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NOTES
RIM FOR THE NEXT GENERATION: A CALL TO ACTION
All-Partner Teleconference | June 24, 2009
MER Conference| May 8, 2012
Charles R. Booz Michael Salvarezza Julia Brickell
Information Governance, Inc. LRN H5
©2012
©2012
©2012
2012 Managing Electronic Records Conference 13.1
2. Cohasset Associates, Inc.
NOTES
©2012
©2012
CHALLENGES
eDiscovery Federated RM
Email Archiving Enterprise IG Platforms
Electronic RM
New Laws?
Financial New Regulations?
HIPAA
Crisis 2008 New Laws?
Morgan Stanley
E‐Discovery irregularity fine $1.58b New Regulations?
Enron Scandal Zubulake‐UBS Warburg
Sarbanes‐Oxley FRCP 2006 Goldman
Sachs
DoD 5015.2 9/11 MoReq
Patriot Act
©2012
2012 Managing Electronic Records Conference 13.2
3. Cohasset Associates, Inc.
NOTES
CHALLENGES
Complexity of Information Governance
Requirements
Complexity of
requirements grows
Current exponentially with size of
Generation organization
Solutions
"Small" SMEs "Large" SME's Fortune 2000 Fortune 500 Fortune 100
Complexity of rapidly changing compliance landscape
Complexity of corporate/legal structure
Complexity of content/context
Complexity of infrastructure
Complexity due to sheer volume of information
©2012
CHALLENGES
Title 21 CFR 11
SEC 17a-4
MiFID
Patriot Act
DoD 5015.2
©2012
Records Management vs. Social Media vs. Business
Records
Management
Social Media is about: Businesses
Promotes: care about:
•Sharing •Governance •Agility
•Collaboration •Complexity
•Open-ness •Access to
•Rapid access information
to Information •Insights
derived from
information
•Speed and
results
9
©2012
2012 Managing Electronic Records Conference 13.3
4. Cohasset Associates, Inc.
NOTES
INFORMATION GOVERNACE
IDARS
Legal
ECM
Security
Governance, Risk Information Enterprise Information
Regulation Management, and Management
Compliance (GRC)
Compliance (GRC) Governance
Financial Imaging Systems
Reporting
Compliance Business
RM Intelligence
Managing
Risks
©2012
Records Information Management
End Users End Users
Laws Security
Content Producers Regulations BOD Privacy Content Consumers
Risk Officer Officer Other
‐ MS Office Internal Policies ‐ MS SharePoint
‐ MS SharePoint Officer Officer ‐ Alfresco
Best Practices
‐ Alfresco Etc. Legal ‐ Business Applications
‐ Business Applications Counsel Corporate CorporateCompliance ‐ Social Media
‐ Social Media RM IT Officer
Capture Information? POLICY: (e.g., Retrieve Information?
Security?
Cost Governance? Corporate
Records
Data Privacy?
D t Pi ? eDiscovery & Holds?
l
Lifecycle Event Sources Retention
‐ Business Applications
‐ Processes
Schedule)
Events that impact Standard Metadata Definitions?
information lifecycle?
System Admin?
Business Records
Managers Management? Storage ILM?
Federated RM
Functionality?
ECM ECM Social Other
RSD Folders
System System Media Repositories
Jurisdiction A Other Jurisdictions
Jurisdiction C
Jurisdiction n
©2012
Records Information Management
‐ Paper
‐ Film
‐ Fiche
Physical Unstructured content
documents (high volumes)
Web pages Electronic ‐ MS‐Office
Other types ‐ PDF
Social Media of formats documents ‐ Other
Types of
Record
Formats ‐ MS Exchange
Entries in data Data in data ‐ Lotus Notes
warehouse warehouses Messages ‐ IM
‐ Social Media
Structured content
(very high volumes)
Data in
Entries in SQL Sections of ‐ AFP
application
Database large reports ‐ PDF
databases ‐ Other
©2012
2012 Managing Electronic Records Conference 13.4
5. Cohasset Associates, Inc.
NOTES
INFORMATION GOVERNACE
IG Function RM IT
Lifecycle of Responsibility RM Program and Records Often views RM as low priority and limited
unstructured content Retention Schedule (retention policies). to paper & electronic documents.
Lifecycle of Often unaware/unable to manage Maintains control of its lifecycle.
structured content lifecycle of this content.
EDiscovery and holds Limited scope to unstructured Gaining role conducting discovery within
documents declared as records. corporate repositories and producing
them.
Data Privacy of Often unaware/unable to manage data Expects RM to manage privacy aspects of
content privacy aspects of records. unstructured content. Often views privacy
of structured content as data security.
f t t d t t d t it
Reduce Cost Limited visibility and leverage over Focused in reducing cost of infrastructure
topic. but lacks ability to optimize infrastructure
costs versus IG SLAs.
Philosophy Organize information – cannot rely on Why organize, simply search.
search
Differences in Lingo
Archive Move content offsite when no longer Backup and recovery term.
needed.
Information Lifecycle Manage retention/disposition of Move content to lower cost storage tiers
Management content. (Storage ILM).
©2012
INFORMATION GOVERNACE
Compliance Risk
Officer Officer
Legal
Counsel
Retention &
Disposition RM
Other Lifecycle Lifecycle of Paper
Other facets Record (Storage)
Officer
Lifecycle of
Record Lifecycle of Data Privacy
IT Content Index Attributes Privacy settings Officer
Lifecycle of Lifecycle of
Security
Metadata Security Officer
IT Groups Classification
Lifecycle of
Electronic Record
Privacy (Storage ILM)
Officer IT
©2012
INFORMATION GOVERNACE
Security Privacy
Officer BOD
Risk Officer Other
Officer Officer
Legal
Counsel Corporate Corporate Compliance
RM IT Officer
Information Governance Steering Committee
Corporate IT: Manage corporate information and IT Compliance Officer: Oversee and manage compliance
infrastructure issues within organization
Corporate RM: Security Officer: Responsible for security matters within
‐ Manage process of creating IG policies organizations, including data security
‐ Ensure that policies are up to date
‐ Ensure policies are available to field personnel Other Officer: Other corporate officer
Legal Counsel: Responsible for legal department within BOD: Board of Directors with primary responsibility for
approving corporate IG policy
organization ‐ must be able to act decisively regarding
legal challenges that face organization. Other: Depends on organization.
Risk Officer: Manage risk matters within organization
Privacy Officer: Oversee and manage compliance with
Privacy laws and regulations
©2012
2012 Managing Electronic Records Conference 13.5
6. Cohasset Associates, Inc.
NOTES
INFORMATION GOVERNACE
Information Governance
End Users Steering Committee End Users
Laws Security
Content Producers Regulations BOD Privacy
Officer Officer
Content Consumers
‐ MS Office Internal Policies Risk Other ‐ MS SharePoint
Best Practices Officer Officer
‐ MS SharePoint ‐ Alfresco
‐ Alfresco Etc. Legal ‐ Business Applications
‐ Business Applications Counsel CorporateCorporate Compliance ‐ Social Media
RM IT Officer
‐ Social media
Information Governance Policies
Capture Information ‐ Retention and Disposition Retrieve Information
‐ Data Privacy Corporate IG Policies
‐ Discovery Security
‐ Migration across storage tiers
‐ Standard Metadata Definitions
Cost Governance
‐ Other
Lifecycle Event Sources Data Standard Metadata Definitions eDiscovery & Holds
‐ Business Applications Privacy EDiscovery
‐ Processes Enterprise Information Governance Platform & Holds
Events that impact
information lifecycle IG Policies Control and IG Policies
Administration System Admin
Business Records
IG Control & Admin of lifecycle for IG Control & Admin
Managers Management
ALL information Storage ILM
Enforcement Enforcement
Enforce lifecycle actions
ECM ECM Social Other
RSD Folders
System System media Repositories
Jurisdiction A Other Jurisdictions
Jurisdiction C
Jurisdiction n
©2012
INFORMATION GOVERNACE
Records Information Management
•Manual Retention Policy Methods
•Policy remote Excel/Email/Paper/PDF Jurisdiction #1
End User
•Unstructured documents File
Plan
File
Plan
File
Plan
Retention Retention
•Retention policy ONLY Schedule
Manual
Schedule
•Little or no involvement of IT RM
RMA
Records Records
Admin Admin
Jurisdiction #2
File File File File
Plan Plan Plan Plan
Manual Administration Retention
Schedule
Retention
Schedule
Manual
of RIM Program Records
RM
Records
RMA
Admin Admin
Risk Jurisdiction #n
Officer Corporate File File File File File File
Corporate
IT RM Plan Plan Plan Plan Plan Plan
Retention Retention
Legal Retention
Schedule Schedule
Counsel Corporate Schedule
RMA Manual
RM Records Records
RM
Admin Admin
Conventional Corporate RM Program
©2012
INFORMATION GOVERNACE
Strategic Information Governance
•All facets of Information Lifecycle
•Management of all forms of records Jurisdiction #1
End User
•Policies in application integratable form File File File
Plan Plan Plan
•Direct involvement of IT & others IG Policies
IG Control & Admin
Records Records
Enforcement
Admin Admin
Jurisdiction #2
File File File File
Integrated Administration
Integrated Administration Plan Plan Plan Plan
RRS
of IG Program IG Policies
IG Control & Admin
Records Records
Admin Admin Enforcement
Risk Jurisdiction #n
Officer Corporate File File File File File File
Corporate
IT RM Plan Plan Plan Plan Plan Plan
Legal IG Policies RRS RRS
Counsel Corporate
IG Policies IG Policies
RM Records Records
IG Platform technology deployed at Corporate Admin IG Control & Admin Admin IG Control & Admin
Enforcement Enforcement
Information Governance Program
©2012
2012 Managing Electronic Records Conference 13.6
7. Cohasset Associates, Inc.
NOTES
INFORMATION GOVERNACE
Current Situation Automated Policy Enforcement
Rules Corporate Information
(Policies) Governance Policies
RM Data Privacy Structured Information Governance
Policies Content Corporate/Regional/Jurisdictional
Policies Control & Admin Repositories Control and Administration Processes
Control & Admin
Control & Admin Tools
Repository Policies
Control & Admin (Control & Records Data Audit
ECM eDiscovery Repository Admin) Mgmt Privacy Mgmt
IDARS
Policies eDiscovery Other
Policies Control & Admin
Policies
Control & Admin Control & Admin
Repository Repository
Information Repositories
Regional/Jurisdictional/Local
Next Generation Intelligent Tools Content in Content in
Content Addressable Storage (Repositories) ECM Systems Data Whse
Repositories Policies
Control & Admin Content in
Repository Content in IDARS
CAS Systems
Size of bubbles not to scale
©2012
Leveraging Automation
© 2012 H5
©2012
Uses of Automation
Automated classification can help Records
Managers to:
Find the data
Review the data
Sort the data
Classify the data you need
Reduce the data you don’t need
© 2012 H5
©2012
2012 Managing Electronic Records Conference 13.7
8. Cohasset Associates, Inc.
NOTES
Advantages of Automation
Automation, chosen and customized with proper
expertise:
Can be used to decide what to keep and how to
categorize it
– Better than people
p p
– Faster than people
Can address:
– Internal and external data
– Data in motion
Increases likelihood of getting the job done
© 2012 H5
©2012
Approach
Consider the data stashes
– Used for different purposes
– Contain different content
– Important for different reasons
Assess the information likely to be useful from each
data stash
– What types of information are important?
– Whose data might contain that content?
What departments? What people?
© 2012 H5
©2012
Classification Quality with Automation
Human Tagging
– No desire to do it
– Inaccurate
– Inconsistent
– Not exhaustive
– Requires expensive training and documentation
Automated Tagging
– Fast
– Consistent, but…
– Without expertise, results vary wildly
© 2012 H5
©2012
2012 Managing Electronic Records Conference 13.8
9. Cohasset Associates, Inc.
NOTES
TREC Legal Track
National Institute of Standards & Technology
Text Retrieval Conference (“TREC”) has a Legal Track
designed to evaluate effectiveness of search technologies
and methods
M
Measures ability t id tif d t responsive t h
bilit to identify data i to hypothetical
th ti l
“topics” or “requests”
Open to the public (vendors, law firms, academics)
Uses publicly available data sets
Quality is measured in terms of “precision” and “recall”
© 2012 H5
©2012
TREC 2008 Interactive Task
Finding all
relevant documents
is 100% recall
Precision = correct hits
total hits
Finding only
relevant documents
is 100% precision
n
_correct hits__
Recall =
total responsive
Sponsored by National Institute of Standards and Technology. See TREC 2008 Legal Track Overview at
http://trec.nist.gov/pubs/trec17/papers/LEGAL.OVERVIEW08.pdf (p. 37)
Points represent results after an adjustment to account for state of OCR in the test collection
© 2012 H5
©2012
TREC 2009 Interactive Task
1.0
Finding all
relevant documents
0.8 is 100% recall
Finding only
Precision = correct hits
total hits
relevant documents
0.6 is 100% precision
0.4
0.2
0.0
0.0 0.2 0.4 0.6 0.8 1.0
_correct hits__
Recall
Recall =
total responsive
Sponsored by National Institute of Standards and Technology.
© 2012 H5 See TREC 2009 Overview http://trec.nist.gov/pubs/trec18/papers/LEGAL09.OVERVIEW.pdf
©2012
2012 Managing Electronic Records Conference 13.9
10. Cohasset Associates, Inc.
NOTES
Search “superior to manual reviews”
Richmond Journal of Law
and Technology (2011)
___________________________
“Of course, not all technology-assisted
reviews (and not all manual reviews) TECHNOLOGY-ASSISTED
are created equal. The particular REVIEW IN
processes found to be superior in this E-DISCOVERY CAN BE MORE
study are both interactive, employing a EFFECTIVE AND MORE
combination of computer and human EFFICIENT THAN
input.” (p.48) EXHAUSTIVE MANUAL
REVIEW
Maura R. Grossman
Gordon V. Cormack
XVII RICH. J.L. & TECH. 11 (2011), http://jolt.richmond.edu/v17i3/article11.pdf
© 2012 H5
©2012
A Better Search Results in Less Data
100,000 Impact of calibrated filter over prior
filter for every 100,000 records
90,000 filtered
80,000
Non-Relevant
70,000
Relevant
60,000
60 000
95,900
50,000
40,000 66,900
30,000
20,000
12,600
10,000
4,100 4,100 4,100
0
Starting Population: Prior Filter: H5 Filter:
Calibrated Filter
Contains Filters In Filters In
Filters in
100,000 Documents 71,000 Documents 16,700 16,700
Documents
Documents
© 2012 H5
©2012
Search Myths
All search methods are created equal
All search tools are created equal
All search terms (queries) are created
(q )
equal
No special expertise is required to
search
© 2012 H5
©2012
2012 Managing Electronic Records Conference 13.10
11. Cohasset Associates, Inc.
NOTES
Test the Tools
Tools have different capabilities
Tools have different default setups
Most tools index the data to search it
Most tools don’t index everything
© 2012 H5
©2012
Test the Terms
Types of search:
Keyword/Boolean
Concept Search
• Ontology Based
•A l
Analyze word/phrase relationships (B
d/ h l ti hi (Bayesian)
i )
Clustering (Bayesian)
• Auto-classifier
• Near Duplicates
• Predictive Coding
Experts know the strengths and weaknesses
© 2012 H5
©2012
Effective Search Methodology
Develop and test the Terms Technology
Interview subject
matter experts
Measure
Design accuracy
Define target queries Apply to data
Sample data
Knowledge Transfer Measurement Consistency
Linguists, Statisticians, Researchers, Attorneys, Project Managers, Computer Scientists
© 2012 H5
©2012
2012 Managing Electronic Records Conference 13.11
12. Cohasset Associates, Inc.
NOTES
H5 EDGE Classifier
Effective Search Methodology
Search Design Network
Interview attorneys and
subject matter experts
3
Measure accuracy
2 Define target Classifiers
Design queries
Sample data
4
Client Network
4
1
Incumbent Engine
5 5
Client Infrastructure
Client/Archive Hosted litigation
Review platform
© 2012 H5
©2012
Search Realities
Search and automation is an expertise
Competency requires knowledge and
process:
– Tools: What’s the instrument? What is its
approach to processing? To indexing? To
? ?
retrieval? What searches can it handle?
– Terms (search queries): What do you need to
find? How do you craft queries? How do you test
their effectiveness?
Quality requires expertise in the tools and the terms
© 2012 H5
©2012
Search Expertise Matters
“Whether search terms or ‘keywords’
will yield the information sought is a
complicated question i
li t d ti involving th
l i the
interplay, at least, of the sciences of
computer technology, statistics and
linguistics.”
United States v. O’Keefe,
537 F. Supp. 2d 14 (D.D.C. 2008)
© 2012 H5
©2012
2012 Managing Electronic Records Conference 13.12
13. Cohasset Associates, Inc.
NOTES
Measurement Matters
[TREC] can be expected to identify
… reliable search and information
retrieval methodologies and best
practice recommendations, which, if
adhered to, certainly would support
an argument that the party employing
them performed a reasonable ESI
search, whether for privilege review
or other purposes.
Victor Stanley, Inc., v. Creative Pipe, Inc.,
250 F.R.D. 251 (D. Md. 2008)
TREC: National Institute of Standards and Technology
Text Retrieval Conference Legal Track
© 2012 H5
©2012
STRATEGIC INFORMATION GOVERNANCE CONCEPT
• IG Steering Committee:
► Develop and maintain IG policies and procedures in Organization
• Dynamically Refresh Information Attributes and Lifecycle:
► Automate collection, certification and disposition of all information
• Assure Information Integrity:
► Auditability, Transparency and Authenticity
• Maintain Future Efficacy:
► Anticipatory and Flexible
Organization
Information Governance
IG Policies: Steering Committee
‐ Retention and disposition
‐ Data Privacy ORGANIZATION IG Policies
‐ Electronic discovery
‐ Lifecycle of content
‐ Lifecycle of content indexes
Local IG Policies (Jurisdictions)
‐ Lifecycle of metadata
‐ Other IG Control and
Jurisdictions & Legal Entities Administration Activities
IG Policies in Jurisdictions and Legal IG Enforcement Activities
Entities
Business Units
Information created and utilized in Repository Repository
Business Units controlled by IG Policies
©2012
Inspirational Leadership for
Records Management
• Ambiguity is actually OK
• Take risks – go on a TRIP
• Challenge the status quo
– try something different
• Find the value
proposition
• Elevate the conversation
39
©2012
2012 Managing Electronic Records Conference 13.13
14. Cohasset Associates, Inc.
NOTES
RIM FOR THE NEXT GENERATION: A CALL TO ACTION
QUESTIONS
All-Partner Teleconference | June 24, 2009
MER Conference| May 9, 2012
Charles R. Booz Michael Salvarezza Julia Brickell
Information Governance, Inc. LRN H5
©2012
2012 Managing Electronic Records Conference 13.14