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The Chief Information Offi cer’s Body of Knowledge: People, Process, and Technology by Dean Lane

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Enterprise Performance Management Done Right: An Operating System for Your Organization by Ron Dimon

Executive’s Guide to Virtual Worlds: How Avatars Are Transforming Your Business and Your Brand by Lonnie Bensond

IT Leadership Manual: Roadmap to Becoming a Trusted Business Partner by Alan R. r Guibord

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Unleashing the Power of IT: Bringing People, Business, and Technology Together by Dan Roberts

The U.S. Technology Skills Gap: What Every Technology Executive Must Know to Save America’s Future by Gary J. Beach

Information Governance: Concepts, Strategies and Best Practices by Robert F. Smallwoods

Robert F. Smallwood




Cover image: © iStockphoto / IgorZh Cover design: Wiley

Copyright © 2014 by Robert F. Smallwood. All rights reserved.

Chapter 7 © 2014 by Barclay Blair

Portions of Chapter 8 © 2014 by Randolph Kahn

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Smallwood, Robert F., 1959- Information governance : concepts, strategies, and best practices / Robert F. Smallwood. pages cm. — (Wiley CIO series)

ISBN 978-1-118-21830-3 (cloth); ISBN 978-1-118-41949-6 (ebk); ISBN 978-1-118-42101-7 (ebk) 1. Information technology—Management. 2. Management information systems. 3. Electronic

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For my sons

and the next generation of tech-savvy managers





PART ONE—Information Governance Concepts, Defi nitions, and Principles 1p

CHAPTER 1 The Onslaught of Big Data and the Information Governance Imperative 3

Defi ning Information Governance 5

IG Is Not a Project, But an Ongoing Program 7

Why IG Is Good Business 7

Failures in Information Governance 8

Form IG Policies, Then Apply Technology for Enforcement 10

Notes 12

CHAPTER 2 Information Governance, IT Governance, Data Governance: What’s the Difference? 15

Data Governance 15

IT Governance 17

Information Governance 20

Impact of a Successful IG Program 20

Summing Up the Differences 21

Notes 22

CHAPTER 3 Information Governance Principles 25

Accountability Is Key 27

Generally Accepted Recordkeeping Principles® 27 Contributed by Charmaine Brooks, CRM

Assessment and Improvement Roadmap 34

Who Should Determine IG Policies? 35

Notes 38

PART TWO—Information Governance Risk Assessment and Strategic Planning 41g g

CHAPTER 4 Information Risk Planning and Management 43

Step 1: Survey and Determine Legal and Regulatory Applicability and Requirements 43


Step 2: Specify IG Requirements to Achieve Compliance 46

Step 3: Create a Risk Profi le 46

Step 4: Perform Risk Analysis and Assessment 48

Step 5: Develop an Information Risk Mitigation Plan 49

Step 6: Develop Metrics and Measure Results 50

Step 7: Execute Your Risk Mitigation Plan 50

Step 8: Audit the Information Risk Mitigation Program 51

Notes 51

CHAPTER 5 Strategic Planning and Best Practices for Information Governance 53

Crucial Executive Sponsor Role 54

Evolving Role of the Executive Sponsor 55

Building Your IG Team 56

Assigning IG Team Roles and Responsibilities 56

Align Your IG Plan with Organizational Strategic Plans 57

Survey and Evaluate External Factors 58

Formulating the IG Strategic Plan 65

Notes 69

CHAPTER 6 Information Governance Policy Development 71

A Brief Review of Generally Accepted Recordkeeping Principles® 71

IG Reference Model 72

Best Practices Considerations 75

Standards Considerations 76

Benefi ts and Risks of Standards 76

Key Standards Relevant to IG Efforts 77

Major National and Regional ERM Standards 81

Making Your Best Practices and Standards Selections to Inform Your IG Framework 87

Roles and Responsibilities 88

Program Communications and Training 89

Program Controls, Monitoring, Auditing and Enforcement 89

Notes 91

PART THREE—Information Governance Key Impact Areas Based on the IG Reference Model 95p

CHAPTER 7 Business Considerations for a Successful IG Program 97

By Barclay T. Blair

Changing Information Environment 97


Calculating Information Costs 99

Big Data Opportunities and Challenges 100

Full Cost Accounting for Information 101

Calculating the Cost of Owning Unstructured Information 102

The Path to Information Value 105

Challenging the Culture 107

New Information Models 107

Future State: What Will the IG-Enabled Organization Look Like? 110

Moving Forward 111

Notes 113

CHAPTER 8 Information Governance and Legal Functions 115

By Robert Smallwood with Randy Kahn, Esq., and Barry Murphy

Introduction to e-Discovery: The Revised 2006 Federal Rules of Civil Procedure Changed Everything 115

Big Data Impact 117

More Details on the Revised FRCP Rules 117

Landmark E-Discovery Case: Zubulake v. UBS Warburg 119

E-Discovery Techniques 119

E-Discovery Reference Model 119

The Intersection of IG and E-Discovery 122 By Barry Murphy

Building on Legal Hold Programs to Launch Defensible Disposition 125 By Barry Murphy

Destructive Retention of E-Mail 126

Newer Technologies That Can Assist in E-Discovery 126

Defensible Disposal: The Only Real Way To Manage Terabytes and Petabytes 130 By Randy Kahn, Esq.

Retention Policies and Schedules 137 By Robert Smallwood, edited by Paula Lederman, MLS

Notes 144

CHAPTER 9 Information Governance and Records and Information Management Functions 147

Records Management Business Rationale 149

Why Is Records Management So Challenging? 150

Benefi ts of Electronic Records Management 152

Additional Intangible Benefi ts 153

Inventorying E-Records 154

Generally Accepted Recordkeeping Principles® 155

E-Records Inventory Challenges 155


Records Inventory Purposes 156

Records Inventorying Steps 157

Ensuring Adoption and Compliance of RM Policy 168

General Principles of a Retention Scheduling 169

Developing a Records Retention Schedule 170

Why Are Retention Schedules Needed? 171

What Records Do You Have to Schedule? Inventory and Classifi cation 173

Rationale for Records Groupings 174

Records Series Identifi cation and Classifi cation 174

Retention of E-Mail Records 175

How Long Should You Keep Old E-Mails? 176

Destructive Retention of E-Mail 177

Legal Requirements and Compliance Research 178

Event-Based Retention Scheduling for Disposition of E-Records 179

Prerequisites for Event-Based Disposition 180

Final Disposition and Closure Criteria 181

Retaining Transitory Records 182

Implementation of the Retention Schedule and Disposal of Records 182

Ongoing Maintenance of the Retention Schedule 183

Audit to Manage Compliance with the Retention Schedule 183

Notes 186

CHAPTER 10 Information Governance and Information Technology Functions 189

Data Governance 191

Steps to Governing Data Effectively 192

Data Governance Framework 193

Information Management 194

IT Governance 196

IG Best Practices for Database Security and Compliance 202

Tying It All Together 204

Notes 205

CHAPTER 11 Information Governance and Privacy and Security Functions 207

Cyberattacks Proliferate 207

Insider Threat: Malicious or Not 208

Privacy Laws 210

Defense in Depth 212

Controlling Access Using Identity Access Management 212

Enforcing IG: Protect Files with Rules and Permissions 213


Challenge of Securing Confi dential E-Documents 213

Apply Better Technology for Better Enforcement in the Extended Enterprise 215

E-Mail Encryption 217

Secure Communications Using Record-Free E-Mail 217

Digital Signatures 218

Document Encryption 219

Data Loss Prevention (DLP) Technology 220

Missing Piece: Information Rights Management (IRM) 222

Embedded Protection 226

Hybrid Approach: Combining DLP and IRM Technologies 227

Securing Trade Secrets after Layoffs and Terminations 228

Persistently Protecting Blueprints and CAD Documents 228

Securing Internal Price Lists 229

Approaches for Securing Data Once It Leaves the Organization 230

Document Labeling 231

Document Analytics 232

Confi dential Stream Messaging 233

Notes 236

PART FOUR—Information Governance for Delivery Platforms 239y

CHAPTER 12 Information Governance for E-Mail and Instant Messaging 241

Employees Regularly Expose Organizations to E-Mail Risk 242

E-Mail Polices Should Be Realistic and Technology Agnostic 243

E-Record Retention: Fundamentally a Legal Issue 243

Preserve E-Mail Integrity and Admissibility with Automatic Archiving 244

Instant Messaging 247

Best Practices for Business IM Use 247

Technology to Monitor IM 249

Tips for Safer IM 249

Notes 251

CHAPTER 13 Information Governance for Social Media 253

By Patricia Franks, Ph.D, CRM, and Robert Smallwood

Types of Social Media in Web 2.0 253

Additional Social Media Categories 255

Social Media in the Enterprise 256

Key Ways Social Media Is Different from E-Mail and Instant Messaging 257

Biggest Risks of Social Media 257

Legal Risks of Social Media Posts 259


Tools to Archive Social Media 261

IG Considerations for Social Media 262

Key Social Media Policy Guidelines 263

Records Management and Litigation Considerations for Social Media 264

Emerging Best Practices for Managing Social Media Records 267

Notes 269

CHAPTER 14 Information Governance for Mobile Devices 271

Current Trends in Mobile Computing 273

Security Risks of Mobile Computing 274

Securing Mobile Data 274

Mobile Device Management 275

IG for Mobile Computing 276

Building Security into Mobile Applications 277

Best Practices to Secure Mobile Applications 280

Developing Mobile Device Policies 281

Notes 283

CHAPTER 15 Information Governance for Cloud Computing 285

By Monica Crocker CRM, PMP, CIP, and Robert Smallwood

Defi ning Cloud Computing 286

Key Characteristics of Cloud Computing 287

What Cloud Computing Really Means 288

Cloud Deployment Models 289

Security Threats with Cloud Computing 290

Benefi ts of the Cloud 298

Managing Documents and Records in the Cloud 299

IG Guidelines for Cloud Computing Solutions 300

Notes 301

CHAPTER 16 SharePoint Information Governance 303

By Monica Crocker, CRM, PMP, CIP, edited by Robert Smallwood

Process Change, People Change 304

Where to Begin the Planning Process 306

Policy Considerations 310

Roles and Responsibilities 311

Establish Processes 312

Training Plan 313

Communication Plan 313

Note 314


PART FIVE—Long-Term Program Issues 315g g

CHAPTER 17 Long-Term Digital Preservation 317

By Charles M. Dollar and Lori J. Ashley

Defi ning Long-Term Digital Preservation 317

Key Factors in Long-Term Digital Preservation 318

Threats to Preserving Records 320

Digital Preservation Standards 321

PREMIS Preservation Metadata Standard 328

Recommended Open Standard Technology-Neutral Formats 329

Digital Preservation Requirements 333

Long-Term Digital Preservation Capability Maturity Model® 334

Scope of the Capability Maturity Model 336

Digital Preservation Capability Performance Metrics 341

Digital Preservation Strategies and Techniques 341

Evolving Marketplace 344

Looking Forward 344

Notes 346

CHAPTER 18 Maintaining an Information Governance Program and Culture of Compliance 349

Monitoring and Accountability 349

Staffi ng Continuity Plan 350

Continuous Process Improvement 351

Why Continuous Improvement Is Needed 351

Notes 353

APPENDIX A Information Organization and Classifi cation: Taxonomies and Metadata 355

By Barb Blackburn, CRM, with Robert Smallwood; edited by Seth Earley

Importance of Navigation and Classifi cation 357

When Is a New Taxonomy Needed? 358

Taxonomies Improve Search Results 358

Metadata and Taxonomy 359

Metadata Governance, Standards, and Strategies 360

Types of Metadata 362

Core Metadata Issues 363

International Metadata Standards and Guidance 364

Records Grouping Rationale 368

Business Classifi cation Scheme, File Plans, and Taxonomy 368

Classifi cation and Taxonomy 369


Prebuilt versus Custom Taxonomies 370

Thesaurus Use in Taxonomies 371

Taxonomy Types 371

Business Process Analysis 377

Taxonomy Testing: A Necessary Step 379

Taxonomy Maintenance 380

Social Tagging and Folksonomies 381

Notes 383

APPENDIX B Laws and Major Regulations Related to Records Management 385

United States 385

Canada 387 By Ken Chasse, J.D., LL.M.

United Kingdom 389

Australia 391

Notes 394

APPENDIX C Laws and Major Regulations Related to Privacy 397

United States 397

Major Privacy Laws Worldwide, by Country 398

Notes 400







Information governance (IG) has emerged as a key concern for business executivesand managers in today’s environment of Big Data, increasing information risks, co-lossal leaks, and greater compliance and legal demands. But few seem to have a clear understanding of what IG is; that is, how you defi ne what it is and is not, and how to implement it. This book clarifi es and codifi es these defi nitions and provides key in- sights as to how to implement and gain value from IG programs. Based on exhaustive research, and with the contributions of a number of industry pioneers and experts, this book lays out IG as a complete discipline in and of itself for the fi rst time.

IG is a super-discipline that includes components of several key fi elds: law, records management, information technology (IT), risk management, privacy and security, and business operations. This unique blend calls for a new breed of information pro- fessional who is competent across these established and quite complex fi elds. Training and education are key to IG success, and this book provides the essential underpinning for organizations to train a new generation of IG professionals.

Those who are practicing professionals in the component fi elds of IG will fi nd the book useful in expanding their knowledge from traditional fi elds to the emerging tenets of IG. Attorneys, records and compliance managers, risk managers, IT manag- ers, and security and privacy professionals will fi nd this book a particularly valuable resource.

The book strives to offer clear IG concepts, actionable strategies, and proven best practices in an understandable and digestible way; a concerted effort was made to simplify language and to offer examples. There are summaries of key points through- out and at the end of each chapter to help the reader retain major points. The text is organized into fi ve parts: (1) Information Governance Concepts, Defi nitions, and Principles; (2) IG Risk Assessment and Strategic Planning; (3) IG Key Impact Areas; (4) IG for Delivery Platforms; and (5) Long-Term Program Issues. Also included are appendices with detailed information on taxonomy and metadata design and on re- cords management and privacy legislation.

One thing that is sure is that the complex fi eld of IG is evolving. It will continue to change and solidify. But help is here: No other book offers the kind of compre- hensive coverage of IG contained within these pages. Leveraging the critical advice provided here will smooth your path to understanding and implementing successful IG programs.

Robert F. Smallwood



I would like to sincerely thank my colleagues for their support and generous contribu-tion of their expertise and time, which made this pioneering text possible. Many thanks to Lori Ashley, Barb Blackburn, Barclay Blair, Charmaine Brooks, Ken Chasse, Monica Crocker, Charles M. Dollar, Seth Earley, Dr. Patricia Franks, Randy Kahn, Paula Lederman, and Barry Murphy.

I am truly honored to include their work and owe them a great debt of gratitude.

PART ONE Information Governance Concepts, Defi nitions, and Principles


The Onslaught of Big Data and the Information Governance Imperative

C H A P T E R 1

The value of information in business is rising, and business leaders are more andmore viewing the ability to govern, manage, and harvest information as critical to success. Raw data is now being increasingly viewed as an asset that can be leveraged, just like fi nancial or human capital.1 Some have called this new age of “Big Data” the “industrial revolution of data.”

According to the research group Gartner, Inc., Big Data is defi ned as “high-volume, high-velocity and high-variety information assets that demand cost-effective, inno- vative forms of information processing for enhanced insight and decision making.” 2 A practical defi nition should also include the idea that the amount of data—both struc- tured (in databases) and unstructured (e.g., e-mail, scanned documents) is so mas- sive that it cannot be processed using today’s database tools and analytic software techniques. 3

In today’s information overload era of Big Data—characterized by massive growth in business data volumes and velocity—the ability to distill key insights from enor- mous amounts of data is a major business differentiator and source of sustainable com- petitive advantage. In fact, a recent report by the World Economic Forum stated that data is a new asset class and personal data is “the new oil.” 4 And we are generating more than we can manage effectively with current methods and tools.

The Big Data numbers are overwhelming: Estimates and projections vary, but it has been stated that 90 percent of the data existing worldwide today was created in the last two years 5 and that every two days more information is generated than was from the dawn of civilization until 2003. 6 This trend will continue: The global market for Big Data technology and services is projected to grow at a compound annual rate of 27 percent through 2017, about six times faster than the general information and com- munications technology (ICT) market. 7

Many more comparisons and statistics are available, and all demonstrate the incredible and continued growth of data.

Certainly, there are new and emerging opportunities arising from the accu- mulation and analysis of all that data we are busy generating and collecting. New enterprises are springing up to capitalize on data mining and business intelligence opportunities. The U.S. federal government joined in, announcing $200 million in Big Data research programs in 2012.8


Big Data values massive accumulation of data, whereas in business, e-discovery realities and potential legal liabilities dictate that data be culled to only that which has clear business value.

But established organizations, especially larger ones, are being crushed by this onslaught of Big Data: It is just too expensive to keep all the information that is being generated, and unneeded information is a sort of irrelevant sludge for decision makers to wade through. They have diffi culty knowing which information is an accurate and meaningful “wheat” and which is simply irrelevant “chaff.” This means they do not have the precise information they need to base good business decisions upon.

And all that Big Data piling up has real costs: The burden of massive stores of information has increased storage management costs dramatically, caused overloaded systems to fail, and increased legal discovery costs. 9 Further, the longer that data is kept, the more likely that it will need to be migrated to newer computing platforms, driving up conversion costs; and legally, there is the risk that somewhere in that mountain of data an organization stores is a piece of information that represents a signifi cant legal liability.10

This is where the worlds of Big Data and business collide . For Big Data proponents, more data is always better, and there is no perceived downside to accumulation of mas- sive amounts of data. In the business world, though, the realities of legal e-discovery mean the opposite is true. 11 To reduce risk, liability, and costs, it is critical for unneeded information to be disposed of in a systematic, methodical, and “legally defensible” (jus- tifi able in legal proceedings) way, when it no longer has legal, regulatory, or business value. And there also is the high-value benefi t of basing decisions on better, cleaner data, which can come about only through rigid, enforced information governance (IG) policies that reduce information glut.

Organizations are struggling to reduce and right-size their information footprint by discarding superfl uous and redundant data, e-documents, and information. But the critical issue is devising policies, methods, and processes and then deploying information technol- ogy (IT) to sort through which information is valuable and which no longer has business value and can be discarded.

IT, IG, risk, compliance, and legal representatives in organizations have a clear sense that most of the information stored is unneeded, raises costs, and poses risks. According to a survey taken at a recent Compliance, Governance and Oversight Counsel summit, respondents estimated that approximately 25 percent of information stored in organizations has real business value, while 5 percent must be kept as busi- ness records and about 1 percent is retained due to a litigation hold. “This means that

The onslaught of Big Data necessitates that information governance (IG) be implemented to discard unneeded data in a legally defensible way.


[about] 69 percent of information in most companies has no business, legal, or regulatory value. Companies that are able to dispose of this data debris return more profi t to sharehold- ers, can leverage more of their IT budgets for strategic investments, and can avoid excess expense in legal and regulatory response” (emphasis added). 12

With a smaller information footprint , organizations can more easily fi nd what they tt need and derive business value from it.13 They must eliminate the data debris regularly and consistently, and to do this, processes and systems must be in place to cull valuable information and discard the data debris daily. An IG program sets the framework to accomplish this.

The business environment has also underscored the need for IG. According to Ted Friedman at Gartner, “The recent global fi nancial crisis has put information gov- ernance in the spotlight. . . . [It] is a priority of IT and business leaders as a result of various pressures, including regulatory compliance mandates and the urgent need for improved decision-making.” 14

And IG mastery is critical for executives: Gartner predicts that by 2016, one in fi ve chief information offi cers in regulated industries will be fi red from their jobs for failed IG initiatives. s 15

Defi ning Information Governance

IG is a sort of super discipline that has emerged as a result of new and tightened legislation governing businesses, external threats such as hacking and data breaches, and the recog- nition that multiple overlapping disciplines were needed to address today’s information management challenges in an increasingly regulated and litigated business environment.16

IG is a subset of corporate governance, and includes key concepts from re- cords management, content management, IT and data governance, information se- curity, data privacy, risk management, litigation readiness, regulatory compliance, long-term digital preservation , and even business intelligence. This also means that it includes related technology and discipline subcategories, such as document management, enterprise search, knowledge management, and business continuity/ disaster recovery.

Only about one quarter of information organizations are managing has real business value.

With a smaller information footprint, it is easier for organizations to fi nd the information they need and derive business value from it.

IG is a subset of corporate governance.


IG is a sort of superdiscipline that encompasses a variety of key concepts from a variety of related disciplines.

Practicing good IG is the essential foundation for building legally defensible disposition practices to discard unneeded information and to secure confi dential in- formation, which may include trade secrets, strategic plans, price lists, blueprints, or personally identifi able information (PII) subject to privacy laws; it provides the basis for consistent, reliable methods for managing data, e-documents, and records.

Having trusted and reliable records, reports, data, and databases enables managers to make key decisions with confi dence.17 And accessing that information and business intelligence in a timely fashion can yield a long-term sustainable competitive advan- tage, creating more agile enterprises.

To do this, organizations must standardize and systematize their handling of in- formation. They must analyze and optimize how information is accessed, controlled, managed, shared, stored, preserved, and audited. They must have complete, current, and relevant policies, processes, and technologies to manage and control information, including who is able to access what information , and when, to meet external legal and regulatory demands and internal governance policy requirements. In short, IG is about information control and compliance.

IG is a subset of corporate governance, which has been around as long as corpora- tions have existed. IG is a rather new multidisciplinary fi eld that is still being defi ned, but has gained traction increasingly over the past decade. The focus on IG comes not only from compliance, legal, and records management functionaries but also from ex- ecutives who understand they are accountable for the governance of information and that theft or erosion of information assets has real costs and consequences.

“Information governance” is an all-encompassing term for how an organization manages the totality of its information.

According to the Association of Records Managers and Administrators (ARMA), IG is “a strategic framework composed of standards, processes, roles, and metrics that hold organizations and individuals accountable to create, organize, secure, maintain, use, and dispose of information in ways that align with and contribute to the organization’s goals.”18

IG includes the set of policies, processes, and controls to manage information in compliance with external regulatory requirements and internal governance frameworks . Specifi c policiess apply to specifi c data and document types, records series, and other business informa- tion, such as e-mail and reports.

Stated differently, IG is “a quality-control discipline for managing, using, improv- ing, and protecting information.” 19

Practicing good IG is the essential foundation for building legally defensible disposition practices to discard unneeded information.


IG is “a strategic framework composed of standards, processes, roles, and metrics, that hold organizations and individuals accountable to create, orga- nize, secure, maintain, use, and dispose of information in ways that align with and contribute to the organization’s goals.” 20

Fleshing out the defi nition further: “Information governance is policy-based man- agement of information designed to lower costs, reduce risk, and ensure compliance with legal, regulatory standards, and/or corporate governance.”21 IG necessarily in- corporates not just policies but information technologies to audit and enforce those policies. The IG team must be cognizant of information lifecycle issues and be able to apply the proper retention and disposition policies, including digital preservation where records need to be maintained for long periods.

IG Is Not a Project, But an Ongoing Program

IG is an ongoing program , not a one-time project. IG provides an umbrella to manage and control information output and communications. Since technologies change so quickly, it is necessary to have overarching policies that can manage the various IT platforms that an organization may use.

Compare it to a workplace safety program; every time a new location, team member, piece of equipment, or toxic substance is acquired by the organization, the workplace safety program should dictate how that is handled. If it does not, the workplace safety policies/procedures/training that are part of the workplace safety program need to be updated. Regular reviews are conducted to ensure the program is being followed and ad- justments are made based on the fi ndings. The effort never ends. s 22 The same is true for IG.

IG is not only a tactical program to meet regulatory, compliance, and litigation demands. It can be strategic , in that it is the necessary underpinning for developing a c management strategy that maximizes knowledge worker productivity while minimiz- ing risk and costs.

Why IG Is Good Business

IG is a tough sell. It can be diffi cult to make the business case for IG, unless there has been some major compliance sanction, fi ne, legal loss, or colossal data breach. In fact, the largest

IG is how an organization maintains security, complies with regulations, and meets ethical standards when managing information.

IG is a multidisciplinary program that requires an ongoing effort.


impediment to IG adoption is simply identifying its benefi ts and costs, according to the Economist Intelligence Unit. Sure, the enterprise needs better control over its information, but how much better? At what cost? What is the payback period and the return on investment? 23

It is challenging to make the business case for IG, yet making that case is funda- mental to getting IG efforts off the ground.

Here are eight reasons why IG makes good business sense, from IG thought leader Barclay Blair:

1. We can’t keep everything forever. IG makes sense because it enables organiza- tions to get rid of unnecessary information in a defensible manner. Organi- zations need a sensible way to dispose of information in order to reduce the cost and complexity of the IT environment. Having unnecessary informa- tion around only makes it more diffi cult and expensive to harness informa- tion that has value.

2. We can’t throw everything away. IG makes sense because organizations can’t keep everything forever, nor can they throw everything away. We need information—the right information, in the right place, at the right time. Only IG provides the framework to make good decisions about what infor- mation to keep.

3. E-discovery. IG makes sense because it reduces the cost and pain of discov- ery. Proactively managing information reduces the volume of information exposed to e-discovery and simplifi es the task of fi nding and producing responsive information.

4. Your employees are screaming for it—just listen. IG makes sense because it helps knowledge workers separate “signal” from “noise” in their informa- tion fl ows. By helping organizations focus on the most valuable informa- tion, IG improves information delivery and improves productivity.

5. It ain’t gonna get any easier. IG makes sense because it is a proven way for organizations to respond to new laws and technologies that create new re- quirements and challenges. The problem of IG will not get easier over time, so organizations should get started now.

6. The courts will come looking for IG. IG makes sense because courts and regu- lators will closely examine your IG program. Falling short can lead to fi nes, sanctions, loss of cases, and other outcomes that have negative business and fi nancial consequences.

7. Manage risk: IG is a big one. Organizations need to do a better job of identi- fying and managing risk. The risk of information management failures is a critical risk that IG helps to mitigate.

8. E-mail: Reason enough. IG makes sense because it helps organizations take con- trol of e-mail. Solving e-mail should be a top priority for every organization. 24

Failures in Information Governance

The failure to implement and enforce IG can lead to vulnerabilities that can have dire consequences. The theft of confi dential U.S. National Security Agency documents


by Edward Snowden in 2013 could have been prevented by properly enforced IG. Also, Ford Motor Company is reported to have suffered a loss estimated at $50 to $100 million as a result of the theft of confi dential documents by one of its own em- ployees. A former product engineer who had access to thousands of trade secret docu- ments and designs sold them to a competing Chinese car manufacturer. A strong IG program would have controlled and tracked access and prevented the theft while pro- tecting valuable intellectual property. 25

Law enforcement agencies have also suffered from poor IG. In a rather frivolous case in 2013 that highlighted the lack of policy enforcement for the mobile environ- ment, it was reported that U.S. agents from the Federal Bureau of Investigation used government-issued mobile phones to send explicit text messages and nude photographs to coworkers. The incidents did not have a serious impact but did compromise the agency and its integrity, and “adversely affected the daily activities of several squads.” 26 Proper mobile communications policies were obviously not developed and enforced.

IG is also about information security and privacy, and serious thought must be given when creating policies to safeguard personal, classifi ed or confi dential informa- tion. Schemes to compromise or steal information can be quite deceptive and devious, masked by standard operating procedures—if proper IG controls and monitoring are not in place. To wit: Granting remote access to confi dential information assets for key personnel is common. Granting medical leave is also common. But a deceptive and dishonest employee could feign a medical leave while downloading volumes of confi dential information assets for a competitor—and that is exactly what happened at Accenture, a global consulting fi rm. During a fraudulent medical leave, an employee was allowed access to Accenture’s Knowledge Exchange (KX), a detailed knowledge base containing previous proposals, expert reports, cost-estimating guidelines, and case studies. This activity could have been prevented by monitoring and analytics that would have shown an inordinate amount of downloads—especially for an “ailing” em- ployee. The employee then went to work for a direct competitor and continued to download the confi dential information from Accenture, estimated to be as many as 1,000 critical documents. While the online access to KX was secure, the use of the electronic documents could have been restricted even after the documents were down-r loaded, if IG measures were in place and newer technologies (such as information rights management [IRM] software) were deployed to secure them directly and main- tain that security remotely. With IRM, software security protections can be employed to seal the e-documents and control their use—even after they leave the organization. More details on IRM technology and its capabilities is presented later in this book.

Other recent high-profi le data and document leakage cases revealing information security weaknesses that could have been prevented by a robust IG program include:

■ Huawei Technologies, the largest networking and mobile communications company in China, was sued by U.S.-based Motorola for allegedly conspiring to steal trade secrets through former Motorola employees.

Ford’s loss from stolen documents in a single case of intellectual property (IP) theft was estimated at $50 to $100 million.


■ MI6, the U.K. equivalent of the U.S. Central Intelligence Agency, learned that one of its agents in military intelligence attempted to sell confi dential docu- ments to the intelligence services of the Netherlands for £2 million GBP ($3 million USD).

And breaches of personal information revealing failures in privacy protection abound; here are just a few:

■ Health information of 1,600 cardiology patients at Texas Children’s Hospital was compromised when a doctor’s laptop was stolen. The information includ- ed personal and demographic information about the patients, including their names, dates of birth, diagnoses, and treatment histories. 27

■ U.K. medics lost the personal records of nearly 12,000 National Health Service patients in just eight months. Also, a hospital worker was suspended after it was discovered he had sent a fi le containing pay-slip details for every member of staff to his home e-mail account. 28

■ Personal information about more than 600 patients  of the Fraser Health Authority in British Columbia, Canada, was stored on a laptop stolen from Burnaby General Hospital.

■ In December 2013, Target stores in the U.S. reported that as many as 110 million customer records had been breached in a massive attack that lasted weeks.

The list of breaches and IG failures could go on and on, more than fi lling the pages of this book. It is clear that it is occurring and that it will continue. IG controls to safeguard confi dential information assets and protect privacy cannot rely solely on the trustwor- thiness of employees and basic security measures. Up-to-date IG policies and enforcement efforts and newer technology sets are needed, with active, consistent monitoring and program adjustments to continue to improve.

Executives and senior managers can no longer avoid the issue, as it is abundantly clear that the threat is real and the costs of taking such avoidable risks can be high. A single security breach is an IG failure and can cost the entire business. According to Debra Logan of Gartner, “When organizations suffer high-profi le data losses, espe- cially involving violations of the privacy of citizens or consumers, they suffer serious reputational damage and often incur fi nes or other sanctions. IT leaders will have to take at least part of the blame for these incidents.” 29

Form IG Policies, Then Apply Technology for Enforcement

Typically, some policies governing the use and control of information and records may have been established for fi nancial and compliance reports, and perhaps e-mail, but they are often incomplete and out-of-date and have not been adjusted for changes in the business environment, such as new technology platforms (e.g., Web 2.0, social

IG controls to safeguard confi dential information assets and protect privacy can- not rely solely on the trustworthiness of employees and basic security measures.


media), changing laws (e.g., U.S. Federal Rules of Civil Procedure 2006 changes), and additional regulations.

Further adding to the challenge is the rapid proliferation of mobile devices like tablets, phablets, and smartphones used in business—information can be more easily lost or stolen—so IG efforts must be made to preserve and protect the enterprise’s information assets.

Proper IG requires that policies are fl exible enough not to hinder the proper fl ow of information in the heat of the business battle yet strict enough to control and audit for misuse, policy violations, or security breaches. This is a continuous iterative policy- making process that must be monitored and fi ne-tuned. Even with the absolute best efforts, some policies will miss the mark and need to be reviewed and adjusted.

Getting started with IG awareness is the crucial fi rst step. It may have popped up on an executive’s radar at one point or another and an effort might have been made, but many organizations leave these policies on the shelf and do not revise them on a regular basis.

IG is the necessary underpinning for a legally defensible disposition program that discards data debris and helps narrow the search for meaningful information on which to base business decisions. IG is also necessary to protect and preserve critical infor- mation assets. An IG strategy should aim to minimize exposure to risk, at a reasonable cost level, while maximizing productivity and improving the quality of information delivered to knowledge users.

But a reactive, tactical project approach is not the way to go about it—haphazardly t swatting at technological, legal, and regulatory fl ies. A proactive, strategic program, with a clear, accountable sponsor, an ongoing plan, and regular review process, is the only way to continuously adjust IG policies to keep them current so that they best serve the organization’s needs.

Some organizations have created formal governance bodies to establish strat- egies, policies, and procedures surrounding the distribution of information inside and outside the enterprise. These governance bodies, steering committees, or teams should include members from many different functional areas, since proper IG ne- cessitates input from a variety of stakeholders. Representatives from IT, records man- agement, corporate or agency archiving, risk management, compliance, operations, human resources, security, legal, fi nance, and perhaps knowledge management are typically a part of IG teams. Often these efforts are jump-started and organized by an executive sponsor who utilizes third-party consulting resources that specialize in IG efforts, especially considering the newness of IG and its emerging best practices.

So in this era of ever-growing Big Data, leveraging IG policies to focus on re- taining the information that has real business value, while discarding the majority of information that has no value and carries associated increased costs and risks, is criti- cal to success for modern enterprises. This must be accomplished in a systematic, consistent, and legally defensible manner by implementing a formal IG program. Other crucial elements of an IG program are the steps taken to secure confi dential information by enforcing and monitoring policies using the appropriate information technologies.

Getting started with IG awareness is the crucial fi rst step.



■ The onslaught of Big Data necessitates that IG be implemented to discard unneeded data in a legally defensible way.

■ Big Data values massive accumulation of data, whereas in business, e-discovery realities and potential legal liabilities dictate that data be culled to only that which has clear business value.

■ Only about one quarter of the information organizations are managing has real business value.

■ With a smaller information footprint, it is easier for organizations to fi nd the information they need and derive business value from it.

■ IG is a subset of corporate governance and encompasses the policies and leveraged technologies meant to manage what corporate information is re- tained, where, and for how long, and also how it is retained.

■ IG is a sort of super discipline that encompasses a variety of key concepts from a variety of related and overlapping disciplines.

■ Practicing good IG is the essential foundation for building legally defensible disposition practices to discard unneeded information.

■ According to ARMA, IG is “a strategic framework composed of standards, processes, roles, and metrics that hold organizations and individuals account- able to create, organize, secure, maintain, use, and dispose of information in ways that align with and contribute to the organization’s goals.” 30

■ IG is how an organization maintains security, complies with regulations and laws, and meets ethical standards when managing information.

■ IG is a multidisciplinary program that requires an ongoing effort and active participation of a broad cross-section of functional groups and stakeholders.

■ IG controls to safeguard confi dential information assets and protect privacy cannot rely solely on the trustworthiness of employees and basic security measures.

■ Getting started with IG awareness is the crucial fi rst step.


1. The Economist, “Data, Data Everywhere,” February 25, 2010, 2. Gartner, Inc., “IT Glossary: Big Data,” (accessed April 15, 2013). 3. Webopedia, “Big Data,” (accessed April 15, 2013).


4. World Economic Forum, “Personal Data:The Emergence of a New Asset Class”(January 2011), http://

5. Deidra Paknad, “Defensible Disposal: You Can’t Keep All Your Data Forever,” July 17, 2012, www

6. Susan Karlin, “Earth’s Nervous System: Looking at Humanity Through Big Data,” www.fastcocreate .com/1681986/earth-s-nervous-system-looking-at-humanity-through-big-data#1(accessed March 5, 2013).

7. IDC Press Release, December 18, ,2013, New IDC Worldwide Big Data Technology and Services Forecast Shows Market Expected to Grow to $32.4 Billion in 2017

8. Steve Lohr, “How Big Data Became So Big,” New York Times, August 11, 2012, www.nytimes. com/2012/08/12/business/how-big-data-became-so-big-unboxed.html?_r=2&smid=tw-share&

9. Kahn Consulting, “Information Governance Brief,” sponsored by IBM, Brief-Defensible-Disposal.pdf (accessed March 4, 2013).

10. Barclay T. Blair, “Girding for Battle,” Law Technology News, October 1, 2012, nologynews/PubArticleLTN.jsp?id=1202572459732&thepage=1

11. Ibid. 12. Paknad, “Defensible Disposal.” 13. Randolph A. Kahn,, November 28, 2012. 14. Gartner Press Release, “Gartner Says Master Data Management Is Critical to Achieving Effective

Information Governance,”, January 19, 2012 15. Ibid. 16. Monica Crocker, e-mail to author, June 21, 2012. 17. Economist Intelligence Unit, “The Future of Information Governance,”

business-view/future-information-governance.htm (accessed November 14, 2013). 18. ARMA International, Glossary of Records and Information Management Terms , 4th ed., 2012, TR 22–2012.s 19. Arvind Krishna, “Three Steps to Trusting Your Data in 2011,” IT Business Edge , posted March 9, 2011, . (accessed November 14, 2013).

20. ARMA International, Glossary of Records and Information Management Terms , 4th ed., 2012, TR 22–2012.s 21. Laura DuBoisand Vivian Tero, “Practical Information Governance: Balancing Cost, Risk, and Pro-

ductivity,” IDC White Paper (August 2010), information-governance-ar.pdf

22. Monica Crocker, e-mail to author, June 21, 2012. 23. Barclay T. Blair, Making the Case for Information Governance: Ten Reasons IG Makes Sense , ViaLumina

Ltd, 2010. Online at (accessed November 14, 2013).

24. Barclay T. Blair, “8 Reasons Why Information Governance (IG) Makes Sense,” June 29, 2009, www. digitallandfi

25. Peter Abatan, “Corporate and Industrial Espionage to Rise in 2011,” Enterprise Digital Rights Man- agement, . (accessed November 14, 2013).

26. BBC News, “FBI Staff Disciplined for Sex Texts and Nude Pictures,” February 22, 2013,

27. Todd Ackerman, “Laptop Theft Puts Texas Children’s Patient Info at Risk,” Houston Chronicle , July 30, 2009, e php . (accessed March 2, 2012).

28. Jonny Greatrex, “Bungling West Midlands Medics Lose 12,000 Private Patient Records,” Sunday Mer- cury, September 5, 2010, gling-west-midlands-medics-lose-12–000-private-patient-records-66331–27203177/ (accessed March 2, 2012).

29. Gartner Press Release, “Gartner Says Master Data Management Is Critical to Achieving Effective Information Governance.”

30. ARMA International, Glossary of Records and Information Management Terms. s


Information Governance, IT Governance, Data Governance: What’s the Difference?

C H A P T E R 2

There has been a great deal of confusion around the term information gover-nance (IG) and how it is distinct from other similar industry terms, such as information technology (IT) governance and data governance . They are all a subset of corporate governance, and in the above sequence, become increasingly more granular in their approach. Data governance is a part of broader IT governance, which is also a part of even broader information governance. The few texts that exist have compounded the confusion by offering a limited defi nition of IG, or sometimes offering a defi nition of IG that is just plain incorrect , often confusing it with simple datat governance.

So in this chapter we spell out the differences and include examples in hopes of clarifying what the meaning of each term is and how they are related.

Data Governance

Data governance involves processes and controls to ensure that information at the data level—raw alphanumeric characters that the organization is gathering and inputting— is true and accurate, and unique (not redundant). It involves data cleansing ( or data scrubbing) to strip out corrupted, inaccurate, or extraneous data and gg de-duplication, to eliminate redundant occurrences of data.

Data governance focuses on information quality from the ground up at the lowest or root level, so that subsequent reports, analyses, and conclusions are based on clean, reliable, trusted data (or records) in database tables. Data governance is the most rudi- mentary level at which to implement information governance. Data governance efforts seek to ensure that formal management controls—systems, processes, and accountable employees who are stewards and custodians of the data—are implemented to govern critical data assets to improve data quality and to avoid negative downstream effects of poor data. The biggest negative consequence of poor or inaccurate data is poorly and inaccurately based decisions.


Data governance is a newer, hybrid quality control discipline that includes elements of data quality, data management, IG policy development, business process improvement, and compliance and risk management.

Data Governance Strategy Tips

Everyone in an organization wants good-quality data to work with. But it is not so easy to implement a data governance program. First of all, data is at such a low level that executives and board members are typically unaware of the details of the “smoky back room” of data collection: cleansing, normalization, and input. So it is diffi cult to gain an executive sponsor and funding to initiate the effort. 1 And if a data governance program does move forward, there are challenges in getting business users to adhere to new policies. This is a crucial point, since much of the data is being generated by business units. But there are some general guidelines that can help improve a data governance program’s chances for success:

■ Identify a measureable impact. A data governance program must be able to dem- onstrate business value, or it will not get the executive sponsorship and funding it needs to move forward. A readiness assessment should capture the current state of data quality and whether an enterprise or business unit level effort is warranted. Other key issues include: Can the organization save hard costs by implementing data governance? Can it reach more customers or increase revenue generated from existing customers?2

■ Assign accountability for data quality to business units, not IT. Typically, IT has had responsibility for data quality, yet it is mostly not under that department’s con- trol, since most of the data is being generated in the business units. A pointed effort must be made to push responsibility and ownership for data to the busi- ness units that create and use the data.

■ Recognize the uniqueness of data as an asset. Unlike other assets, such as people, factories, equipment, and even cash, data is largely unseen, out of sight, and intangible. It changes daily. It spreads throughout business units. It is copied and deleted. Data growth can spiral out of control, obscuring the data that has true business value. So data has to be treated differently, and its unique qualities must be considered.

■ Forget the past; implement a going-forward strategy. It is a signifi cantly greater task to try to improve data governance across the enterprise for existing data. Remember, you may be trying to fi x decades of bad behavior, mismanagement, and lack of governance. Taking an incremental approach with an eye to the future provides for a clean starting point and can substantially reduce the pain required to implement. A proven best practice is to implement a from-this- point-on strategy where new data governance policies for handling data are implemented beginning on a certain date.

Data governance uses techniques like data cleansing and de-duplication to improve data quality and reduce redundancies.


Good data governance ensures that downstream negative effects of poor data are avoided and that subsequent reports, analyses, and conclusions are based on reliable, trusted data.

■ Manage the change. Educate, educate, educate. People must be trained to under- stand why the data governance program is being implemented and how it will benefi t the business. The new policies represent a cultural change, and people need supportive program messages and training in order to make the shift. 3

IT Governance

IT governance is the primary way that stakeholders can ensure that investments in IT create business value and contribute toward meeting business objectives.4 This strategic align- ment of IT with the business is challenging yet essential. IT governance programs go further and aim to “improve IT performance, deliver optimum business value and ensure regulatory compliance.” 5

Although the CIO typically has line responsibility for implementing IT gover- nance, the CEO and board of directors must receive reports and updates to discharge their responsibilities for IT governance and to see that the program is functioning well and providing business benefi ts.

Typically, in past decades, board members did not get involved in overseeing IT governance. But today it is a critical and unavoidable responsibility. According to the IT Governance Institute’s Board Briefi ng on IT Governance , “IT governance is the re- sponsibility of the board of directors and executive management. It is an integral part of enterprise governance and consists of the leadership and organizational structures and processes that ensure that the organization’s IT sustains and extends the organiza- tion’s strategies and objectives.” 6

The focus is on the actual software development and maintenance activities of the IT department or function, and IT governance efforts focus on making IT effi cient and effective. That means minimizing costs by following proven software develop- ment methodologies and best practices, principles of data governance and information quality, and project management best practices while aligning IT efforts with the busi- ness objectives of the organization.

IT Governance Frameworks

Several IT governance frameworks can be used as a guide to implementing an IT governance program. (They are introduced in this chapter in a cursory way; detailed discussions of them are best suited to books focused solely on IT governance.)

IT governance seeks to align business objectives with IT strategy to deliver business value.


Although frameworks and guidance like CobiT® and ITIL have been widely adopted, there is no absolute standard IT governance framework; the combination that works best for an organization depends on business factors, corporate culture, IT maturity, and staffi ng capability. The level of implementation of these frameworks will also vary by organization.

CobiT® CobiT (Control Objectives for Information and related Technology) is a process-T based IT governance framework that represents a consensus of experts worldwide. Codeveloped by the IT Governance Institute and ISACA (previously known as the Information Systems Audit and Control Association), CobiT addresses business risks, control requirements, compliance, and technical issues. 7

CobiT offers IT controls that:

■ Cut IT risks while gaining business value from IT under an umbrella of a glob- ally accepted framework.

■ Assist in meeting regulatory compliance requirements. ■ Utilize a structured approach for improved reporting and management deci-

sion making. ■ Provide solutions to control assessments and project implementations to im-

prove IT and information asset control. 8

CobiT consists of detailed descriptions of processes required in IT and also tools to measure progress toward maturity of the IT governance program. It is industry agnostic and can be applied across all vertical industry sectors, and it continues to be revised and refi ned. 9

CobiT is broken out into three basic organizational levels and their responsibili- ties: (1) board of directors and executive management; (2) IT and business manage- ment; and (3) line-level governance, and security and control knowledge workers. 10

The CobiT model draws on the traditional “plan, build, run, monitor” paradigm of traditional IT management, only with variations in semantics. The CobiT framework is divided into four IT domains—(1) plan and organize, (2) acquire and implement, (3) deliver and support, and (4) monitor and evaluate—which contain 34 IT processes and 210 control objectives. Specifi c goals and metrics are assigned, and responsibilities and accountabilities are delineated.

The CobiT framework maps to the international information security standard, ISO 17799, and is also compatible with IT Infrastructure Library (ITIL) and other y “accepted practices” in IT development and operations.11

ValIT® ValIT is a newer value-oriented framework that is compatible with and complemen- tary to CobiT. Its principles and best practices focus is on leveraging IT investments to gain maximum value. Forty key ValIT essential management practices (analogous to CobiT’s control objectives) support three main processes: value governance, portfolio management, and investment management. ValIT and CobiT “provide a full frame- work and supporting tool set” to help managers develop policies to manage business risks and deliver business value while addressing technical issues and meeting control objectives in a structured, methodic way. 12


ITIL ITIL (Information Technology Infrastructure Library) is a set of process-oriented best practices and guidance originally developed in the United Kingdom to standard- ize delivery of IT service management. ITIL is applicable to both the private and public sectors and is the “most widely accepted approach to IT service management in the world.”13 As with other IT governance frameworks, ITIL provides essential guidance for delivering business value through IT, and it “provides guidance to or- ganizations on how to use IT as a tool to facilitate business change, transformation and growth.”14

ITIL best practices form the foundation for ISO/IEC 20000 (previously BS15000), the International Service Management Standard for organizational certifi cation and compliance. 15 ITIL 2011 is the latest revision (as of this printing), and it consists of fi ve core published volumes that map the IT service cycle in a systematic way:

1. ITIL Service Strategy 2. ITIL Service Design 3. ITIL Service Transition 4. ITIL Service Operation 5. ITIL Continual Service Improvement 16

ISO 38500 ISO/IEC 38500:2008 is an international standard that provides high-level principles and guidance for senior executives and directors, and those advising them, for the effective and effi cient use of IT. 17 Based primarily on AS 8015, the Australian IT gov- ernance standard, it “applies to the governance of management processes” that are performed at the IT service level, but the guidance assists executives in monitoring IT and ethically discharging their duties with respect to legal and regulatory compliance of IT activities.

The ISO 38500 standard comprises three main sections:

1. Scope, Application and Objectives 2. Framework for Good Corporate Governance of IT 3. Guidance for Corporate Governance of IT

CobiT is process-oriented and has been widely adopted as an IT governance framework. ValIT is value-oriented and compatible and complementary with CobiT, yet focuses on value delivery.

ITIL is the “most widely accepted approach to IT service management in the world.”


It is largely derived from AS 8015, the guiding principles of which were:

■ Establish responsibilities ■ Plan to best support the organization ■ Acquire validly ■ Ensure performance when required ■ Ensure conformance with rules ■ Ensure respect for human factors

The standard also has relationships with other major ISO standards, and embraces the same methods and approaches. 18

Information Governance

Corporate governance is the highest level of governance in an organization, and a key aspect of it is IG. IG processes are higher level than the details of IT governance and much higher than data governance, but both data and IT governance can be (and should be) a part of an overall IG program. The IG approach to governance focuses not on detailed IT or data capture and quality processes but rather on controlling the information that is generated by IT and offi ce systems. d

IG efforts seek to manage and control information assets to lower risk, ensure com- pliance with regulations, and improve information quality and accessibility while imple- menting information security measures to protect and preserve information that has busi- ness value.19 (See Chapter 1 for more detailed defi nitions.)

Impact of a Successful IG Program

When making the business case for IG and articulating its benefi ts, it is useful to focus on its central impact. Putting cost-benefi t numbers to this may be diffi cult, unless you

ISO 38500 is an international standard that provides high-level principles and guidance for senior executives and directors responsible for IT governance.

IG is how an organization maintains security, complies with regulations and laws, and meets ethical standards when managing information.


also consider the worst-case scenario of loss or misuse of corporate or agency records. What is losing the next big lawsuit worth? How much are confi dential merger and acquisition documents worth? How much are customer records worth? Frequently, executives and managers do not understand the value of IG until it is a crisis, an ex- pensive legal battle is lost, heavy fi nes are imposed for noncompliance, or executives go to jail.

There are some key outputs from implementing an IG program. A successful IG program should enable organizations to:

■ Use common terms across the enterprise. This means that departments must agree on how they are going to classify document types, which requires a cross- functional effort. With common enterprise terms, searches for information are more productive and complete. This normalization process begins with developing a standardized corporate taxonomy, which defi nes the terms (and substitute terms in a custom corporate thesaurus), document types, and their relationships in a hierarchy.

■ Map information creation and usage. This effort can be buttressed with the use of technology tools such as data loss prevention , which can be used to discover the fl ow of information within and outside of the enterprise. You must fi rst determine who is accessing which information when and where it is going. Then you can monitor and analyze these information fl ows. The goal is to stop the erosion or misuse of information assets and to stem data breaches with moni- toring and security technology.

■ Obtain “information confi dence” —that is, the assurance that information has ” integrity, validity, accuracy, and quality; this means being able to prove that the information is reliable and that its access, use, and storage meet compliance and legal demands.

■ Harvest and leverage information. Using techniques and tools like data min- ing and business intelligence, new insights may be gained that provide an enterprise with a sustainable competitive advantage over the long term, since managers will have more and better information as a basis for busi- ness decisions.21

Summing Up the Differences

IG consists of the overarching polices and processes to optimize and leverage informa- tion while keeping it secure and meeting legal and privacy obligations in alignment with stated organizational business objectives.

IT governance consists of following established frameworks and best practices to gain the most leverage and benefi t out of IT investments and support accomplishment of business objectives.

Data governance consists of the processes, methods, and techniques to ensure that data is of high quality, reliable, and unique (not duplicated), so that downstream uses in reports and databases are more trusted and accurate.



1. “New Trends and Best Practices for Data Governance Success,” eBook, ook_1104.pdf, accessed March 11, 2013.

2. Ibid. 3. Ibid. 4. M.N. Kooper, R. Maes, and E.E.O. RoosLindgreen, “On the Governance of Information: Introducing

a New Concept of Governance to Support the Management of Information,” International Journal of Information Management 31 (2011): 195–120, . (accessed t November 14, 2013).

5. Nick Robinson, “The Many Faces of IT Governance: Crafting an IT Governance Architecture,” ISACA Journal 1 (2007), of-IT-Governance-Crafting-an-IT-Governance-Architecture.aspx

6. Bryn Phillips, “IT Governance for CEOs and Members of the Board,” 2012, p.18. 7. Ibid., p.26. 8. IBM Global Business Services/Public Sector, “Control Objectives for Information and related Tech-

nology (CobiT®) Internationally Accepted Gold Standard for IT Controls & Governance,” http:// leserve?contentid=187551(accessed March 11, 2013).


■ Data governance uses techniques like data cleansing and de-duplication to improve data quality and reduce redundancies.

■ Good data governance ensures that downstream negative effects of poor data are avoided and that subsequent reports, analyses, and conclusions are based on reliable, trusted data.

■ IT governance seeks to align business objectives with IT strategy to deliver business value.

■ CobiT is processoriented and has been widely adopted as an IT governance framework. ValIT is valueoriented and compatible and complementary with CobiT yet focuses on value delivery.

■ The CobiT framework maps to the international information security stan- dard ISO 17799 and is also compatible with ITIL (IT Infrastructure Library).

■ ITIL is the “most widely accepted approach to IT service management in the world.”

■ ISO 38500 is an international standard that provides high-level principles and guidance for senior executives and directors responsible for IT governance.

■ Information governance is how an organization maintains security, complies with regulations and laws, and meets ethical standards when managing information.


9. Phillips, “IT Governance for CEOs and Members of the Board.” 10. IBM Global Business Services/Public Sector, “Control Objectives for Information and related Tech-

nology (CobiT®) Internationally Accepted Gold Standard for IT Controls & Governance.” 11. Ibid. 12. Ibid. 13. www.itil-offi (accessed March 12, 2013). 14. ITIL, “What Is ITIL?” www.itil-offi March 12, 2013). 15. Ibid. 16. Ibid. 17. “ISO/IEC 38500:2008 “Corporate Governance of Information Technology”

catalogue_detail?csnumber=51639(accessed November 14, 2013). 18. ISO 38500 (accessed March 12, 2013). 19. (accessed November 14,

2013). 20. ARMA International, Glossary of Records and Information Management Terms , 4th ed. TR 22–2012 (from s 21. Arvind Krishna, “Three Steps to Trusting Your Data in 2011,” CTO Edge , March 9, 2011, www.ctoedge



Information Governance Principles *

C H A P T E R 3

Principles of information governance (IG) are evolving and expanding. SuccessfulIG programs are characterized by ten key principles, which are the basis for best practices and should be designed into the IG approach. They include: 1. Executive sponsorship. No IG effort will survive and be successful if it does not

have an accountable, responsible executive sponsor. The sponsor must drive the effort, clear obstacles for the IG team or committee, communicate the goals and business objectives that the IG program addresses, and keep upper management informed on progress.

2. Information policy development and communication. Clear policies must be es- tablished for the access and use of information, and those policies must be communicated regularly and crisply to employees. Policies for the use of e- mail, instant messaging, social media, cloud computing, mobile computing, and posting to blogs and internal sites must be developed in consultation with stakeholders and communicated clearly. This includes letting employees know what the consequences of violating IG policies are, as well as its value.

3. Information integrity. This area considers the consistency of methods used to create, retain, preserve, distribute, and track information. Adhering to good IG practices include data governance techniques and technologies to ensure quality data. Information integrity means there is the assurance that informa- tion is accurate, correct, and authentic. IG efforts to improve data quality and information integrity include de-duplicating (removing redundant data) and maintaining only unique data to reduce risk, storage costs, and informa- tion technology (IT) labor costs while providing accurate, trusted information for decision makers. Supporting technologies must enforce policies to meet legal standards of admissibility and preserve the integrity of information to guard against claims that it has been altered, tampered with, or deleted (called “ spoliation ”). Audit trails must be kept and monitored to ensure compliance with IG policies to assure information integrity. 1

4. Information organization and classifi cation. This means standardizing formats, categorizing all information, and semantically linking it to related information. It also means creating a retention and disposition schedule that spells out how

* Portions of this chapter are adapted from Chapter 3 of Robert F. Smallwood, Managing Electronic Records: Methods, Best Practices, and Technologies , © John Wiley & Sons, Inc., 2013. Reproduced with permission of John Wiley & Sons, Inc. s


long the information (e.g. e-mail, e-documents, spreadsheets, reports) and records should be retained and how they are to be disposed of or archived. Information, and particularly documents, should be classifi ed according to a global or corporate taxonomy that considers the business function and owner of the information, and semantically links related information. Information must be standardized in form and format. Tools such as document labeling can assist in identifying and classifying documents. Metadata associated with documents and records must be standardized and kept up-to-date. Good IG means good metadata management and utilizing metadata standards that are appropriate to the organization.

5. Information security. This means securing information in its three states: at rest, in motion, and in use. It means implementing measures to protect information from damage, theft, or alteration by malicious outsiders and insiders as well as nonmalicious (accidental) actions that may compromise information. For instance, an employee may lose a laptop with confi dential information, but if proper IG policies are enforced using security-related information tech- nologies, the information can be secured. This can be done by access control methods, data or document encryption, deploying information rights manage- ment software, using remote digital shredding capabilities, and implement- ing enhanced auditing procedures. Information privacy is closely related to information security and is critical when dealing with personally identifi able information (PII).n

6. Information accessibility. Accessibility is vital not only in the short term but also over time using long-term digital preservation (LTDP) techniques when appropriate (generally if information is needed for over fi ve years). Accessibil- ity must be balanced with information security concerns. Information acces- sibility includes making the information as simple as possible to locate and access, which involves not only the user interface but also enterprise search principles, technologies, and tools. It also includes basic access controls, such as password management, identity and access management , and delivering t information to a variety of hardware devices.

7. Information control. Document management and report management software must be deployed to control the access to, creation, updating, and printing of documents and reports. When documents or reports are declared records, they must be assigned to the proper retention and disposition schedule to be retained for as long as the records are needed to comply with legal retention periods and regulatory requirements. Also, information that may be needed or requested in legal proceedings is safeguarded through a legal hold process.

8. Information governance monitoring and auditing. To ensure that guidelines and policies are being followed and to measure employee compliance levels, in- formation access and use must be monitored. To guard against claims of spo- liation, use of e-mail, social media, cloud computing, and report generation should be logged in real time and maintained as an audit record. Technology tools such as document analytics can track how many documents or reports users access and print and how long they spend doing so.

9. Stakeholder consultation. Those who work most closely to information are the ones who best know why it is needed and how to manage it, so business units must be consulted in IG policy development. The IT department understands


its capabilities and technology plans and can best speak to those points. Le- gal issues must always be deferred to the in-house council or legal team. A cross-functional collaboration is needed for IG policies to hit the mark and be effective. The result is not only more secure information but also better information to base decisions on and closer adherence to regulatory and legal demands. 2

10. Continuous improvement. IG programs are not one-time projects but rather ongoing programs that must be reviewed periodically and adjusted to account for gaps or shortcomings as well as changes in the business environment, tech- nology usage, or business strategy.

Accountability Is Key

According to Debra Logan at Gartner Group, none of the proffered defi nitions of IG in- cludes “any notion of coercion, but rather ties governance to accountability [emphasis added] that is designed to encourage the right behavior. . . . The word that matters most is accountability .” The root of many problems with managing information is the “fact that there is no accountability for information as such.” 3

Establishing policies, procedures, processes, and controls to ensure the quality, in- tegrity, accuracy, and security of business records are the fundamental steps needed to reduce the organization’s risk and cost structure for managing these records. Then it is essential that IG efforts are supported by IT. The auditing, testing, maintenance, and im- provement of IG is enhanced by using electronic records management (ERM) software along with other complementary technology sets, such as workfl ow and business process management suite (BPMS) software and digital signatures.

Generally Accepted Recordkeeping Principles ®

Contributed by Charmaine Brooks, CRM A major part of an IG program is managing formal business records. Although they account for only about 7 to 9 percent of the total information that an organization holds, they are the most critically important subset to manage, as there are serious compliance and legal ramifi cations to not doing so.

Principles of successful IG programs are emerging. They include executive sponsorship, information classifi cation, integrity, security, accessibility, control, monitoring, auditing, policy development, and continuous improvement.

Accountability is a key aspect of IG.


Records and recordkeeping are inextricably linked with any organized business activity. Through the information that an organization uses and records, creates, or receives in the normal course of business, it knows what has been done and by whom. This allows the organization to effectively demonstrate compliance with applicable standards, laws, and regulations as well as plan what it will do in the future to meet its mission and strategic objectives.

Standards and principles of recordkeeping have been developed by records and information management (RIM) practitioners to establish benchmarks for how or-t ganizations of all types and sizes can build and sustain compliant, defensible records management (RM) programs. t

The Principles

In 2009 ARMA International published a set of eight Generally Accepted Recordkeep- ing Principles,® known as The Principles 4 (or sometimes GAR Principles), to foster awareness of good recordkeeping practices. These principles and associated metrics provide an IG framework that can support continuous improvement.

The eight Generally Accepted Recordkeeping Principles are:

1. Accountability. A senior executive (or person of comparable authority) oversees the recordkeeping program and delegates program responsibility to appro- priate individuals. The organization adopts policies and procedures to guide personnel, and ensure the program can be audited.

2. Transparency. The processes and activities of an organization’s recordkeeping program are documented in a manner that is open and verifi able and is avail- able to all personnel and appropriate interested parties.

3. Integrity. A recordkeeping program shall be constructed so the records and information generated or managed by or for the organization have a reason- able and suitable guarantee of authenticity and reliability.

4. Protection. A recordkeeping program shall be constructed to ensure a reason- able level of protection to records and information that are private, confi den- tial, privileged, secret, or essential to business continuity.

5. Compliance. The recordkeeping program shall be constructed to comply with ap- plicable laws and other binding authorities, as well as the organization’s policies.

6. Availability. An organization shall maintain records in a manner that ensures timely, effi cient, and accurate retrieval of needed information.

7. Retention. An organization shall maintain its records and information for an appropriate time, taking into account legal, regulatory, fi scal, operational, and historical requirements.

8. Disposition. An organization shall provide secure and appropriate disposition for records that are no longer required to be maintained by applicable laws and the organization’s policies. 5

The Generally Accepted Recordkeeping Principles consist of eight principles that provide an IG framework that can support continuous improvement.


The Principles apply to all sizes of organizations, in all types of industries, in both the private and public sectors, and can be used to establish consistent practices across business units. The Principles are an IG maturity model, and it is used as a preliminary evaluation of recordkeeping programs and practices.

Interest in and the application of The Principles for assessing an organization’s recordkeeping practices have steadily increased since their establishment in 2009. The Principles form an accountability framework that includes the processes, roles, stan- dards, and metrics that ensure the effective and effi cient use of records and informa- tion in support of an organization’s goals and business objectives.

As shown in Table 3.1 , the Generally Accepted Recordkeeping Principles matu- rity model associates characteristics that are typical in fi ve levels of recordkeeping capabilities ranging from 1 (substandard) to 5 (transformational). The levels are both descriptive and color coded for ease of understanding. The eight principles and levels (metrics) are applied to the current state of an organization’s recordkeeping capabili- ties and can be cross-referenced to the policies and procedures. While it is not unusual for an organization to be at different levels of maturity in the eight principles, the question “How good is good enough?” must be raised and answered ; a rating of less than “transforma-d tional” may be acceptable, depending on the organization’s tolerance for risk and an analysis of the costs and benefi ts of moving up each level.

The maturity levels defi ne the characteristics of evolving and maturing RM programs. The assessment should refl ect the current RM environment and practices. The principles and maturity level defi nitions, along with improvement recommendations (roadmap), outline the tasks required to proactively approach addressing systematic RM practices and reach the next level of maturity for each principle. While the Generally Accepted

Table 3.1 Generally Accepted Recordkeeping Principles Levels

Level 1


Characterized by an environment where recordkeeping concerns are either not addressed at all or are addressed in an ad hoc manner.

Level 2

In Development

Characterized by an environment where there is a developing recognition that recordkeeping has an impact on the organization, and the organization may benefi t from a more defi ned information governance program.

Level 3


Characterized by an environment where defi ned policies and procedures exist that address the minimum or essential legal and regulatory requirements, but more specifi c actions need to be taken to improve recordkeeping.

Level 4


Characterized by an environment where information governance issues and considerations are integrated into business decisions on a routine basis, and the organization consistently meets its legal and regulatory obligations.

Level 5


Characterized by an environment that has integrated information governance into its corporate infrastructure and business processes to such an extent that compliance with program requirements is routine.

Source: Used with permission from ARMA.

The Generally Accepted Recordkeeping Principles maturity model measures recordkeeping maturity in fi ve levels.


Recordkeeping Principles are broad in focus, they illustrate the requirements of good RM practices. The Principles Assessment can also be a powerful communication tool to promote cross-functional dialogue and collaboration among business units and staff.

Accountability The principle of accountability covers the assigned responsibility for RM at a seniory level to ensure effective governance with the appropriate level of authority. A senior- level executive must be high enough in the organizational structure to have suffi cient authority to operate the RM program effectively. The primary role of the senior ex- ecutive is to develop and implement RM policies, procedures, and guidance and to provide advice on all recordkeeping issues. The direct responsibility for managing or operating facilities or services may be delegated.

The senior executive must possess an understanding of the business and legislative environment within which the organization operates, business functions and activities, and the required relationships with key external stakeholders to understand how RM contributes to achieving the corporate mission, aims, and objectives.

It is important for top-level executives to take ownership of the RM issues of the organization and to identify corrective actions required for mitigation or ensure resolution of problems and recordkeeping challenges. An executive sponsor should identify opportunities to raise awareness of the relevance and importance of RM and effectively communicate the benefi ts of good RM to staff and management.

The regulatory and legal framework for RM must be clearly identifi ed and understood. The senior executive must have a sound knowledge of the organization’s information and technological architecture and actively participate in strategic deci- sions for IT systems acquisition and implementation.

The senior executive is responsible for ensuring that the processes, procedures, governance structures, and related documentation are developed. The policies should identify the roles and responsibilities at all levels of the organization.

An audit process must be developed to cover all aspects of RM within the organization, including substantiating that suffi cient levels of accountability have been assigned and accountability defi ciencies are identifi ed and remedied. Audit processes should include compliance with the organization policies and procedures for all records, regardless of format or media. Accountability audit requirements for electronic records include employing appropriate technology to audit the information architecture and systems. Accountability structures must be updated and maintained as changes occur in the technology infrastructure.

The audit process must reinforce compliance and hold individuals accountable. The results should be constructive, encourage continuous improvement, but not be used as a means of punishment. The audit should contribute to records program improve- ments in risk mitigation, control, and governance issues and have the capacity to support sustainability.

An audit process must be developed to cover all aspects of RM in the organization.


Transparency Policies are broad guidelines for the operation of the organization and provide a basic guide to action that prescribes the boundaries within which business activities are to take place. They state the course of action to be followed by the organization, business unit, department, and employees.

Transparency of recordkeeping practices includes documenting processes and y promoting an understanding of the roles and responsibilities of all stakeholders. To be effective, policies must be formalized and integrated into business processes. Business rules and recordkeeping requirements need to be communicated and installed at all levels of the organization.

Senior management must recognize that transparency is fundamental to IG and compliance. Documentation must be consistent, current, and complete. A review and approval process must be established to ensure that the introduction of new programs or changes can be implemented and integrated into business processes.

Employees must have ready access to RM policies and procedures. They must re- ceive guidance and training to ensure they understand their roles and requirements for RM. Recordkeeping systems and business processes must be designed and developed to clearly defi ne the records lifecycle.

In addition to policies and procedures, guidelines and operational instructions, diagrams and fl owcharts, system documentation, and user manuals must include clear guidance on how records are to be created, retained, stored, and dispositioned. The documentation must be readily available and incorporated in communications and training provided to staff.

Integrity Record generating systems and repositories must be assessed to determine record- keeping capabilities. A formalized process must be in place for acquiring or developing new systems, including requirements for capturing the metadata required for lifecycle management of records in the systems. In addition, the record must contain all the necessary elements of an offi cial record, including structure, content, and context. Records integrity, y reliability, and trustworthiness are confi rmed by ensuring that a record was created by a competent authority according to established processes.

Maintaining the integrity of records means that they are complete and protected from being altered. The authenticity of a record is ascertained from internal and exter- nal evidence, including the characteristics, structure, content, and context of the records, to verify they are genuine and not corrupted or altered. In order to trust that a record is authentic, organizations must ensure that recordkeeping systems that create, capture , and manage electronic records are capable of protecting re- cords from accidental or unauthorized alteration or deletion while the record has value.

To be effective, policies must be formalized and integrated into business processes.


Protection Organizations must ensure the protection of records and ensure they are unaltered through loss, tampering, or corruption. This includes technological change or the failure of digital storage media and protecting records against damage or deterioration.

This principle applies equally to physical and electronic records, each of which has unique requirements and challenges.

Access and security controls need to be established, implemented, monitored, and reviewed to ensure business continuity and minimize business risk. Restrictions on access and disclosure include the methods for protecting personal privacy and propri- etary information. Access and security requirements must be integrated into the busi- ness systems and processes for the creation, use, and storage of records.

LTDP is a series of managed activities required to ensure continued access to digi- tal materials for as long as necessary. Electronic records requiring long-term retention may require conversion to a medium and format suitable to ensure long-term access and readability.

Compliance RM programs include the development and training of the fundamental components, including compliance monitoring to ensure sustainability of the program.g

Monitoring for compliance involves reviewing and inspecting the various facets of records management, including ensuring records are being properly created and captured, im- plementation of user permissions and security procedures, workfl ow processes through sampling to ensure adherence to policies and procedures, ensuring records are being retained following disposal authorization, and documentation of records destroyed or transferred to determine whether destruction/transfer was authorized in accordance with disposal instructions.

Compliance monitoring can be carried out by an internal audit, external organiza- tion, or RM and must be done on a regular basis.

Availability Organizations should evaluate how effectively and effi ciently records and information are stored and retrieved using present equipment, networks, and software . The evaluation should identify current and future requirements and recommend new systems as appropriate. Certain factors should be considered before upgrading or imple- menting new systems. These factors are practicality, cost, and effectiveness of new confi gurations.

A major challenge for organizations is ensuring timely and reliable access to and use of information and that records are accessible and usable for the entire length of the retention period. Rapid changes and enhancements to both hardware and software compound this challenge.

Retention Retention is the function of preserving and maintaining records for continuing use. The reten- tion schedule identifi es the actions needed to fulfi ll the requirements for the retention and disposal of records and provides the authority for employees and systems to retain, destroy, or transfer records. The records retention schedule documents the record- keeping requirements and procedures, identifying how records are to be organized


and maintained, what needs to happen to records and when, who is responsible for doing what, and whom to contact with questions or guidance.

Organizations must identify the scope of their recordkeeping requirements for documenting business activities based on regulated activities and jurisdictions that im- pose control over records. This includes business activities regulated by the govern- ment for every location or jurisdiction in which the company does business. Other considerations for determining retention requirements include operational, legal, fi s- cal, and historical ones.

Records appraisal is the process of assessing the value and risk of records to determine their retention and disposition requirements. Legal research is outlined in appraisal reports. This appraisal process may be accomplished as a part of the process of developing the records retention schedules as well as conducting a regular review to ensure that citations and requirements are current.

The records retention period is the length of time that records should be retained and d the actions taken for them to be destroyed or preserved. The retention periods for different records should be based on legislative or regulatory requirements as well as on admin- istrative and operational requirements.

It is important to document the legal research conducted and used to determine whether the law or regulation has been reasonably applied to the recordkeeping prac- tices and provide evidence to regulatory offi cials or courts that due diligence has been conducted in good faith to comply with all applicable requirements.

Disposition Disposition is the last stage in the life cycle of records. When the retention requirements have been met and the records no longer serve a useful business purpose, records may be destroyed. Records requiring long-term or permanent retention should be trans- ferred to an archive for preservation. The timing of the transfer of physical or elec- tronic records should be determined through the records retention schedule process. Additional methods, including migration or conversion, are often required to preserve electronic records.

Records must be destroyed in a controlled and secure manner and in accordance with authorized disposal instructions. The destruction of records must be clearly doc- umented to provide evidence of destruction according to an agreed-on program.

Destruction of records must be undertaken by methods appropriate to the con- fi dentiality of the records and in accordance with disposal instructions in the records retention schedule. An audit trail documenting the destruction of records should be maintained, and certifi cates of destruction should be obtained for destruction under- taken by third parties. In the event disposal schedules are not in place, written autho- rization should be obtained prior to destruction. Procedures should specify who must supervise the destruction of records. Approved methods of destruction must be speci- fi ed for each media type to ensure that information cannot be reconstructed.

Disposition is the last stage in the life cycle of records. Disposition is not syn- onymous with destruction, although destruction may be one disposal option.


Disposition is not synonymous with destruction, although destruction may be one disposal option. Destruction of records must be carried out under controlled, confi dential conditions by shredding or permanent disposition. This includes the destruction of confi dential microfi lm, microfi che, computer cassettes, and computer tapes as well as paper.

Methods of Disposition

■ Discard. The standard destruction method for nonconfi dential records. If pos- sible, all records should be shredded prior to recycling. Note that transitory records can also be shredded.

■ Shred. Confi dential and sensitive records should be processed under strict security. This may be accomplished internally or by secure on-site shredding by a third party vendor who provides certifi cates of secure destruction. The shredded material is then recycled.

■ Archive. This designation is for records requiring long-term or permanent preservation. Records of enduring legal, fi scal, administrative, or historical value are retained.

■ Imaging. Physical records converted to digital images, after which the original paper documents are destroyed.

■ Purge. This special designation is for data, documents, or records sets that need to be purged by removing material based on specifi ed criteria. This often ap- plies to structure records in databases and applications.

Assessment and Improvement Roadmap

The Generally Accepted Recordkeeping Principles® maturity model can be lever- aged to develop a current state assessment of an organization’s recordkeeping prac- tices and resources, identify gaps and assess risks, and develop priorities for desired improvements.

The Principles were developed by ARMA International to identify characteristics of an effective recordkeeping program. Each of the eight principles identifi es issues and practices that, when evaluated against the unique needs and circumstances of an organization, can be applied to improvements for a recordkeeping program that meets recordkeeping requirements. The Principles identify requirements and can be used to guide incremental improvement in creation, organization, security, maintenance, and other activities over a period of one to fi ve years. Fundamentally, RM and information governance are business disciplines that must be tightly integrated with operational policies, procedures, and infrastructure.

The Principles can be mapped to the four improvement areas in Table 3.2 . As an accepted industry guidance maturity model, the Principles provide a con-

venient and complete framework for assessing the current state of an organization’s recordkeeping and developing a roadmap to identify improvements that will bring the organization into compliance. An assessment/analysis of the current RM practices, procedures, and capabilities together with current and future state practices provides two ways of looking at the future requirements of a complete RM (see Table 3.3 ).


Table 3.2 Improvement Areas for Generally Accepted Recordkeeping Principles

Improvement Area A cc

o un

ta b

ili ty

Tr an

sp ar

en cy

In te

g ri


Pr o

te ct

io n

C o

m p

lia n


A va

ila b

ili ty

R et

en ti

o n

D is

p o

si ti

o n

Roles and responsibilities ◊ ◊ ◊

Policies and procedures ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊

Communication and training ◊ ◊ ◊ ◊ ◊

Systems and automation ◊ ◊ ◊ ◊ ◊ ◊

Who Should Determine IG Policies?



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