Electronic Record Keeping Principles October 25, 2011
Electronic Record Keeping Principles Agenda: Project Background Frank Duffy - Deloitte Project Update: Legal Principles and Record Keeping Question & Answer The Investment Funds Institute of Canada 2
Electronic Record Keeping Principles History: IFIC Document Record Retention and Destruction Guideline (Oct 2010) Current project: Electronic Record Keeping Project( 2011-2012): Phase 1 - The Acceptability and Support for Electronic Records Phase 2- Electronic Signatures The Investment Funds Institute of Canada 3
Frank Duffy Senior Manager Enterprise Risk Deloitte Electronic Records Management
Electronic Records Management In today s business climate, how well you manage corporate records can contribute to your company s bottom line. At Bank of America, we view proper records management as a quintessential contributor to risk mitigation, expense reduction, organic growth and brand loyalty. Jay Myers, Senior Vice President Bank of America Source: ARMA The Investment Funds Institute of Canada 5
Imaging Records The imaging of a record can occur at any point in the lifecycle of the record. This may impact the approach to imaging selected. Document images may be created at the point of service or may be received direct from customers Paper or microfilm records may be converted to images to reduce costs and improve access Current paper records may be imaged to enable automation of business processes Electronic data sharing is driven by the need for timely availability, secure access and sustainability Electronic records may be converted to secure, sustainable formats for long term preservation Examples of decisions that may change subject to the record s lifecycle: In-house or outsourced capabilities Batch process or on-demand Centralized or decentralized services Technical specifications, such as: o File formats (TIFF, PDF, Grayscale) o Resolution o Colour resolution / bit depth o Compression The Investment Funds Institute of Canada 6
Imaging Records Case Study U.S. state vital statistics unit housed nearly 46 million vital records dating back to the 19th century, and many still in paper form. Almost 750,000 documents are registered with the department annually, and citizens request more than 330,000 searches each year. As the department imaged vital records, the following lessons were learned: Data transfer should be carefully planned A custom data transfer tool had to be created to solve the technically difficult task of automatically moving a massive number of documents from the quality assurance stage to the document repository. Leverage opportunities for business process redesign Directly accessing and printing from a document repository made vital records available to qualified citizens more quickly and securely. It also let more staff members process orders, so document requests can be fulfilled faster. Electronic conversion can drive automation Changes in the process for inputting documents into the electronic system dramatically cut processing time in half. Enhanced document security can be tied to workflow Documents are now locked down upon ingestion into the new system, allowing only authorized users to view them during the quality assurance process. Once approved, the documents are released for wider access. There are now more than 14.3 million electronic records - covering 50 years - available for state use. That number will grow to approximately 34 million when the project is complete. Source: https://www.deloitte.com/view/en_us/us/insights/browse-by-content-type/case-studies/a592bc198553c210vgnvcm2000001b56f00arcrd.htm The Investment Funds Institute of Canada 7
Common Imaging Misconceptions Imaging of paper records is an operational decision. Paper is as good, if not better, than electronic. Paper should be retained in case of litigation or investigation. All paper records can and should be imaged. Once imaged, all paper copies should be destroyed. Electronic record systems and processes can be certified. The Investment Funds Institute of Canada 8
A Spectrum of Options Do nothing and retain paper as the master record Convert records to drive operational gains Convert records to address specific areas of information risk (security, privacy, regulatory compliance, etc.) Implement and demonstrate effectiveness of an electronic records solution o o o Capability maturity assessments of RM program Business alignment Policy and governance Organization Processes and practices Enabling technology Integrate records management into internal audit processes Seek a third party assurance report of records management controls (s.5970/sas70) The Investment Funds Institute of Canada 9
Business Value A Balancing Act of Risk and Value Imaging records has led to a growing awareness of information risks that should be taken into account, such as: o o o o Retention and Long Term Preservation Privacy and Confidentiality Data Quality and Analytics Data Governance and Performance The business value to be realized by imaging records should exceed the cost of the imaging process. By understanding the information risk and business value of a given set of records, strategic decisions can be made on investment. 5 0 Low Risk High Value Knowledge Management Asset Management Low Risk Low Value Communications IT Management Project Management Legal Administration Governance High Risk High Value Human Resource Management High Risk Low Value 0 Information Risk 5 Illustrative The Investment Funds Institute of Canada 10
To Learn More Leading practices in Canada include: o CGSB standards (72.11, 72.34) o Sedona Canada Principles (www.thesedonaconference.org) Canada follows international records management principles closely: o ARMA & AIIM publications (TR48-2006, 8-2005, 9-2004, etc.) o ISO standards (15489, 15801, 13028, 18492, 19005, etc.) o Record system requirements DoD-STD 5015.2 and MOREQ2 Examples of other sources of guidance: o Ontario Bar Association; E-Discovery guidelines (www.oba.org) o National Archives: o Canada: www.collectionscanada.gc.ca o US: www.archives.gov/records-mgmt/initiatives/sustainable-faq.html The Investment Funds Institute of Canada 11
Project Update Legal Principles & Record Keeping The Investment Funds Institute of Canada 12
Legal Principles & Record Keeping Applying RM theory to Financial Services Legal Considerations Records Management Program Record Definitions & Metadata Technology Management Context for Financial Services The Investment Funds Institute of Canada 13
Legal Considerations Legal Considerations Electronic Commerce Acts Evidence Acts and Cases Rules of Civil Procedure Industry guidance (Sedona) Financial Services Context Ongoing updates The Investment Funds Institute of Canada 14
Records Management Program Common Business Controls High level customer service Quality Assurance Programs Time sensitive processes Training programs Can be leveraged for an effective Records Management Program The Investment Funds Institute of Canada 15
Record Definitions & Metadata Record Definitions & Metadata Paper Workflow & Imaging Solutions Fax Server Call Centre Voice & Logging Metadata logs transitions Intranet & Internet Portals Mobile applications Structured Databases The Investment Funds Institute of Canada 16
Technology Management Legal Considerations Technology Management Records Management Program requirements Record Definitions & Metadata The Investment Funds Institute of Canada 17
Recordkeeping & Legal Principles Applying RM theory to Financial Services Legal Considerations Rules now reference RM theory Integrity test key Record Definitions & Metadata Medium transition capture Captures source & key info Records Management Program Focus on RM Principles Good RM=Good Business Technology Management RM concepts built into design Consider lifecyle principles Context for Financial Services Use principles to deliver solutions relevant to risk The Investment Funds Institute of Canada 18
Electronic Record Keeping Principles Q & A The Investment Funds Institute of Canada 19