Recently, Doculabs completed a consulting engagement with a client in the financial services industry that was focused on the retention and disposition of “social” content in light of the FINRA and SEC regulations (see my previous blog posts for a discussion of the guidelines). Social content refers to all the posts, blogs, discussions, etc., that are contributed by a firm’s licensed representatives. Once you understand the regulatory guidelines, the question of how to ensure compliance becomes critical.
Essentially, organizations today are using three different approaches to the retention and disposition of the content that’s being generated by social applications (and which then becomes electronically stored information, or ESI). Each approach has advantages and disadvantages, and it’s important to understand the risk management implications of each.
The following table highlights the differences across these approaches to retention and disposition, as well as the pros and cons.
While the table depicts the three approaches independently, recognize that a firm can employ a combination of these approaches to achieve the desired results. For example, a firm might create static copies (Approach #1) on a periodic basis to capture the general context of a site, but also archive e-communications as discrete objects (Approach #2). It might also archive documents posted on a social site to a traditional ECM system (Approach #3).
Of course, cost is always a big factor. Our direction to clients just beginning to enable social content archiving capabilities is to keep it simple. Costs can escalate quickly, so try to define a minimal set of requirements to start with. Once implemented, the capabilities can then be expanded.
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