This presentation covers the essential components that should be included in your operational program documents: Developing business rules to guide - All employees - who are creating and capturing documents, “Records Managers” involved in the records management process, the integration of the records management system into other programs, and the IT Department - who deploy and support the tools.
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2011 Canadian Institute - Records Retention - The Indispensable Nitty Gritty of Retention Policy.pdf
1. The Indispensable Nitty Gritty of
Retention Policy Implementation:
The Operational Side
Event:
Canadian Institute – Records Retention Intensive Course
Toronto, Ontario, Canada
April, 2012
Presented by;
Keith Atteck
ARMA Toronto Chapter – Member of the Year 2011
April 3, 2012
ARMA Toronto Chapter
2. Agenda
The essential components that should be included in your operational
program documents:
• Developing business rules to guide:
All employees - who are creating and capturing documents
“Records Managers” involved in the records management process
The integration of the records management system into other
programs
The IT Department - who deploy and support the tools
Take-Aways: Participants will be shown examples of operational guidelines
and documents
April 3, 2012
ARMA Toronto Chapter
4. The essential components
that should be included in
your operational policy
documents
April 3, 2012
ARMA Toronto Chapter
5. Shipping, Receiving
and Storage
Management
Requests for
Physical Records
Management
Physical Records
Management
Records Centre
Operations
Management
Imaging Program
Management
Global RIM
Program
Response to
Organizational
Change
Response to
Technology Change
Change
Management
RM Support for
Technology
Selection and
Implementation
Enterprise Content
Management
(ECM) Business
Rules and
Configuration
Management
April 3, 2012
ARMA Toronto Chapter
6. New RIM Program: Framework
Framework
RIM Policy
Comprehensive
documentation
Guides and Procedures
April 3, 2012
ARMA Toronto Chapter
Organization Change
Technology Change
Imaging
Legal Hold
Electronic Messages
Vital Records
Security
Metadata
Retention
Classification
RIM Program Manual
Fundamentals of
Records
Management
Technology
agnostic
Applied to all
Tools and
Systems
7. RIM: Need to set the Vision early
Ecosystem of Information
Working in one environment where all records are;
Created or Captured – once,
Collaborated Globally – version controlled, and
Managed – as records.
Being Confident that;
You can find the original record – every time,
You know who worked on it – who used it, and
You know what it was used for – related to activity.
Know that:
One never has to search any other system,
One can leverage the collective wisdom and knowledge of the organization, and
Everyone’s efforts will not be lost or misplaced.
April 3, 2012
ARMA Toronto Chapter
8. RIM: What are your Guiding Principles?
SINGLE authoritative source of information
All documents will be filed electronically
Into one system as a normal course of business
Everyone depends on the system
Manage only ONE COPY
File once – use many times - in many ways
All transacted records made from the document management
system
FIRST point of contact principle
The person who is first point of contact with documentation is
responsible for determining and ensuring that documentation is
appropriately filed
April 3, 2012
ARMA Toronto Chapter
9. RIM Program Manual:
A Guide to Records and Information Management
Introduction: (Employees)
Why Manage Records and Information?
RIM Fundamentals
Roles and Responsibilities
Tools and Resources
April 3, 2012
ARMA Toronto Chapter
10. RIM Program Manual:
A Guide to Records and Information Management
Part 1: Managing Records and Information (Employees)
Records Life Cycle
Create or Capture
Classify and Collaborate
Commit, Store and Retrieve
Retain and Dispose
Controlled Security and Access
April 3, 2012
ARMA Toronto Chapter
11. RIM Program Manual:
A Guide to Records and Information Management
Part 2: Managing the Program (Employees)
RIM Program Roles and Responsibilities
Maintaining the Classification Scheme
Building and Maintaining the Retention Schedule
RIM Program Documentation
Managing Vital Records
Maintaining the Records Metadata Element Set
Ensuring Knowledge of and Compliance With Program
Principles and Guidelines
Auditing and Quality Assurance
April 3, 2012
ARMA Toronto Chapter
12. RIM Program Manual:
A Guide to Records and Information Management
Part 3: Managing Responses to Events (RIM Manager & Support Team)
Organizational Change
Technology Change
Legal Holds and Other Preservation Orders
Records Clean-up Days
April 3, 2012
ARMA Toronto Chapter
13. RIM Program Manual:
A Guide to Records and Information Management
Part 4: Using and Managing Supporting Tools (RIM Manager & Support Team)
Process Tools
Technology Tools
April 3, 2012
ARMA Toronto Chapter
14. RIM Program Manual:
A Guide to Records and Information Management
Glossary of Terms
April 3, 2012
ARMA Toronto Chapter
15. Archives
Introduction
This addresses the identification, acquisition, arrangement, description, preservation,
use, and promotion of the Company's archival records.
The archival records of an organization are those that are of continuing value because
they document the Company's history, organization, structure, and functions. Archival
records serve as the Company's long-term memory by providing for: continuity,
evidence of continuing rights and obligations, access to past experience, expertise and
knowledge, and an historical perspective. An organization's archives also serve a broader
value in that they constitute a part of the cultural heritage of society.
Scope and Definitions
This policy applies to all records created or received by the Company in the course of its
business that are identified as archival in the Records Retention Schedule and in the
process of archival appraisal.
Archival records potentially include selected records in all Company departments and at
all plants and facilities, the records of any organizations that are controlled by the
Company, and Company records in the custody of third parties contracted by the
Company.
Archival records may be in any media format (e.g. paper, electronic, audio, microform,
video, etc.), and include any related metadata.
April 3, 2012
ARMA Toronto Chapter
16. Imaging
The following factors are necessary for the establishment of a credible
image management system:
Written authority from senior management to establish the image
management program;
Documentation that stipulates the image management program is an integral
part of the companies ordinary course of business;
Written authority to dispose of source records/data within a reasonable
period of time following the image capture;
Complete and accurate documentation of the system’s processes and
procedures;
A quality assurance process and supporting documentation to ensure the
integrity of image capture;
An appropriate storage mechanism and contingency plan that ensures access
to the images for the total retention period required under the Retention
Schedules; and
Conformity with industry accepted standards as they relate to the technology.
April 3, 2012
ARMA Toronto Chapter
17. Access Control Model
It is essential that an organisation have formal
guidelines regulating who is permitted access
to its records and information, and under what
circumstances.
The Company recognizes the importance of
restricting access to records to protect:
personal information and privacy,
professional confidentiality,
security of property (physical, financial
and intellectual), and
legal and other professional privileges.
Equally important are legally enforceable
rights of access embodied in corporate
governance, freedom of information, privacy
protection, and archival and legal process law.
At the same time, practices must be designed
so as not to restrict access to the records and
information employees need to do their jobs.
April 3, 2012
ARMA Toronto Chapter
18. Electronic Messaging
Electronic messaging records will be managed throughout their life cycles according to
the requirements of the Records and Information Management Program (RIM Program),
which will exercise control over the classification, retention, storage, retrieval,
protection, preservation and final disposition of all electronic messaging records, as
required by this standards document and by related procedures and guidelines.
Employees will not store or transfer Company electronic messaging records outside of
company-approved electronic messaging or record keeping systems, or to unauthorized
storage repositories.
To ensure that electronic messaging records are properly managed, adequately
described and readily accessible, they must be classified and declared in the Company’s
electronic document management system (EDMS), or electronic records management
system (ERMS).
Where employees, contractors, or other parties do not have ready access to the
Company’s EDMS or ERMS, electronic messaging records must be forwarded or copied to
an authorized user of the EDMS or ERMS to be classified and declared. It is ultimately
the responsibility of the author to ensure that the record is appropriately filed.
Note: A printed message record is considered to be a duplicate or information copy,
and is to be disposed of when no longer required.
April 3, 2012
ARMA Toronto Chapter
19. Knowledge Management
Knowledge Management, is a business process that supports the
management of an organization’s intellectual assets.
There are two types of Knowledge:
• Explicit knowledge – is public and documented knowledge;
structured, fixed content, externalized, and conscious.
• Implicit knowledge – is that which is not directly expressed; that is,
where the meaning is inferred from the context and, therefore, relies
on existing knowledge.
In an EDMS knowledge is captured explicitly in the information contained
in documents as artifacts, but also in the way the information was used information in context - a form of capture of implicit knowledge.
Knowledge Management, to be effective, recognizes that an artifact’s
greatest information value develops as a result of its relationship with
other artifacts, and application of the combined result in a different
context.
It is important to emphasize the relationship between sources of
information and knowledge, and to ensure that participants in the
knowledge management process (knowledge managers, consumers and
contributors) are able to move fluidly across these relationships.
April 3, 2012
ARMA Toronto Chapter
20. RIM Feeds Enterprise Content Management (ECM)
April 3, 2012
ARMA Toronto Chapter
21. RIM: Compliance Auditing
General - Benefits of Auditing
Test the degree of integrity of systems and procedures
Understanding degree and extent of compliance
Identifying gaps in procedures and training
Local - Due Diligence Reviews
Conduct regular reviews of all record classifications & metadata
Identify change issues of employees and management
Identifies changes in the business environment
Global - Quality Assurance Reviews
Critical for demonstrating integrity of systems, tools and procedures
Management knows if the systems, tools and procedures are working
Important for Litigation support – Safe Harbour
April 3, 2012
ARMA Toronto Chapter
22. RIM: Addresses Evidence Risk
Canada Evidence Act
“31.1 Any person seeking to admit an electronic document as evidence has the burden of
Authentication
of electronic
documents
proving its authenticity by evidence capable of supporting a finding that the electronic
document is that which it is purported to be.”
“31.2 (1) The best evidence rule in respect of an electronic document is satisfied
Application of
best evidence
rule —
electronic
documents
• (a) on proof of the integrity of the electronic documents system by
or in which the electronic document was recorded or stored; or
• (b) if an evidentiary presumption established under section 31.4 applies.”
“31.5 For the purpose of determining under any rule of law whether an electronic document
Standards may
be considered
is admissible, evidence may be presented in respect of any standard, procedure,
usage or practice concerning the manner in which electronic documents are to be recorded
or stored, having regard to the type of business, enterprise or endeavour that used,
recorded or stored the electronic document and the nature and purpose of the electronic
document.”
Source: Department of Justice - http://laws.justice.gc.ca/eng/StatutesByTitle/C.html
April 3, 2012
ARMA Toronto Chapter
23. RIM: Evidence Best Practice
Canada
CAN/CGSB 72.34-2005 - Electronic Records as Documentary Evidence
“5.2.1 Those who wish to present an electronic record as evidence in legal
proceedings shall be able to prove
a) authenticity of the record;
b) integrity of the Records Management System that a record was
recorded or stored in; and
c) that it is "a record made in the usual and ordinary course of
business" or that it is otherwise exempt from the legal rule barring
hearsay evidence.”
Source: CGSB - http://www.tpsgc-pwgsc.gc.ca/ongc/home/index-e.html
April 3, 2012
ARMA Toronto Chapter
24. RIM: ISO15489 Best Practice
ISO15489-1:2001 – Information and documentation – Records management
Applies to records, in all formats, created or received by any public or private
organization in the conduct of its activities, or any individual with a duty to
create and maintain records.
Supports:
• Electronic Records Management (ERM) & Physical Records
• ISO9001
– Quality Management Systems
• ISO14001
– Environmental Management Systems
Sets principles of Records & Information Management practice
• Organization institute comprehensive program
• Characteristics, Authenticity, and Integrity of a record
• Based on Functional Classification
Design and implementation of record systems
• Integrity of the system
• Compliance to legal and regulatory environment
• Documenting records transactions
Source: ISO http://www.iso.org/iso/catalogue_detail?csnumber=31908
April 3, 2012
ARMA Toronto Chapter
25. RIM: Best Practice GARP
GARP Capability Maturity Model
Information Governance with
Generally Accepted
Recordkeeping Principles
(GARP)
8 Principles
Accountability
Integrity
Protection
Compliance
Availability
Retention
Disposition
Transparency
GARP Maturity Level
Colour Status
1
Sub-standard
RED
2
In Development
ORANGE
3
Essential
AMBER
4
Proactive
BLUE
5
Transformational
GREEN
Source: ARMA http://www.arma.org/garp/index.cfm
April 3, 2012
ARMA Toronto Chapter
26. RIM: Integrate to Other Programs
Safety or Sustainability have become the culture
of most organizations
It is the first item addressed in meetings
It is measured and reported on
RIM Practice must become the culture of our
business, a part of day-to-day work
Supporting safety or sustainability
Measured and reported on
April 3, 2012
ARMA Toronto Chapter
27. Keep the goal in mind
April 3, 2012
ARMA Toronto Chapter
28. Risk Vs. Rewards for Business
Which version
do you want to
present in
court?
Rewards – Clear Vision
Risk – The Blind
Good governance & transparency
Lack of Governance - ad hoc
RIM Manager is in charge
IT is in charge??????
Can identify a record and a copy
Don’t know what are records
Can identify record authors, custodians and users
Don’t know the custodians
Auditable - demonstrates due diligence
Inability to audit
Controlled record types and sources
Number of uncontrolled
information types and sources
Avoids uncontrolled repositories
Volume of duplication
Reduced volume – original records
Lack of information category
Global search categories – relevancy
structure
Integration of Knowledge Management
Too much technology
Can find everything quickly and efficiently – better
Can’t find anything easily
decisions
Poor basis for business decisions
Controlled technology evolution
No idea what is really happening
Reduced stress to the organization and its personnel
ECM deployments tend to fail
ECM has a solid foundation and can succeed
Etc.
Etc.
ROI – Risk of Incarceration (reduced)
(reduced)
April 3, 2012
ARMA Toronto Chapter
29. Who do you hire?
When you have a financial or
accounting problem,
who do you turn to, or hire?
When you have a technology
or computing problem,
who do you turn to, or hire?
When you need legal advice
or have a legal problem,
who do you turn to, or hire?
When you have an records or
information management problem,
who do you turn to, or hire?
April 3, 2012
ARMA Toronto Chapter
30. Hire a RIM Professional
RIM Professionals are trained to develop and manage records and information
“RIM professionals can offer a safe harbor of sorts….
RIM professionals understand how information and records support the business
and interact with employees on a day-to-day basis on the creation, development,
issuance, and management of business records.
RIM professionals understand the key legal and IT issues and must collaborate
effectively with staff in those departments to ensure the implementation and
management of a solid, documented, and explainable records management
program.
When a RIM program is in effect and adhered to as it is written – and the
organization can show proof of compliance with the program – the organization’s
attorneys are in a much better position to defend its ediscovery processes and the
information it did – or didn’t produce.”
Resources:
American Records Management Association (ARMA)
• http://www.arma.org/
• Chapters in Canada
April 3, 2012
ARMA Toronto Chapter
31. Lessons Learned
Collect stories about records and information failures
Have a clear vision of what is required and how it will work
Connect the business case and practice to operations
Senior management sponsorship hard to get and keep
Get the best experts to advise on program development
Develop a complete eco-system for information
Pick the easy targets, the others will see the results
In-house IT technical support is critical
But watch out for IT practices and initiatives that conflict with RIM
The training program will make or break the deployment
Develop and integrate auditing of the program
Network, tell your story, be involved
Plant seeds
April 3, 2012
ARMA Toronto Chapter