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Records Management Program <[log in to unmask]>
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From:
Lisa O'Donnell <[log in to unmask]>
Date:
Thu, 18 Aug 2016 16:21:48 -0400
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Records Management Program <[log in to unmask]>
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Given the incredible volume of digital data, it is impossible to really
analyze unstructured data for accurate classification per most records
retention schedules I've seen.

Does anyone have a reasonable approach to the following dilemma?

Horn #1  Cherry-picking
Ideally, one wants to retain only that content that constitutes an official
record, and only for as long as the RRS specifies.  Even with
auto-classification tools, classifying the content by record type is rarely
"auto" and usually arduous, time-consuming, and iterative. Even if the only
practical action is to identify and delete duplicate data, the context in
which the duplicates exists can be useful information.

Horn #2  Caching
There is also a case to be made that taking a snapshot of the data "as-is"
is valuable to buy time for the business to make those qualitative
judgements, and also as protection against future disputes. Companies
have an obligation to preserve data if there is an known cause or
reasonable expectation of litigation.  Since acquisitions seem always to
generate some sort of legal action-whether from disgruntled employees, or
IP challenges or SEC concerns, etc., that could constitute a reasonable
expectation.

Conventional wisdom is that content unnecessarily saved is more likely to
be damaging to the company interests than content inadvertently destroyed.
What, then, is a reasonable confidence interval after which we are
sufficiently sure that all relevant data has been appropriately classified
and distributed to the right owners and the right platforms and/or has been
put on a specific hold responsive to a particular case or investigation?

I posit that if your RRS has a schedule for M&A materials (e.g. 10Y after
Close Date), you could apply this broadly to the whole snapshot, and
defensibly destroy the whole collection at the end of the retention
period.  However, one would also have to be able to demonstrate due
diligence in your data integration practices to ensure that both active and
archival content had been adequately managed.

What say you?  Could such an approach be defensible?  Does anyone have any
experience with such an approach, positive or negative?  What is a
reasonable retention time for an as-is snapshot of data acquired?

Appreciate your opinions and insights.
Thank you.

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