Policies First - Holism in Information Governance

By Chris Walker posted 02-20-2013 18:12



If it doesn’t work manually, automating won’t do diddly for you; policy comes before procedure.

Somebody asked if auto-classification and retention / disposition processing had been tested in court. I’ve not been directly involved with any cases, but yeah, these things have been tested. Sometimes they passed the test, other times not. So what? The issue was not with the technology.

The thing is, if the tools you’re using are automating or supporting policies and procedures that won’t stand up in court, the tools aren’t going to help you. The purpose of tools is to implement sound policies, not to define them. They’re tools, for pity’s sake; they’re dumb. If your policy’s flawed the only thing that automation will do is allow you to make more mistakes in less time.

Back in November of 2012 I attended a Contoural event in Chicago to take part on a technology panel. As I was listening to some of my fellow panellists, something struck me (no, not a projectile from the audience) …

Silo’s and point solutions (as concepts) were mentioned a few times. Now, the focus of the panel discussion was about how to get rid of evidence in case there was any inkling your organization would end up in court as defendant. Yes, we were advocating defensible disposition and not the Ollie North method of litigation preparation. We were five techno-numpties at the front of the room, talking about how to prepare for legal action. This, my friends, is a silo’d approach. Yes, I understand that you can’t go back and start from scratch, but you can set things up for the future so that you don’t need to scramble.

The key is to define holistic Information Governance (IG) policies. By holistic I mean policies that not only cover your keester in court, but also ensure that your information is useable on a day-to-day basis. Anyone who thinks that IG is only about risk is wrong. W-R-O-N-G, wrong.

Pop quiz: What’s more risky to your organization? Not disposing of content when you can, or not having the right information to make sound business decisions?

Governance done right not only keeps you out of jail, it also helps you run your business. An holistic Information Governance model has to cover what corporate users can do with corporate IT assets (acceptable use), who can access information, how information is organized, how and when information is disposed of, whether or not user provisioned devices are allowed, etc. IG does not only cover content that’s stored in ECM-type repositories; IG covers any and all content under an organization’s custodianship (including stuff you’ve sent off to 3rd party storage providers), regardless of location or format. Yes, IG covers your ERP, CRM, LOB, and other systems. If you’re responsible for it, your IG model better address it.

Don’t get all freaked out and start thinking that IG is there to control the business and run the entire show. It’s not. IG is there to make sure the business has the best information possible to conduct core business activities. That’s it. IG supports the business, IG doesn’t run the business. IG doesn’t even dictate what technologies to deploy. It does, however, define what many of the functional and non-functional requirements are for managing an organization’s information.

Because I know some of you are gonna harp on the legal aspect …

Done right, Information Governance will help you prepare for litigation. Being in a position to defensibly dispose of content is a benefit of IG. But, defensible disposition should not be achieved at the expense of being able to conduct business and making good decisions. IG helps by balancing the need for risk mitigation against the information requirements of the core business. E.g.: It may be completely (legally speaking) permissible to turf those invoices, but is there information contained in the invoices that ought to be extracted and stored in a data warehouse for future use? If you approach IG in a fragmented fashion you’ll never know. Or you’ll know and never sort it out because all your stakeholder groups will be arguing about it forever until legal finally wins but compromises your ability to successfully run your business.

True Enterprise Information Governance (EIG) takes an holistic approach to identifying what an organization’s information needs, risks, and responsibilities are. Risk mitigation is balanced against business need and the likelihood that a risk becomes an issue. Information is organized so that those who need it can get it when they need it, but the information is also secure. Information that is outdated and no longer relevant is disposed of, defensibly. Information is an asset; Information Governance ensures that the asset is managed appropriately.

And lest ye think that Information Governance applies only to large corporations and governments … you’ve got another thing coming. The only organizations that don’t need IG are those that don’t use or produce information.

For a little more about my thoughts on IG, read this post from Sept. 2012; it’ll give you a bit more insight into where my head’s at.

#ElectronicRecordsManagement #disposition #information governance #InformationGovernance #compliance #Risk