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Implementation of Records Management Principles
 
 
 
In each of the following sections, pick the answer for each question that best describes the current situation at your firm. There are no ‘right or wrong’ answers, just what is currently implemented at your company. In order to answer these questions, you do not need to be a Records Management expert, but to help you understand purpose of the questions a short definition is provided within each section.
   
 
 
 
Principle of Accountability
 
 
 
Accountability embodies the following: Responsibility for recordkeeping is formally designated to ensure program development & program implementation. Policies and procedures are documented, formally approved, and communicated to personnel. The program is monitored for compliance; any areas requiring improvement are identified and improvements are implemented. Governance is established through the organization, assigning defined roles and responsibilities Auditability, the process designed to prove the program is accomplishing its goals while seeking areas for improvement to further protect the organization and its records, is in place.
   
 
 
 
Implementation of Records Management Accountability: Organization Structure
 
Records Management is not a well formed organization; RM operational aspects report to multiple functional managers
 
Records Management department is a recognized department but operates without direct senior management oversight and control
 
Records Management reports in to a Director level position
 
Records Management reports in to a VP level position
 
Records Management reports in to C-level position
 
 
 
Existence and Scope of a Records Management Functional Manager
 
No identifiable Records Manager position exists or Records Management oversight is an administrative role distributed among non-dedicated staff.
 
Records Management functional manager is in place but doesn't own electronic records
 
Records Management functional manager is in place and owns both paper and electronic records
 
Records Management functional manager is in place and is a director level or equivalently high level officer
 
Records Management functional manager is in place and reports to a C-level position
 
 
 
Records Management Orientation
 
Records Management is tactical, i.e. focused on day to day activities only, and is disorganized
 
Records Management is tactical, focused on day to day activities only, but is well organized
 
Records Management is mostly tactical with some strategic, long term initiatives
 
Records Management has strategic and tactical aspects integrated
 
Records Management’s strategic goals are elevated to top level consideration as impactful to the overall corporate well-being
 
 
 
Records Management Scope
 
Records Management operations handle paper records for a cluster of local departments
 
The Records Management operations’ scope encompasses the entire company but processes paper records only
 
Records Management operations’ scope encompasses the entire company and covers both paper and electronic records
 
Records Management is integrated companywide, covers all media forms and the importance of RM is visibly recognized by senior management
 
 
 
Records Management Visibility
 
Only the departments that actively use the records management functions are aware of them
 
Some departments that don’t normally handle documents know to check with Records Management when they have a document related project
 
There are ongoing Records Management active initiatives within the company; senior management has awareness of Records Management
 
Records Management has full executive sponsorship which in turn makes most department aware of its functions
 
Senior management has ownership of Records Management and the high visibility makes everyone aware of the importance of records management
 
 
 
Would you say all corporate goals related to accountability are being met? If not, what remains to be done?
   
 
 
 
Principle of Transparency
 
 
 
Transparency embodies the requirement that every organization must create and manage the records documenting its recordkeeping program to ensure that the structure, processes, and activities of the program are apparent and understandable to legitimately interested parties and that the records documenting the program and its activities are reasonably available to them.
   
 
 
 
Transparency Adoption
 
No emphasis on the importance of Records
 
Some realization of the importance of Records
 
Records Management is taken seriously in the organization
 
Records Management is an essential part of the organization’s corporate culture
 
Records Management is a key component of information governance in the organization
 
 
 
Access to Information
 
Access to information is difficult; requests are not readily accommodated;
 
Access to information is limited;
 
Information is readily available
 
Software tools to assist access to information
 
 
 
Transparency Implementation
 
No established controls for information access exist
 
Control of information access exists in some areas but is not systematic
 
Information has systematic availability; there is a written policy regarding transparency
 
Information access is monitored for compliance
 
There are continuous improvement programs covering transparency
 
 
 
Would you say all corporate goals related to information transparency are being met? If not, what remains to be done?
   
 
 
 
Principle of Integrity
 
 
 
Integrity embodies the following: the ability to prove that a record is authentic and unaltered. Authentication requires proof that a document comes from the person, organization, or other legal entity claiming to be its author or authorizing authority.
   
 
 
 
Integrity Authentication
 
There is no defined process for authentication
 
There is some data for authentication such as indices for physical records and metadata for electronic records but there is no systematic process
 
There is a formal process for integrity authentication
 
There is a clear, well established process for integrity authentication with high level requirements
 
There is a clear, well established process for integrity authentication with high level requirements that is applicable to new systems as they are developed
 
 
 
Chain of Custody
 
Chain of custody processes are ad hoc, vary by department and are not trustworthy
 
There is an emerging process but no formal process for chain of custody
 
There is a formal process for chain of custody covering physical and/or electronic records
 
The process for chain of custody has security and signature requirements allowing for both physical and electronic records
 
There is a clear, well established process for chain of custody with high level requirements that is applicable to new systems as they are developed
 
 
 
Integrity Processes
 
Integrity processes are ad hoc, vary by department and are not trustworthy
 
There is an emerging process but no formal process for integrity but local variations exist
 
Compliance of the integrity process has been verified
 
The integrity process is advanced to the point metadata is integral with the RM process
 
The integrity process is consistent across the enterprise and is explicit as to the requirements
 
 
 
Integrity Audits
 
Integrity audits are not conducted
 
Integrity audits are conducted but are not regular
 
There are regular integrity audits that are easy to execute because of the integration of the process
 
 
 
Would you say all corporate goals related to information integrity are being met? If not, what remains to be done?
   
 
 
 
Principle of Protection
 
 
 
Protection embodies the following: protection requires an appropriate security structure so only personnel with the appropriate level of security or clearance can gain access to the information. Further information is secure from “leaking” outside the organization. Finally, an organization’s audit program must have a clear process to ascertain whether sensitive information is being handled in accordance with the protection policies.
   
 
 
 
Privacy Protection Adoption
 
No consideration is given to the protection and/or privacy of information in the records being managed
 
Some consideration is given to the protection of information privacy
 
A formal written policy and supporting procedures exist for the protection of information privacy
 
Systematic protection of sensitive information is provided by implemented procedures and applications
 
The protection of information including the privacy of records has recognized value at the senior management level; because of this inadvertent disclosure is rare
 
 
 
Access Controls
 
Access control to a record is assigned by the author or individual records manager
 
Access control is centralized but not uniform and automated
 
Uniform procedures and automated systems provide access control protection
 
Continuous improvement programs exist to make sure access control stays compliant and tracks technology changes
 
 
 
Storage and Transmission
 
The storage and transfer of information and records is not regulated by policy and is at times haphazard
 
A policy exists for some aspects of storage and transmission of managed information but it is not complete or not well implemented
 
There is a formal written policy and implementing procedures covering the key aspects of records and information asset storage and transmission
 
Systematic protection of information and records is provided by a uniformly applied policy and assisting technology
 
Continuous improvement programs exist to make sure the storage and transmission protection stays compliant and tracks technology changes
 
 
 
Compliance
 
Monitoring and enforcement of protection policies is decentralized
 
Information is protected by a written policy but it has limitations
 
Compliance audits are conducted in regulated areas of the company; employee training is provided
 
Compliance audits are conducted on regular basis across the enterprise; employees are trained and tested for competency
 
Compliance to the protection policy has senior management attention including audit information review
 
 
 
Would you say all corporate goals related to information protection are being met? If not, what remains to be done?
   
 
 
 
Principle of Availability
 
 
 
Availability embodies the following: the ability to identify, locate, and retrieve the records and related information required to support its ongoing business activities; having an efficient and intuitive set of methods and tools to organize the records of the organization; providing employees and agents with sufficient training to utilize these tools successfully; and removal of obsolete or redundant records in adherence with the organization’s records retention policies.
   
 
 
 
Availability of Information When and Where Needed
 
Records and other information assets are not readily available
 
Records retrieval mechanisms have been deployed in some areas
 
There are established standards for availability for guidance
 
Clear policies exist and are implemented to make records and information readily available when and where needed
 
Policies and processes concerning the availability of information are reviewed and supported by senior management as business drivers
 
 
 
Availability Organizational Issues
 
Retrieval of records takes time and the 'official' version is hard to identify
 
There is spotty implementation of retrieval mechanisms; no standards exist as to how readily information should be available to knowledge workers
 
The ‘Official' version of a record is identifiable and retrievable 'most of the time'
 
Records and information assets are consistently and readily available so employees have ready access to the information they need to do their job
 
There is organized knowledge worker training on availability; continuous improvement programs exist to make sure implementation is state of the art
 
 
 
Tools for Availability
 
Automated retrieval tools to assist availability are few; information is lacking indices, metadata, and/or locators
 
No standard tools are deployed enterprise-wide; some classification and/or retrieval tools exist in some areas
 
Consistent classification, storage and retrieval mechanisms are deployed across the enterprise
 
There is a centralized inventory of identified information assets that is used to assist access to records
 
Information access processes and tools are continuously upgraded to realize the ROI of availability
 
 
 
Legal Discovery
 
Legal discovery is a difficult due to issues of availability
 
Legal discovery is more complicated & costly than it should be; inconsistent availability of information is an issue
 
A well defined, systematic process exists to execute legal discovery
 
All appropriate systems in place to implement the legal discovery process including an automated hold process
 
Continuous improvement programs with senior management support exist to make sure the legal discovery process is state of the art
 
 
 
Would you say all corporate goals related to availability are being met? If not, what remains to be done?
   
 
 
 
Principle of Compliance
 
 
 
Compliance embodies: adopting and enforcing suitable policies to direct and control its recordkeeping, assuring the recordkeeping system contains information showing that the organization’s activities are conducted in a lawful manner, and legal requirements such as requirements to maintain tax or other records.
   
 
 
 
Compliance Adoption
 
Clear guidelines for records retention don’t exist; compliance with applicable regulations is not defensible
 
Some policies and implementing procedures related to compliance exist but are not complete
 
Relevant laws and regulations have been identified and addressed by compliance programs; compliance is highly valued in the organization
 
Records are retained and linked to compliance metadata or other evidencing mechanism
 
Policies and procedures are in place so no adverse consequences are expected due to compliance failures
 
 
 
Compliance Implementation
 
Records are not managed in accordance with generally recognized principles
 
Some compliance policies and operational procedures have been implemented but are not complete
 
There is systematic, principled Records creation, capture, storage and disposition enterprise wide
 
There are systems to capture and protect; employees are trained on the systems; regular audits document compliance
 
All of the audit gaps have been addressed and there is a program for continuous improvement
 
 
 
Compliance Organizational Issues
 
Compliance activities are decentralized; there are no compliance standards; there is no oversight of compliance
 
Sporadic compliance policies exist but there is no accountability
 
There is a strong code of business conduct integrated into Records Management and Information Governance policies
 
Audits and reviews are conducted; remedial action is taken whenever needed
 
Auditing results are reviewed by senior management; continuous improvement is a top level mandate
 
 
 
Legal Hold Process
 
No defined or well understood legal hold process exists
 
A legal hold process exists but is not integrated with Information Management and discovery processes
 
An integrated legal hold process exists but is for critical systems only
 
An integrated, repeatable, enterprise-wide legal hold process with defined roles exists
 
The legal hold process is integral with the organization’s Information Management, records management and discovery processes
 
 
 
Would you say all corporate goals related to compliance are being met? If not, what remains to be done?
   
 
 
 
Principle of Retention
 
 
 
Retention embodies: the document life cycle, which is the time period from the creation of a record to its final disposition; addresses legal and regulatory compliance, fiscal accountability, operational business needs and historical information.
   
 
 
 
Retention Schedule
 
No Retention Schedule or other official procedure for actively controlling the life cycle of documents based on their classification and applicable laws exists
 
A Retention Schedule has been created but is not actively communicated nor well implemented and/or the Retention Schedule is not updated or maintained
 
A formal Retention Schedule exists and is in general, consistent use
 
The Retention Schedule is in use and is reviewed and adjusted whenever needed by an effective process
 
In addition to having an up to date and well deployed Retention Schedule, the overall principles of retention are a senior management priority
 
 
 
Retention Implementation
 
Rules and procedures are haphazard; a retention schedule may exist but is not identified, trained on and centralized
 
Retention schedule does not encompass all records or all needs
 
Defined retention related goals exist and procedures to realize these goal, such as a retention schedule , are being implemented
 
Records retention is well implemented due to major attention with ongoing improvements
 
Retention is an integrated Information Management process applying to all business info and integrated into applications; stated goals related to retention are all met
 
 
 
Retention Organizational Issues
 
Employees retain and dispose potential records based on perceived needs
 
A Retention Schedule exists but is not well known; little or no training on the retention procedures is done
 
Employees are aware of the Retention Schedule and many are able to apply it
 
In general, employees understand how to classify records and process reccords in acccordance with the Retention Schedule; training on the Retention Schedule procedures is in place
 
Information is consistently retained for appropriate periods of time
 
 
 
Would you say all corporate goals related to retention are being met? If not, what remains to be done?
   
 
 
 
Principle of Disposition
 
 
 
Disposition embodies the following: destruction, return to clients, transfer to another organization in connection with a divestiture, or transfer to an historical archive; if records are converted or migrated to new media, disposition of the previous media; suspension in the event of pending or ongoing litigation or audit.
   
 
 
 
Disposition / Transfer Process Adoption
 
No documented processes for disposition exist
 
Preliminary guidelines for disposition have been established
 
Official procedures for disposition have been developed
 
Disposition procedures have been adopted and are understood by all
 
Disposition processes are consistently applied and effective; further, the processes are regularly evaluated and improved
 
 
 
Disposition / Transfer Process Implementation
 
Individuals take actions without documented processes
 
There is sporadic enforcement and auditing of disposition processes
 
Disposition policies and procedures are not standardized; but a collection of individual departmental procedures is in place
 
There is consistent application of disposition procedures across the enterprise; further, electronic information is expunged, not just deleted
 
The disposition process covers all records, on all media; the disposition process is assisted by technology and integrated into applications and data storage
 
 
 
Legal Hold Process Ability to Halt Disposition Process
 
No Legal Hold process is in place across organization
 
There is a recognition of the need for Legal Hold and some awareness of the requirements
 
An official Legal Hold policy and procedures have been developed
 
The Legal Hold process is defined, understood and used consistently as evidenced by monitoring
 
The Legal Hold process is defined, understood and used consistently; to further assure no inappropriate disposition occurs, the process is assisted by technology
 
 
 
Would you say all corporate goals related to disposition are being met? If not, what remains to be done?
   
 
 
 
Are there any comments you would like to make regarding any of the above questions?
   
 
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