Who's in Charge Here?
Compliance and electronic records management is an issue that crosses departments from legal to IT to the end users who often are responsible for implementing the record-keeping procedures. When you mix in all of these different constituencies, it is sometimes difficult to find common ground and get beyond departmental concerns to present a unified view of what needs to be done. Miguel Rodriguez, product manager for records management and email archiving solutions at Mobius, says sometimes these groups have different requirements.
"In some cases, I would say that these types of projects are driven by the general counsel or legal department or a newly created compliance group," he says. "In many cases, IT is just responding to them, and sometimes you find they are not always completely in sync. IT is worried about maintaining the backup and keeping the systems running. The legal counsel and compliance group are more worried about keeping things according to regulations and for the minimum time they have to be kept and having a clear disposition of records and content based on those regulations and on the law."
One way companies deal with this problem is to look at it strictly as an IT or storage problem. Mancini believes this is a flawed approach. As records management gets more complex and more electronic, he says, "people rely on their IT staff to make these calls, and the problem is when you rely exclusively on the IT folks, you wind up with a storage-centric mentality around what needs to be saved. What you need to take into account is legal framework or process framework and come up with a strategy that reflects all of that and uses technology to address those concerns, but doesn't start and end with technology."
End users are another key constituency, and getting them involved early in the process seems to help. Alan Lybeck, group leader of information and documentation services at Guidant/Boston Scientific (a medical devices company which uses Hummingbird solutions to help manage its records), has to deal with intense regulation and litigation issues. He says his company copes by combining IT and compliance in order to build a department with the talents of both groups, but they also look at the records-management implementation process as a project with a defined set of procedures and goals. "We try to bring groups together to partner in the process up front," Lybeck says. "If you try to implement it from one person's perspective, you are going to fall short. We partnered with the compliance organization and IS and some of the business units to run it as a project. You have a project sponsor and you run it through a very specific process to gather requirements, design it, and make sure end-user customers sign off on the design."
One System to Guide Them
Yet another problem companies face is maintaining information across disparate systems. Some of these may be legacy mainframes or other esoteric systems that make it more challenging to gather and maintain the records in a single architecture. In spite of the fact that Guidant/ Boston Scientific is a Hummingbird shop, and Lybeck has been very happy with the way it has handled his record-keeping needs, he believes no single repository can handle every type of data across a range of systems. Thus, he uses the Hummingbird system to maintain business rules for all systems, even when the data can't be maintained in the main Hummingbird repository.
"I believe it's technically impossible to have everything hard-coded to a Hummingbird system," Lybeck says. "How we manage it is that we control the retention program, so for all paper and electronic records, [we define] the categories and rules for managing those categories that dictate how long to retain them." For example, Guidant/Boston Scientific maintains its financial records in SAP, and the Hummingbird system has the rules for how long to retain each financial data type, but the SAP system owners are responsible for adhering to that schedule, Lybeck explains.
However, Systemware's Griffin says using an architecture like SOA (Service Oriented Architecture), it is possible for record keeping to cross systems. "We are not strangers to those very disparate kinds of content silos," he says. "How do you take something out of a Linux or a mainframe system and pull it into one repository and then be able to present it out over the web or present it to back-end processes that may be on a server or a different kind of application or operating system?" Griffin says that Systemware was an early adopter of SOA but that customers have also been looking for architectures that are more open and that allow multiple systems to communicate, and he says that is where his company (and the industry) has been headed.
Build Well and Involve Users
As with any complex system, building a solid electronic records management system takes patience and planning. Mancini says that means taking your time and doing the up-front planning, making sure you understand the problem, then handling the solutions in a very specific and deliberate fashion, getting executive buy-in and taking a top-down approach.
One key ingredient in a successful electronic records project, says Bill Morey, director of records at Corporate Express (which uses EMC solutions), is having an executive sponsor and making sure that the folks in the executive chamber understand the issue without overstating it or getting melodramatic. "You need to bring it down to earth: Here are the real issues without over-blowing them," he says. "I think the obligation is to make it real, make it substantive, and be responsible in terms of what the scope is. What do we need to do as a company?"
Mobius's Winkler says another part of making it a success is getting end users to stay involved, because it does require some input from end users to make a system successful. "There is an element of responsibility on the business unit for understanding the business of records management and how the retention schedule and classification is going to be set up. They need to understand this is an enterprise issue . . . they have to be aware that any piece of content could be declared a record."
Morey says they accomplish this at Corporate Express by going into each department, assessing its needs, and building a system for them that doesn't require users to be archiving experts. "We have an enrollment package. We do an assessment of what kind of documents do you create on a regular basis from your desktop. We do that as quietly as possible behind the scenes, then we come back and train those users who are using the archiving system on a regular basis on what types of documents go into the repository, and what types don't," he says.