This post explains how to break the tape habit.
We’re surprised at how many organizations use backup tapes as archives, to ensure that they are living up to their regulatory compliance and legal “duty to preserve” obligations. Your organization may be one of them. But this is a really bad idea. It causes substantial operational inefficiencies, requires significant efforts to remedy, and exposes these organizations to increased compliance and litigation risk. Usually the IT and Legal folks in such organizations agree with us, but then don’t know how to go about breaking the tape habit and doing archiving more effectively without making things worse.
This post provides a quick outline describing how to do so. Even if you believe you’re doing backup, archiving, and RM/Legal retention effectively, it might be worth reading, for some of the recommendations for organizations regarding legacy ESI, tape backup, and archiving.
In a Nutshell: How to Stop Using Tape for Archiving
Immediately stop using tapes for archive, retention, holds, releases, and disposition purposes.Tapes should only be used for backup storage for business continuity.
Begin an evaluation process to categorize existing tapes into three categories: (1) those with content subject to hold(s), (2) those with content subject to retention, (3) those with content subject neither to hold(s) nor retention. Dispose of tapes in the third category immediately.
For tapes with content in the first and second categories, Adopt a strategic approach to retaining/disposing of them that balances cost and risk and allows for cost-effective, scalable discovery and RM.
The next three sections describe some of the best and standard practices we have found with respect to legacy ESI, tape backup, and archiving.
1. Archive vs. Backup
A best (and actually standard) practice is to distinguish between backup storage for business continuity, and archiving for efficient, effective, long term storage of ESI for business and legal reasons.
Backup rotation schemes determine when ESI is backed up on a piece of removable storage media, and how long it should be retained. The appropriate rotation scheme for recovering a company’s ESI is determined by calculating the best balance of recovery point objective (RPO) and recovery time objective (RTO). Typical rotation schemes include a mix of short cycle (e.g. daily or weekly) incremental backups with longer cycle (e.g. monthly or quarterly) full backups. Mirroring of servers and offsite storage can reduce the requirements for a complex tape backup scheme.
A typical archive-to-tape organization might do a network backup regimen coupled with its tape backup rotation (a full backup every quarter, with no disposition), and this program is most likely sufficient for recovery. Often they’ve implemented this full backup with no disposition to address the urgent need to ensure retention and legal holds. But it is highly inadequate as an archival approach to meet the company’s litigation needs, which extend beyond simply ensuring retention, for four reasons:
Tape makes differential retention, holds, releases, and disposition of documents—as opposed to entire tapes—very difficult and expensive.
The full quarterly retention to tape, with no disposition, increases ESI copies and associated risks with each backup.
The unmanageability and volume of the data on the tapes will make future discovery and production unpredictable and costly, particularly since it is highly likely that future discoveries will require production of increasingly varied ESI (as opposed to e.g. just email or “official business records”).
The availability of tape backup as an archive option often results in some business units relying on tape backup for records retention. This approach is then typically inconsistently practiced for different documents and between different business units.
2. Archiving Properly for Retention and Discovery
Day forward and for new ESI, we recommend that you use an approach such as content addressable storage (CAS) archiving for ESI for long term archiving of likely discoverable ESI. With such an approach, all such content will have ensured retention, with greater ability to differentially ensure holds, releases, and disposition—and it will facilitate any future implementation of ECM, RM, and discovery tools. Note that this approach allows you to continue to perform your current tape backup scheme, but it will be irrelevant for day-forward requirements for retention, holds, release, and disposition. As a result, you will be free to adopt a backup policy solely based on its RPO and RTO requirements—allowing the tapes to be taped over as soon as the rotation schedule dictates.
3. Legacy ESI on Backup Tapes
As an initial approach for legacy ESI currently residing on backup tapes, we recommend that you sort the tapes into three classes, according to whether your tapes have holds, other retention requirements, or neither:
Tapes with holds: keep in the near term
Tapes with no holds, but with retention requirements: keep in the near term
Tapes with no holds and no retention requirements: consider for immediate disposition
In this initial sort, you’ve already got a potential pile of tapes that are candidates for immediate disposition (group 2). Then as resources allow, assess group 2 (with retention but no hold requirements) to determine whether it contains tapes that are redundant (because a copy already exists on another system and already is or can be declared the copy of record). Those tapes in group 2 are then candidates for disposition. Finally, as resources and risk allow, assess group 3 (with hold requirements) to determine whether it can be safely deduped or culled.
It may turn out that the initial sort or later assessments will determine that ROI doesn’t justify the work necessary to safely destroy the tapes one or more groups. But even so, the sorting and assessment exercises will provide you with valuable insight into the state of your legacy data.#businesscontinuity #tape #disasterrecovery #BackUp #contentaddressablestorage #archiving #InformationGovernance