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Effective Records Management in Today's Business Environment
Effective Records Management in Today's Business Environment
Contents
1 Introduction
2 Business Drivers for
Records Management
6 Implications of Regulatory and
Compliance Mandates
9 The Value Chain in Information
Life Cycles
11 Changing Office Technologies
14 Organizational Best Practices
Records Management
Effective Records Management in Today’s Business Environment 1
Introduction
Successful enterprises have come to rely The default assumption is that employees
on information as a major internal asset to perform job functions as delineated by policy,
leverage or as a lucrative product to sell. procedure and management directives.
There is increasing public scrutiny regarding
the need for corporate leaders to assure that Executive level attention to records management
business information in the form of records strategies, policies, procedures, and technology
can be trusted, protected and produced systems now is the expected practice in
when required. The importance of properly well-run organizations. Executive signatures
managing business records is covered in news required on financial statements by the
sources almost daily, including the failure Sarbanes-Oxley Act (SOX) make it critical to
of some organizations to retain records for manage enterprise information and evidentiary
mandated time periods (Arthur Andersen) records in a well-documented and consistent
and the discovery in some cases of reputation- manner. Each organization’s value chain and
damaging emails (Microsoft and many information workflow must have supporting
others). Regrettably, litigation frequently records management activities and auditable
is a tactic used to resolve disputes between business processes that clearly document the
persons and organizations. Governmental status of activities; i.e., what is known, and
investigations routinely are initiated when when everyone knew it. A carefully developed
audits yield findings of non-compliance with records management strategy and rigorously
expected business practices or activities. In enforced company information management
both of these scenarios, there is an immediate policies are the key to achieving excellence in
focus on how well management supported management that promotes customer, investor,
the proper retention and timely production of regulator, employee and public confidence in an
records, in either paper or electronic format. organization’s activities, products, and services.
Today’s complex business environments ultimately are responsible for the prudent
generate numerous challenges for both stewardship of corporate assets. Yet many
management and employees. Fast-paced companies today lack effective policies and
changes in office technologies, changing procedures to control, manage, preserve and
governmental mandates and global competition retrieve critical corporate records and other
create both obstacles and opportunities. business documents. Consequently, they waste
However, a common aspect of all business valuable time searching for information when
environments is the constant demand for it is needed, risk severe penalties and loss of
ontime access to data, information and corporate reputation for non-compliance
documentation. Informational business with records-related regulations and legal
records are needed for operational guidance, statutes, keep some records too long, spend
reporting to auditors, documentation of too much for storage, and too often fail to
intellectual capital, evidence in litigation protect mission-critical information from loss
and a variety of other tactical and strategic or destruction.
drivers. Business records with critical
informational content must be locatable and Because operational effectiveness is a concern
retrievable quickly and accurately. Otherwise for shareholders, customers, and Boards
lost productivity, public embarrassment of Directors it is incumbent on Chief
and damaged financial status may result. Of Executive Officers (CEOs) to be fully aware
equal importance is the transition of most of their current corporate records practices,
enterprises today from sifting through piles requirements, and known gaps in meeting
of paper to managing gigabytes of data. This goals. Effective enterprise strategies must
shift creates a mandate for an enterprise to be in place to assure that information assets
control and manage its office. are well-managed. Records management is
outside the line of business functions and
Information is one of the most vital strategic core competencies of most organizations.
and operational assets of organizations. Therefore, companies wishing to adhere
Organizations depend on information to to recognized best practices increasingly
make critical strategic decisions, protect turn to third party solution providers with
contractual rights, support innovation, professional records management experience
develop products, deliver services, drive and expertise. Without such external
marketing, process transactions, serve professional assistance, organizations must
customers, and generate revenue. This bear the direct cost of internal development
essential information is contained in business including the required expertise, facilities or
documents, or records. Business records need equipment for the development of records
to be effectively managed. Senior executives management programs and solutions.
Information is one of the most vital strategic and operational assets of organizations. Organizations
depend on information to make critical strategic decisions, support innovation and generate revenue.
This essential information is contained in business documents or records.
The business risks associated with poorly tasks continues to grow. At the same time it
managed information resources are becomes critical to have well-run information
substantial and increasing. Unfortunately, systems that support an organization’s
when information management issues are business goals. Should an organization’s loss
covered by the news media, it often is in a of information become publicly disclosed, the
highly negative context. For example, when financial impact in lost customers and public
Arthur Andersen was implicated in the confidence can be immense. These dangers are
accounting irregularities related to Enron, especially true for financial services, insurance
the headlines did not cover that Arthur and data management businesses where
Andersen had the foresight to have a records customer loyalty often correlates to perceived
retention schedule and records management organizational trustworthiness and reliability.
program. The headlines did, however, cover
extensively the use of shredders and allegations The electronic information glut that affects
of intentional spoliation of evidence. When organizations makes it increasingly difficult
public records used by state governments that to establish which information is of sufficient
must be made available to the public cannot value for long term retention. For this reason,
be located, allegations of misconduct may it is challenging to differentiate data, files, and
arise quickly. And when small sets of emails documents that should be discarded early in
mysteriously disappear in any organization, the information life cycle from official records.
there can be an assumption of spoilation — Information often is created on a personal
that someone has tampered with the computer, printed to paper locally, saved to
email system and has intentionally deleted off-line disks, and sent through networks to
potentially incriminating evidence. many recipients. These proliferating copies
of records create difficulty in establishing
Information management typically is one the identity, accuracy, and authenticity
of the largest overhead burdens of an of records that require retention for long
organization. The creation of correspondence, term preservation. Many individuals find
reports, brochures, forms and graphic themselves in the unenviable position of an
materials can be highly expensive due to both office worker who no longer knows which
the cost of materials and labor. Now that copy of their documents should be preserved
much of this information flow must occur as records material. Should they preserve
within computer systems and networks, the paper copy or the numerous versions of
the incremental cost of performing daily electronic files? (see Fig. 1)
and records is simply beyond the job importance of retaining records and the
description and work-place experience of tools available calls for dedicated professional
most employees. Employees dedicated to expertise. Effective records management can
line-of-business activities need to be spending reduce the cost of doing business by effectively
time accomplishing functionally important managing information resources in a number
tasks, rather than wrestling with long-term of ways:
corporate records retention issues. In fact, • Ensure compliance with regulations and
the local, state, and federal government legal statutes, thereby avoiding costly fines
agency investigative research required to and penalties to which executives may
professionally establish records retention be liable, as well as damage to corporate
periods for certain classes of corporate records reputations
is far beyond the capabilities of the average
office worker. Records retention research • Limit financial risk from pre-trial
requires specialized insights and educational discovery in government investigations
background. Creating a records filing and and civil litigation
indexing system that can be used across an • Streamline storage requirements for both
organization to assure that both paper and electronic and paper documents
electronic records can be found also is a task • Reduce time and effort required to
that only well-trained records management reconstruct mission-critical information in
professionals should undertake. the event of a disaster or other loss
Developing policies, procedures, and training • Reduce labor costs to control, manage,
programs to educate employees about the preserve and access information.
The losses suffered by many organizations due to improper attention to accounting irregularities
have focused attention on the need for excellence in record keeping.
fined up to $1 million and/or be sentenced the costs of electronic records discovery often
to prison for up to 10 years. If the false are paid by the defendant, creating significant
representations are deemed to be willful and incentive to settle cases quickly.
intentional, the fine may reach $5 million
Influence by regulatory agencies in the record-
and the prison sentence could reach 20 years.
keeping processes of business is growing.
These admonitions apply to “anyone who
There is increasing need to assure records
knowingly alters, destroys, mutilates, conceals,
creation and retrieval occurs accurately and
covers up, falsifies, or makes false entries in
quickly, with proper supervision.
records or documents.”
Another area of growing concern for • The Securities and Exchange Act of 1934,
corporations is the stringent attention paid by Rule 240.17a-4 prescribes nonrewriteable
courts to the preservation of records when the non-erasable media for recording some
prospect of litigation arises. Just as Sarbanes- electronic records
Oxley legislation addresses the destruction of • The National Association of Securities
records, “spoliation” of evidence is similarly Dealers Rule 3010 directs that organizations
of importance to courts expecting to see oversee the communications of authorized
high quality fully disclosed documentation. representatives with the public, including
Spoliation is the destruction or alteration of assurance that employees comply with
evidence by actively destroying information or policies. To assure compliance there can be
simply failing to preserve it. When records are expectations of monitoring emails received
destroyed at a defendant’s site or while under internally or sent externally, as well as the
management control, the courts generally will
ability to select for separate treatment emails
find in favor of the plaintiffs even when ill
that may have legal implications.
intent on the part of the defendant may not
be present. Courts have awarded fines and • SEC regulations require that organizations
sanctions against organizations that failed to provide comprehensive electronic records
preserve records on magnetic tapes, optical retention and search capabilities that ensure
disks, or older computer systems when the the latest two years of records are readily
data could not be read or used. In addition, accessible.
Zubulake vs. UBS Warburg greatly increased the scope of a party’s duty to preserve and
produce electronic records, and imposed sanctions for spoliation (destruction of evidence).
In these cases, it may be most cost effective Without a sound data migration strategy,
to contract for outside assistance with some organizations may in the future try to retrieve
of these records management issues so that electronic files that are not readable on
internal personnel can focus their attention on contemporary computer equipment. This
the organization’s line of business and delegate will greatly impact organizational success in
some information management services to addressing records retrieval needs and could
more highly skilled, trained specialists. negatively impact the overall success of the
Contemporary concerns about technology organization in the marketplace. (see Fig. 3)
obsolescence and digital preservation are the
Defining an organization’s information life
source of another information life cycle issue. All
cycle within the operating framework of line-
computer systems run on hardware and software
of-business processes and value chain is critical
that begin to become obsolete from the moment
to the identification of critical records needing
they are installed and configured. As hardware
long term retention. Each organizational
systems such as tape, magnetic disk, and CD/
business process that generates revenue must
DVD drives wear, the information recorded
have the critical records for that process
with those devices is in danger of becoming
defined in a Records Retention Schedule,
inaccessible over time. As office desktop
retention periods assigned, and applicable
computer software versions change yearly, the
policies and procedures developed to address
various data formats being created may not
them. In addition, appropriately trained
be re-usable in the future depending on the
personnel must be assigned to assure that those
backward compatibility of each vendor’s software
offering. For this reason, many organizations are records are captured and preserved, or the
creating digital document preservation strategies loss to the organization may be substantial,
that include a migration of electronic records financially or in public perception. In contrast,
over time from the original native file formats well-managed organizations with highly
to more permanent file formats, such as PDF skilled personnel assuring that record-keeping
or TIF, to archival media such as CD-ROMs, systems are properly managed will enhance
and eventually to printing and preservation on the marketplace reputation and viability of an
acid-free archival-quality paper media. organization and its management.
5. Enterprise accessible database systems for Much of the records material produced
business functions such as accounting, within these systems either is archived to
human resources management, or handling backup tapes that must be restored to be
facilities maintenance requests useful, or the information is protected by
offloading the data to CD-ROM, DVD,
6. Intranet web sites for publishing internal
or a form of magnetic disk or tape. This
policies, research data, or other private
practice exacerbates a complex growing
information
information duplication problem unless
7. Extranets and public web sites that offer the disks or tapes are organized and labeled
web-based documents and data to business to indicate the content of the media.
partners or the general public. Unfortunately, much of the information
stored off-line on computer media external to
In fact, there is a continual synthesis and originating computer systems often is poorly
integration of data that results in changing labeled, difficult to retrieve, and filed locally
information content format and presentation. in paper filing cabinets. This can seriously
For instance, in creating a monthly report, a disrupt electronic records discovery. A major
person might download data to a spreadsheet, improvement in controlling paper documents
paste the spreadsheet as a table into a word can come from implementing barcodes and
processor, attach the word-processing file to RFI sensitive labels to track physical files.
an email, send the email to an Intranet web Implementing computer network resident
publisher, and then post the monthly report records management software to track
on an Intranet. It can become difficult to both physical and electronic files also can
follow the chain of records that constitute the reduce the time required to find records. An
final document. Without documented records opportunity for outsourcing of electronic
management procedures, the evidentiary records creation and storage can occur when
sources of the final published report can be lost paper documents are scanned into electronic
and difficult to produce should evidence of the images that must be stored on CDs or other
reports’ production processes be needed. Fig. 4 long term storage media.
is a conceptual illustration of the diverse types
of interconnected computer software, systems To ensure that the electronic records being
and electronic records repositories that may created in these repositories can be coordinated,
impact a typical office worker. controlled and managed, responsible
There is a continual synthesis and integration of data that results in changing information
content format and presentation.
1. Policies and Procedures for creating and 6. Increasingly, the presence of a dedicated
storing records in both paper and electronic hardware/software electronic records
format that are demonstrably supported system repository so that employees have a
by an organization’s executives, including place to store personal computer files,
the Chief Executive Officer, Chief electronic mail messages, and any other
Financial Officer, Chief Information electronic documents for long term retention
Officer, Chief Legal Counsel, and Chief based on a formally defined Records
Compliance Officer Retention Schedule and business rules
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