Laying the foundation for ECM with records information management

Before your business thinks about buying an enterprise content management system, a deep dive into records information management could be in order. Take it from CIO Laura Fucci.

Before spending the money on an enterprise content management (ECM) system, the enterprise needs to get its house of records in order. At least that is the loud and clear message of CIOs like Laura Fucci, who delayed an ECM implementation for financial reasons, and is happy she did.

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 When Fucci was appointed CIO of Clark County, Nev., four years ago, buying an enterprise content management system was high on her bosses' to-do list.

"But we did not have a countywide records management program or policy or retention in place," Fucci said. "Every department was reading the state laws and doing records retention and destruction the way they felt it needed to be done in their departments."

Fucci, who oversees an IT budget of $41 million, had no "skin in the game" except for buying that enterprise content management system, but she realized that before Clark County could think about ECM, it needed to build a records information management (RIM) program.

That's a tall order. Clark County is Nevada's largest population center, with 2 million residents, and is the 14th most-populated county in the U.S. Its 8,000 square miles include five large cities, as well as a sweep of unincorporated area. The 40 county departments that serve the region enjoy a lot of autonomy.

As one of few top county executives with an enterprise-wide view, Fucci launched a project to set up a records information program. She began by meeting with "key players" to sell the program. Then she pulled together a steering committee representing the county's 20 departments that handled records. The committee included members of the county's legislative and judicial branches. "It's not often we get full participation like that," she said.

Principles of an effective records information management program
Click on the link for a fuller description of ARMA International's eight generally accepted recordkeeping principles:

 

 

  • Accountability: The organization shall assign a senior executive who will oversee a recordkeeping program and ensure program auditability.

  • Integrity: The recordkeeping program shall be constructed so the records and information have a reasonable and suitable guarantee of authenticity and reliability.

  • Protection: The recordkeeping program shall ensure a reasonable level of protection for records and information that are private, confidential, privileged, secret or essential to business continuity.

  • Compliance: The recordkeeping program shall be constructed to comply with applicable laws and other binding authorities, as well as the organization's policies.

  • Availability: The organization shall maintain records in a manner that ensures timely, efficient and accurate retrieval of needed information.

  • Retention: The organization shall maintain its records and information for an appropriate time, taking into account legal, regulatory, fiscal, operational and historical requirements.

  • Disposition: The organization shall provide secure and appropriate disposition for records that are no longer required to be maintained by applicable laws and the organization's policies.

  • Transparency: The processes and activities of an organization's recordkeeping program shall be documented in an understandable manner, and [made] available to all personnel and appropriate interested parties.

 

 As concerns were raised in the steering committee, working groups formed to address them. The committee also hired a records management vendor to work with more than 200 "record liaisons" appointed from each of the departments to identify all of the records categories in the county. "It was an all-inclusive project," Fucci said.

"I was very careful as I went through this project to make sure it was not about buying and implementing technology," Fucci said. "It is very easy for people to get enamored with some technology before they really understand the problem they are trying to fix."

Records world according to GARP

It is not unusual for CIOs to find themselves up against a records information systems in disarray, said Diane Carlisle, the deputy executive director of not-for-profit ARMA International, a professional association of records information managers. And as digital records pervade the organization, CIOs increasingly find themselves being tapped to set the situation straight.

"What this CIO did that was a little different, is that she was aware enough to know what was going on in the business as a whole, to know that the technology needed to fall within a structure of policies, processes, and legal and regulatory requirements," Carlisle said.

Indeed, as it turned out, Fucci's approach is a crucial precursor to implementing an enterprise content management system successfully. According to Cambridge, Mass.-based Forrester Research Inc., more than 80% of ECM systems fail to be deployed because there is dissention in the company about what to do with old records. An organization's legal, business and IT operations all have divergent views of what should be saved and what should be discarded, said Mark Diamond, CEO of Contoural Inc., a consulting firm in Mountain View, Calif. Until this complex issue is settled, there is little hope of an enterprise-wide automated system having any practical value, he said.

But there is a path forward.

Since its inception in 1955, ARMA has developed a set of eight generally accepted recordkeeping principles, or GARP, that inform an effective RIM program. The organization also has developed best practices and standards aimed at dealing with such things as building a retention schedule and dealing with inactive records. And it publishes a model for gauging the maturity level of a RIM program. One of its guides, Records and Information Management for Information Technology Professionals, focuses on key records processes that are relevant to managing information through technology.

The nonprofit Association for Information and Image Management is another resource for records management.

Who should be in charge of a RIM program is an issue that continues to dog many organizations. "What works best and is most desirable for the program is, of course, to have a person with a C-level title, whether it is CIO or COO," ARMA's Carlisle said, adding that government agencies are starting to use the title "information officer".

Take the 'we' approach to RIM

CIOs who find themselves in charge of records information management should "take the 'we' approach," Carlisle says. In addition to the top records management person, a RIM team should include representatives from legal and compliance, because legal holds and e-discovery have become a big part of records management. Operations people from the various business units, who know how records are used to conduct business, should also be on board, according to ARMA principles.

It is very easy for people to get enamored with some technology before they really understand the problem they are trying to fix.
Laura Fucci
CIOClark County, Nevada

 In a concerted effort, Clark County's RIM steering committee and its departmental liaisons categorized records, documented retention schedules, fixed such inconsistencies as fees charged for records, and defined a procedure for discovery holds. The group also added records (such as Environmental Protection Agency air-quality records) to the state archive. In the process, the committee identified records that did not need to be kept, reducing the amount the county spends on storage.

The county did not have the funds to hire a certified ARMA records manager, but it did appoint an internal candidate with records experience, who is now undergoing ARMA training. In retrospect, Fucci wishes that person had been involved from the start of what turned out to be an 18-month effort, she said.

Now, with the recession still in full tilt in Clark County, there is no money for an ECM system. Fucci does not regret her effort, however. On the contrary, "CIOs are in a unique position to take this on, because of that enterprise view," she said.

Let us know what you think about the story; email Linda Tucci, Senior News Writer.

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