Records Management & Compliance: Making the Connection
Information Management Journal, May/Jun 2004 by Kahn, Randolph A
7 Program Improvement
The seventh IMC key is recognizing when the system is not working and doing something about it. When programmatic failures become known, the system may need an overhaul. In one company, for example, instead of having a company-wide method for determining how e-records should be stored and indexed, that responsibility was left to the technology owners' discretion. In the interest of saving some storage space, a technology professional decided to index tens of millions of insurance claims by claim number only. When a regulator asked for all retained claims to be searched by plan name, claimant name, and other criteria, it could not be done. The company had to spend millions to search for the requested e-records. Had a company-wide list of indexing criteria been developed and provided to all system owners, the problem could have been averted. It is bad business and a wasteful investment in technology to capture, store, and migrate company e-records but not be able to access them when needed.
We live in interesting, albeit particularly unforgiving, times, especially as they relate to records mismanagement. When records-related mishaps bring down companies and their executives alike, it is reasonable for a company to ask itself whether its program is really good enough to protect the company. There has never been a better time to take a closer look at just how good a records management program is and seriously consider applying IMC. In the end, if a program is going to be evaluated by compliance principles, it should be built on the IMC principles.
References
"FDIC Information Security: Improvements Made but Weaknesses Remain" (Report to the Board of Directors, Federal Deposit Insurance Corp.). Washington, D.C.: U.S. General Accounting Office, 2002.
"Federal Judge Appoints WorldCom Monitor." Reuters. 3 July 2002.
Guidelines Manual, §3E1.1. United States Sentencing Commission. 2002.
"Information Management: Challenges in Managing and Preserving Electronic Records." Washington, D.C.: U.S. General Accounting Office (GAO-O2-586), 2002. Available at http://www.gao.gov/new.items/d02586.pdf (accessed 5 March 2004).
Kahn, Randolph A. and Barclay T. Blair. Information
Nation: Seven Keys to Information Management
Compliance. Silver Spring, MD: AIIM, 2004.
Levitt, Mark and Robert P. Mahowald. "Worldwide Email Usage Forecast, 2002-2006: Know What's Coming Your Way." Framingham, MA: IDC, 2002. Available at http://www.idc.com/getdoc.jhtml?containerId=27975 (accessed 5 March 2004).
Lyman, Peter and Hal R. Varian. "How Much Information?" Berkeley, CA: University of CaliforniaBerkeley School of Information Management and Science, 2003. Available at http://www.sims.berkeley.edu/research/projects/howmuch-info-2003 (accessed 5 March 2004).
"SEC, NYSE, NASD Fine Five Firms Total of $8.25 Million for Failure to Preserve E-Mail Communications." Securities and Exchange Commission press release. 3 December 2002. Available at http://www.sec.gov/news/press/2002-173.htm (accessed 5 March 2004).
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