The principles in practice in a new RIM program.

AuthorGable, Julie
PositionRecords and information management

A small financial services firm and an oil and gas exploration company were both facing challenges with the need for new records management programs. As we will see, their similarities stem from the productivity and operational aspects of managing records to support business processes--the basic reason that records exist. What differs is how knowledge of the Principles and the IMM influenced their respective approaches to establishing a new records and information management (RIM) program, particularly the crucial decisions of where to begin and how to continue.

Case Study 1: Small Investment Advisory Firm Wants Document Management System

The Arbor firm offers investment services to individuals. It is regulated by the Securities and Exchange Commission, the Dodd-Frank Act, and the usual blend of state and local laws. It must comply with specific guidelines regarding its records.

The firm opened less than 10 years ago, and as a small business it strives to use technology for a competitive advantage. Many client account records begin as paper documents with original signatures, but they become images once certain business processes are complete. The firm does not have standard file naming conventions, and most client records are scanned within the business process to a shared drive, sometimes more than once in the course of completing their workflow. Evidence of trading activities and various reports exist only as electronic records.

The firm has a compliance officer and has documented its policies and procedures for many of its regulatory requirements, including information privacy and security. It has an executive committee that includes the compliance officer, the CEO, and the CFO, with legal advice provided by a third-party firm.

Arbor has never destroyed anything, believing it is better to have proof of what was done than to be unable to produce a record. During a routine audit, however, it became apparent that multiple copies of the same documents existed under different names on various shared drives, making it difficult to identify the re cord copy of any document that an auditor requested. Searching was also a challenge because identical documents had different descriptive information on various spreadsheets. To ensure that it never has to face another audit that resembles a scavenger hunt, Arbor wants to implement a document management system for all of its records. Arbor recognizes that it needs help with records classification and standardized metadata. The question is, where does it start?

The Principles to the Rescue

Even though the Principles are arranged as a list, and it is tempting to move down them item by item like stepping stones, they are actually more like a starburst (see Figure 1). Some principles have a distinct regulatory flavor--for example, the...

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