Showing posts with label proactive. Show all posts
Showing posts with label proactive. Show all posts

Tuesday, November 11, 2008

Use case: Records retention policy and management protocol

For many organizations, the perennial information management challenge they face is records retention. Some organizations my either have no cognizable records retention policy or a state-of-the-art records management protocol they can never seem to get effectively implemented. Regardless of what state its records policy or management protocols are in, and organization that seeks to implement one should have a sense of the following fundamental characteristics of their data and organization:
a. File create, modify and access times;
b. File “owner”;
c. file content;
d. The rules that define which group within the organization’s internal data taxonomy, the classified information belongs to, i.e. – HR, finance, taxes, customers, operations, marketing, etc.;
e. The applicable regulatory framework for the organization – this consists of nondiscretionary externally mandated records retention requirements; and
f. Pending (to the extent they exist) litigation hold requirements.
1. Defensible data remediation; getting rid of files with little business value and high exposure.
Organizations that have implemented records retention programs without classification are likely over-capturing information. This means that while they get what they should, they may also capture superfluous information that is of no business value that could well represent significant risk to the organization.
Records retention managers who leverage search and classification technology will be able to report on a host of information, including, but not limited to, the age of files it encounter during a network scan as well s file access and modify times. This allows records retention managers to being data remediation based on file age and utility. Arguably, old files that are never modified or accessed likely have little or no business value. In fact these files are the ones that constitute the greatest organizational threat in the form of dormant data liability. However, simply because they exist, they may be responsive to a litigation or regulatory request.
2. Data classification; defining that which is an organizational record.
The precursor step to defining what constitutes an organizational record is data classification. Prior to data classification, the data must be discovered and its contents accessed. In today’s world, file metadata and content become part of an enterprise index. Policies, driven by corporate stakeholder criteria, can then identify the items that qualify as “records” based on the organization’s rules and apply user-specific metadata to them.
In the records retention use case, records retention managers or policy makers can create and automate simple or complex classification rule sets that will classify and tag relevant documents with values such as “tax record,” “HR record,” “final contract,” etc. The resulting record can then be migrated to its archival resting point on secondary storage or read-only media. In short, powerful metadata tagging capabilities now allow records managers and policy makers to get their arms around vast amounts of data and apply flexible and elegant classification schemes that heretofore would have been inconceivable.
II. Use case: Information security
In a recent study conducted by TIP, and independent IT research group founded by Gartner, EMC, Giga, and Bell Labs alumni, upwards of 70% of information security (infosec) professionals interviewed have confirmed that there has been a shift in their focus from external threats to internal threats to their information security. Some hot points for information storage mangers include stemming intellectual property (IP) leakage, identifying network security gaps and managing information access. Helping infosec professional by giving them insight into the nature of data at rest is a core foundation for infosec solutions. Questions such as, “who in the enterprise has data related to project X and where is it?” can easily be answered by leveraging regular expression content filter engines that identify and alert infosec professional to the existence and network coordinates of certain types of information that meet the organization’s risk profiles. Infosec managers should be able to scan, locate and sequester information such as credit card data, social security information or any other pattern or keyword-based sensitive and proprietary material. Even more importantly, they should be able to conduct automated risk rankings that combine multiple metadata and content conditions. Information access technology delivers these types of solutions. Now infosec personnel can ascertain data ownership and access rights and be in a better position to help make policy decisions about avoiding future organizational exposure.

Information Management - The Big Picture

Given the explosive growth of electronic information in corporate America, managing electronic discovery is increasingly a challenge for corporate IT departments, in-house and outside counsel, each of whom are stakeholders. In December of 2006, the Judicial Conference of the US amended the Federal Rules of Civil Procedure (FRCP) to clarify the roles, responsibilities and discovery obligations of the various parties to litigation. The amendments, for the first time, made specific reference to electronically stored information, or ESI, as it is now commonly known. The changes in attitudes toward e-discovery are noticeable and the amendments have, without question, helped create an unprecedented level of dialog and collaboration to understand how electronic information is created, used, managed and disposed of in the corporate environment.

Why, then, have the amendments, intended to reduce confusion, also introduced a level of complexity to the e-discovery process that has left a lot of people scratching their heads?

For example, corporate counsel in a defense posture is keyed in on everything from creating corporate data maps to handling multiple and complex litigation holds, as well as establishing repeatable and defensible guidelines for discovery. What happens the following week when the storage administrator retires a key server and implements his data consolidation strategy? How good is the data map then?
Records retention managers have also been significantly affected. For years, they have been seen as silent corporate operatives who had murky roles and dealt with boxes of old documents. Today, nothing could be further from the truth. They are on the front lines of protecting an organization from a data management policy perspective.

Another role that has seen significant evolution is that of the “storage administrator.” Corporate data storage administrators are IT personnel whose roles are largely characterized by their knowledge of an organization’s data growth and proliferation patterns – key factors that allow them to make recommendations as to how, when and if an organization’s data management hardware and associated software platforms need modification or change.

Another driver is the evolution of technology for e-discovery to serve both proactive and reactive use cases. The vast majority of matters today are addressed in a reactive fashion with a mind to quickly address pressing, active concerns that demand rapid retrieval of responsive ESI for early case assessments, meet and confer and other matter-specific requirements. However, the future is clear in that there is a need for consistent, repeatable and targeted e-discovery processes that can also be deployed across a company, creating an “e-discovery ready,” proactive environment.

Therefore, the answer may lie in the fact that while the amendments impose obligations on the parties, they don’t specifically state how one should go about fulfilling them. When it comes to corporations today, the old silo-based information management paradigms will not work when it comes to information discovery of any kind, for any reason. The bottom line is: litigation, storage management/data consolidation, records retention, regulatory responses, internal investigations, information security initiatives, personnel policy management, business intelligence, data mining, compliance and monitoring are all effectively subsets of what we call “e-discovery.” This new paradigm of e-discovery subsumes many previously compartmentalized departmental initiatives that are under the auspices of legal, IT, records management, HR and finance. It is predicated on the degree to which an organization has information access and the ability to perform effective data classification. In short, companies should be able to leverage enterprise data for multiple business needs from a common underlying information access and classification platform.

Friday, October 31, 2008

Unstructured Information Management What You Don’t Know Can Hurt You

Companies large and small create an impressive amount of data, including email messages, documents and presentations. Most of that data is unstructured, existing primarily on corporate file servers, employee desktop and notebook computers. Industry analysts estimate that this unstructured data accounts for 80% of all corporate information, and expect it to grow 50% or more each year.

Unstructured Information is Unmanaged Information Unstructured data is typically unmanaged. The file system on which this information resides typically is not monitored and the content is practically invisible to employees, auditors or corporate compliance officers. In an effort to provide a greater degree of visibility, control and management of this information to meet compliance reporting requirements, companies have implemented one or more technologies, each of which has advantages and disadvantages:

Enterprise search ? An enterprise search engine is an effective way to index and find documents that contain certain terms. Most are easy to implement and require only a modicum of regular maintenance. Unfortunately, most enterprise search engines are tuned to find all the documents that may contain a particular term, rather than a specific document that may be required by an auditor. It is left to the user to winnow through all the returned documents to find what they need, which can be a time-consuming and costly exercise. Additionally, search engines are mostly lacking in providing the ability to manage the documents it indexes.

Enterprise Content Management ? ECM systems can effectively manage many types of content and can provide access and version control, both of which are effective aspects of information management. ECM systems also tend to be very expensive to setup and maintain. These systems typically require an organization to purchase server and user licenses, implement policies and processes for using the system, and train its users. Because of these costs, companies often limit their ECM implementations to specific areas of their business or types of data, such as documents that pertain to finance. According to many analyst organizations, ECM systems are being used to manage approximately five percent of today?s corporate information.

File Backup ? Many companies attempt to solve the problem of document retention by creating regular backups of all the data on the network. These backups are saved to tapes, which are then stored offsite for disaster recovery purposes. Backing up all data regardless of its business value is an inefficient use of time and resources, increases the cost of tape storage and decreases the likelihood of rapid single file recovery, which is the most-used aspect of file backup.

Doing nothing ? This is the ?solution? that many companies choose for handling unstructured information. Unfortunately, the prevailing thought among many has been that unstructured information is insignificant and therefore does not require management. After all, most of this information ranges from personal files to draft documents or one of dozens of copies of sales presentations, the majority of which aren?t worth the cost required to manage them.

While most files aren?t worth managing, the risk comes from the small number of files that do matter. For instance, your Sarbanes-Oxley policy and procedure manual, which took valuable internal resources, a consulting firm, and many months to create, has likely been copied from the content management system specially created for finance-related documents. The next time you update that manual with critical information, you have fulfilled one aspect of the act by tracking and recording those changes in your records management system. However, what about the dozens of copies that may have spread across the network on shared file servers? How can you be certain those copies are deleted or updated to keep people from following old procedures or controls? If you aren?t doing anything to manage that data, you are leaving your company exposed and vulnerable.

Recognizing Valuable Information
Addressing these issues is key to an effective solution for Sarbanes-Oxley or any information governance initiative. Obviously doing nothing is not the answer. At the same time, it would be cost-prohibitive to manage all files as though they were critical business records. Therefore, the ability to specify which data is critical and worthy of this level of management is a crucial first step. If you are aware of the data?s value, you can make educated decisions as to the disposition of important data and create an appropriate retention policy.

Determining a data?s value is a result of effective information visibility and control.

Information Visibility ? The first aspect of recognizing valuable data requires that it be visible. While your compliance office may have access to all corporate information across the network, the sheer amount of data necessitates the use of technology to find and manage the appropriate documents.

Information Control ? To effectively manage and control unstructured information, you need a solution that allows you to copy, move, delete or tag documents with custom metadata; i.e., information about the document. Even better, the solution should provide an integrated policy engine that can be customized with your company?s information governance regulations. For instance, creating a policy mandates that any document on the employee network that contains a customer account number must be 1) tagged with custom metadata of ?Customer,? and 2) moved to a secured server or file archive system.

Data classification is an important aspect of information visibility and control. Several products have emerged or expanded into this space, to offer an all-embracing solution for complying with Sarbanes-Oxley and other regulations. By implementing one of these data classification systems, documents on your network can be located, opened and tagged according to the content found within each document. A typical classification workflow might look something like this:

1. Catalog ? The system scans the file systems, finding and collecting file metadata from hundreds of file types.

2. Classify ? Opening each document, the system classifies data according to file attributes and keywords or word patterns, and tags with custom metadata according to pre-set policies.

3. Search ? The system allows users to find desirable information based on a combination of metadata and full document text, utilizing standard Windows and UNIX access control lists.

4. Report ? The system should allow appropriate users to create and access summary or detailed reporting functionality.

5. Act ? Finally, the system should integrate actions, such as tagging files with custom metadata, setting retention and monitoring policies, and offering move, copy and delete functionality, again based upon an access control list.

To contrast, an enterprise search engine provides an efficient method to find content that contains the search term you need. But then what? If you wanted to copy, move, delete or perhaps tag the document with customized metadata, you would have to manually do so.

Data Retention, Availability and Recovery Retention is another aspect of corporate information that cannot be overlooked. While many companies elect to back up all data on a weekly or monthly basis, the cost of time and resources increases as the amount of data grows. Knowing what is in your data ? by making information visible, by tagging with metadata and by controlling access ? allows you to intelligently create a retention policy that moves or backs up only the data needed to comply with your corporate information governance policy or government regulation.

Most organizations use a backup solution that periodically copies data to tape or disk drives. An organization may back up its mission-critical data every night and all of its data every week. It may store the backup tapes for up to six months to guard against accidental deletions, send tape copies offsite as a safeguard against disaster and retain backup tapes long-term to meet regulatory requirements.

Lacking the means to gauge the value of the data, companies often take the safe route and back up all of it. Not only is the approach ineffective, it indicates inefficient data management and creates a potential risk. Storing data that is not required to be kept can be used against a company in the event of a lawsuit or regulatory compliance issue. In this respect, backing up data in its entirety creates a liability.

Corporations can meet regulatory data retention requirements, cut backup and recovery costs and manage risk by introducing file archiving into the mix.

A file archiving system uses data classification to determine the content?s value, then moves or copies files according to that value. File archiving systems can find and retrieve files based on their content. Any number of parameters can be used, including author, date, and customized tags such as ?SEC 17a-4? or ?Sarbanes-Oxley.?

This naturally leads us to the tiering of storage services. Backup and file archiving are natural places to start for providing tiered storage services, based upon the value of the data in your network.

As an example, consider a company that has 10 terabytes (TB) of data on production file servers. In the past, the company may have backed up critical files onto disk storage and then backed up all files onto tape once a week. The company catalogued the tapes, kept them for three months and then cycled them back through the process. New government regulations mandate that all data related to quarterly financial results must be kept for five years. Unfortunately, the company has no way to differentiate among the disparate types of data on its network. The company is forced to retain all of the data for five years, expanding the amount retained from 10 TB to 2.5 petabytes (PB). As data amounts double annually, so will the amount that must be stored. The company will find itself devoting more and more time and resources to data backup.

To solve this problem, let us assume that the company implemented a data classification system. By discovering the value of its unstructured information and tagging according to the value, the company copied 500 GB of financial reporting data to WORM storage for long-term retention and moved seven TB to tiered storage, which is backed up to tape every three months. The data in three-month storage would total 42 TB, compared with the 2.5 PB that would have been required if the data had not been archived. With tiered storage, the company significantly reduced backup time and resources, shrank the cost of production file storage and increased its IT service levels by freeing up personnel and data for other tasks.

Tiering your data storage services allows you to put SOX controls only around the data that pertains to your financial information and lock down the appropriate data on compliance-specific storage boxes.

Proving Compliance

The old adage is true: the best defense is a good offense. In the case of Sarbanes-Oxley compliance, the best offense is to create and implement provable policies. Having a data classification system allows you to produce standard reports that show duplicate copies of applicable documents, that show who has accessed the file within a specific time period, and that monitor implementation of your information governance policies. With reporting functionality available in a dashboard implementation, you can think of your system as a burglar alarm: a deterrent to potential wrongdoing and a way to prove that you?re actively checking for compliance-related issues.

Best Practices
Implementing one of today?s data classification systems should be an integral part of your Sarbanes-Oxley best practices. Setting information governance policies fulfills a basic requirement. Active management of your unstructured data will find, tag and move content according to your corporate policies, lowering the risk that information will ?fall through the cracks? and potentially protect you from breaking the law. Creating a tiered storage system will allow you to set retention policies according to the value of the content, saving money and reducing risks. And proving compliance ? or at least show that you?re attempting to comply ? is sometimes the best way to meet and exceed current ? and future ? government regulations not only around financial systems but around employee and customer privacy as well.

Reducing Risk and Lowering Costs
In the end, the benefits of visibility and control of your unstructured information reduces risks ? of compliance violations, litigation exposure, untimely responses and privacy and security breaches ? and lowers costs through streamlined storage operations, improved service levels and automated policy-driven data management.

Monday, October 20, 2008

Kazeon eDiscovery Solutions featured in Information Week

With its award winning eDiscovery software and growing list of Global 2000 companies which rely on its eDiscovery for proactive and reactive litigation processes, Kazeon makes the news again in a new article in Information Week. To find out the whole story....See the full article below.......

http://www.informationweek.com/news/business_intelligence/mining/showArticle.jhtml?articleID=210604040&pgno=1&queryText=&isPrev=