I work for a 150+ year old life insurance company that is embarking on a major modernization effort, which includes converting 8 legacy mainframe policy administration platforms into two administration platforms. Needless to say, there is a significant amount of data scrubbing that has to occur, a portion of which will be outsourced.

We've convinced the project sponsors that now is a good time to image the policy application files, (a mere 750,000) thus allowing the data cleanup vendors easy access the files for data validation. The project sponsors are on board, but Legal and Compliance have expressed concerns about maintaining the security of the medical documents once they been imaged. Although we have been imaging policy change documents since 2001, any medical documentation, including the initial application and underwriting reviews, remain in paper format.

I'm looking for guidance from RMs in other life insurance companies or the health industry on how they deal with the security issues related to imaging medical documents or restricted files. We define restricted files as those belonging to home office employees or producers, high net worth clients, or those with protected medical conditions.

Even though this initiative is focused on imaging existing files, I'm looking to the future as well. A sub-component of the modernization effort is to develop straight through processing for handling new insurance applications - where possible, everything will be received and maintained electronically. We're currently use FileNet and will be migrating to FileNet's P8 ECM environment over the next few years.

I'm not in favor of imaging only the non-medical documents because "I hate paper." - Steve, you taught me well!

Any advice you have on how to maintain the security of these documents to satisfy Legal & Compliance will be greatly appreciated. Since our Compliance team is extremely risk-averse, examples of how this is handled in other companies usually helps us sell our position.



Mary Frances Janicik, CRM


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