structured File Plan

Records Management

Regulations

Laws

Policies

Corporate Information

Retention&

DispositionDecisions

63

• An e-Record is:– E-mail– Anything at the desktop

• Deleting the right document at the right time (Retention and Disposition).

– Destroy according to law/policy

• e-Records puts the organization in control of the destruction.

• Consists of (3) new capabilities:– Declare– Classify– Apply Life Cycle

The Solution – e-records

e-Records(3) Objectives

1. Declare (User)• Put a document under e-Records management control

2. Classify (User)• Assign a retention rule to the document• Automatic or Manual Classification

3. Apply LifeCycle (Records Administrator)• Apply LifeCycle rules to a declared document• Destroy or Transfer (out) a record

Recordkeeping for End Users

• Declare Electronic/Non-Electronic documents

• Classify during Declaration

Effort

RewardThe

5-second

Rule

???

Declaring Documents To Be Records

Classifying a Document

Safety

Inspections

Incidents

Finance

Budgets

Audits

Travel

Requests

Reports

File Plan

Retention Rule 2

Retention Rule 4

Retention Rule 5

Retention Rule 6

Retention Rule 7

Retention Rule 1

Retention Rule 3

Retention Rule 8

Retention Rule 9

Retention Rule 10

Retention Rule 11

Retention Rule 12

Retention Schedule

Doc. 1

Doc. 2

Doc. 3

Doc. 4

Doc. 5

Doc. 6

Rule 1

Rule 3

Rule 1

Rule 5

Rule 8

Rule 8

Classification

US DoD 5015.2 Why pay attention to it?

• No credible alternative.

• 5015.2 forms a meaningful foundation.– The “minimum bar”.

• Ongoing upgrade/development.– ARMA International ERMC.

• Vendors are $$$ bound to it.– Required for most sales.

5015.2-Certified Products CACI's HighView Records Manager v4.1.1 with IBM

Corporation's Records Manager v4.1.1 IBM Corporation's IBM DB2 Records Manager v4.1.1 CEXEC eRecords Enabler V2.0 by CEXEC, Inc. Open Text Corporation's Livelink Records Management

v2.9 FileNet Corporation's FileNet Records Manager v3.0 Stellent, Inc.'s Stellent Records Management v7.1 Accutrac Software, Inc.'s Accutrac XE v2.0 TOWER Software's TRIM Context v5.2 with Microsoft

Corporation's Microsoft SharePoint Portal Server 2003 IBM Corporation's IBM DB2 Records Manager v4.1 Meridio, Inc.'s Meridio v4.2 Meridio, Inc.'s Meridio v4.2 with Microsoft Corporation's

MS SharePoint Portal Server v2.0 Documentum's Documentum Records Manager v4.1 with

MS SharePoint Portal Server 2003 Documentum's Documentum Records Manager v4.1 Documentum's Documentum Records Manager v4.1 with

EMC Corporation's with EMC Centera v2.2 (SP2) Documentum's Documentum Records Manager v4.1 with

ApplicationXtender v5.2 TOWER Software's TRIM Context v5.2 Microsoft Corporation's MS Windows SharePoint Services

2003 with MDY Advanced Technologies, Inc.'s FileSurf 7.5 (SR3)

MDY Advanced Technologies, Inc.'s FileSurf v7.5 (SR3) ZyLAB Technologies BV's ZyIMAGE Records Management

Module v1.0 Objective Corporation Ltd's Objective 7 Stellent, Inc.'s Stellent Records Management v7.0 Zasio Enterprises, Inc.'s Versatile Enterprise v6 Open Text Corporation's Livelink Records Management

v2.7 Feith Systems and Software, Inc.'s Feith Document

Database v7 IBM Corporation's IBM DB2 Records Manager Enabler for

Content Manager v8.2 Optika Inc.'s Acorde Enterprise v4.0

MDY Advanced Technologies, Inc.'s FileSurf v7.50 with NetApp NearStore and NetApp Filer, Decru DataFort, and Documentum

Hyland Software, Inc.'s OnBase Records and Information Management Module v1.0

IBM Corporation's IBM DB2 Records Manager v3.1 LaserFiche's LaserFiche Records Management Edition

v7 MDY Advanced Technologies, Inc.'s FileSurf v7.50 with

Network Appliance, Inc.'s NetApp NearStore and NetApp Filer, Decru Inc.'s DataFort, and KVS, Inc.'s Enterprise Vault v4.0

MDY Advanced Technologies, Inc.'s FileSurf v7.50 with Network Appliance, Inc.'s NetApp NearStore and NetApp Filer and Decru Inc.'s DataFort

Hummingbird, LTD's Hummingbird Enterprise v5.1.1 Integic Corporation's e.POWER Activator v6.3 with

Hummingbird, LTD's Hummingbird Enterprise v5.1.1 MDY Advanced Technologies, Inc.'s FileSurf v7.5 with

KVS, Inc.'s Enterprise Vault v4.0 and EMC Corporation's EMC Centera v2.0

MDY Advanced Technologies, Inc.'s FileSurf v7.5 with KVS, Inc.'s Enterprise Vault v4.0

Cimage NovaSoft, Inc.'s e3-RM 5.0 Vignette Corporation's Vignette Records and Document

Server v4.1 (formerly Seraph v4.1) Documentum's Documentum Records Manager v3.1

with Hummingbird WebTop DM v5.0 IBM Corporation's IBM DB2 Records Manager v2.1.1 TOWER Software's TRIM Context v5.2 170 Systems, Inc.'s 170 MarkView v4 Relativity's Relativity Records Manager (R2M) v3.0 Open Text Corporation's Livelink Records Management

v2.5 for Solaris File Surf v7.50 by MDY Advanced Technologies, Inc.

with iManage MailSite v 6.5 (DMS) by iManage, Inc.

As of Feb. 15 2004

US DoD 5015.2 Standard

• Approved Nov. 1997 for all DND agencies.

• NARA endorsement for US civilian government.

• Vendor Certification Program– Registry of certified products .

• Two certification categories.– RMA products.

– “Product Pairs”.• EDMS with certified RMA products.

http://jitc.fhu.disa.mil/recmgt

Enterprise e-Records

e-Records Server

Metadata

App 1

Declare/ClassifyApp 2

Declare/ClassifyApp 3

Declare/ClassifyApp 5

Declare/Classify

App 6

Declare/ClassifyApp 4

Declare/Classify

File Plan

Retention ScheduleRecords Processes

RecordsAdministration

REPOSITORY REPOSITORY REPOSITORY REPOSITORY REPOSITORY REPOSITORY

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations

RecordKeeping for Compliance

Declaration and Classification

• It’s all that matters!• Declaration

– Getting enough documents declared– Getting them declared at the right time

• Classification– Getting it right

• You’ve got to achieve both• This is what you have to get good at!!!!

You Have to Account for;

To Outwit Your Users

User Attitudes Business Software

Technical PlatformPolicies/Procedures

Declaration – AutomaticWorkFlow

Create Order

Finalize Order

Approval Level 1 Approval Level 2

Place Order

Declare a Record!

“Monitored” Folders

Finance

Safety

Administration

Legal

Declare!

Declare!

~~~~~~~~~

~~~~~~~~~

~~~~~~~~~

~~~~~~~~~

DeclareDocuments

in TheseFolders

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations

RecordKeeping for Compliance

The Holy Grail of e-Records

“Go Ahead…

Classify me.”

Content Based Auto-Classify

• Software that “reads” a document, reduces to core concept– Uses Neural Net software technology

• Compares document concept to Subject File– Finds the best match– Builds a taxonomy on the target subject

• Self-Learning– Accuracy rises with more attempts

The Challenges of Content-Based Auto-Classification

• High Effort, Low Yield– Takes 10-20 documents to train each subject/activity– Extraordinary setup effort

• Accuracy still only 70%? (under ideal circumstances)

– Works well in well-defined, predictable situations

• Don’t Relate Searching to Classification– Classification is different from searching

• Required for Success– Cost embedded within e-records technology– Easier taxonomy construction– Faster, smarter classification

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it

Work8. Conclusions/Recommendations

RecordKeeping for Compliance

Declaring Electronic RecordsUser Reluctance

• It’s “my” document• This is “too much work”• Let “Admin” do it!

Declare that Document!

“Declaring a document is an unnatural act”

Three “Secrets”of Successful Implementation

1. Success is determined by software implementation, not the software itself

– No matter what the features, users will resist

2. Different apps, platforms, attitudes present different challenges

– A solution that works in one circumstance will not work in another

3. RecordKeeping must be part of the business culture

– Will fail without supporting policies, processes

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What Implementation is Really All About

81

Declare the Records

Classify Them (correctly)

Apply Disposition to Them

We have to get the records (under our control)

We need to make sure they are (properly) classified

Now we can apply our retention rules to them

Translating to Real Terms

81

Declare the Records

Classify Them (correctly)

Apply Disposition to Them

How are we going to get 10,000 users to do this, reliably and consistently?

How do me make sure classification accuracy rate > 95%?

This cannot be done unless the bottom two layers happen!

This is what we have to achieve!

A 3-Stage Approach to e-Records Success

1.Establish corporate policies based on the regulations that effect you

2.Translate these policies into specific business procedures

3.Apply the technologies to automate and control the business procedures

Technology

Business Procedures

Corporate Policy

Mandates / RegulationsMandates / Regulations

e-Records Implementation Methodology

10. Enterprise Roll-Out

9. Initial Technology Pilot8. Implement RM Technology

7. Map Business Processes6. Implementation Plan/Strategy

5. Strengthen RM Foundation

4. Enshrine Policies3. Corporate Policies

2. Corporate Awareness1. Supporting Structure

Stage 1 - Policies

Stage 2 –Procedures

Stage 3 - Technology

• Users Don’t Want Another Piece of Software for Recordkeeping.

– Perceived as Administration.– More work, no return.

• Recordkeeping Must be Part of Everyday Work Processes.

– No “separate” effort for recordkeeping.• Build e-Records Into the Business Software.

– Declare a record and classify while writing, approving, and sending documents.

Make e-Records DisappearWhy so Important?

1. The Need for RecordKeeping2. Market Assessment/Trends3. Achieving Compliance4. e-Records Fundamentals5. Declaring & Classifying6. The Holy Grail7. Implementation - Making it Work8. Conclusions/Recommendations

RecordKeeping for Compliance

Implementations are Lagging Sales Why?

2000 2001 2002 2003 2004

Sales

Implementation

Conclusions/Recommendations

• e-Records is here to stay– You’ll need it for compliance

• It is becoming part of ECM– You’ll increasingly have to deal with it

• Learn it!– Don’t think you know it!

• It is difficult to implement– Develop records skills