Don’t Forget the Objective The Importance of Records Management Goals

1. Corporate Administration Don’t Forget the ObjectiveThe Importance of Records Management Goals Marcel A. Bryar Vice President and Deputy General Counsel November 12, 2008

2. Why emphasize goals? Follow the Powell Doctrine The Risk of a Quagmire is Real How to Think about your Goals Think Broad But Stay Focused Potential Goals Get Buy-Off Don’t Put on a Straightjacket Questions? Agenda

3. Launching a records management program is dangerous Every enterprise has many records and much information to manage You can easily get bogged down trying to get your arms around that mass Before diving in, therefore, you want to ask yourself, and think hard about, why The answer to that question will help you decide which records and what information you want to manage Rather than trying to boil the ocean, you can focus your efforts and have a better chance of success Why emphasize goals?

4. "We owe it to the men and women who go in harm's way to make sure that … [we have clear] purposes." "We must not, for example, send military forces into a crisis with an unclear mission they cannot accomplish …” Powell, 1992 Records management is not war, but it shares some key features with war It’s complex, requiring you to get many players to perform a multitude of individual tasks in a manner that achieves a common goal And, as in war, you’re always in danger of mission creep Follow the Powell Doctrine

5. ARMA’s 2008 survey show a disconnect between results and effort 74% of respondents have policies for electronic documents, 59% for e-mail (which is low to begin with) But 72% don’t think they have e-mail management under control 68% worry about e-discovery The Risk of a Quagmire is Real

6. The right question to ask is “why,” not “what” Every compliance program requires you to ask and answer 3 questions Why – Why am I doing this? The answer to this question will give you your goals What – What am I going to do to achieve my goals? The answer to this question will tell you what you want people to do, i.e., it will tell you your policies How – How am I going make sure people follow my policies? The answer to this question will tell you how to implement your policies Before launching any compliance program, you want to make sure you know why it’s necessary If you start by wondering what you’re going to do, you’re asking the wrong question How to Think about your Goals

7. Records management is an information management problem The volume of paper and electronic data you have obviously is relevant to your business But your most important goals will relate to the information on those records Integrate your program with your data management program Or create a data management program if you don’t already have one – and then merge the two Don’t limit yourself to compliance goals – records management can serve business goals as well Storage, of course, costs money More important, making information accessible increases productivity Think Broad

8. Set realistic goals Even if it would be a good thing, ask yourself if you can do it Even if you can do it, ask yourself if the investment will be worth it You may discover your success depends on other programs Shuttle back and forth between implementation requirements and goal setting Talk with regulators to get clarity about their requirements Remember to keep asking yourself “Why do I care?” But Stay Focused

9. A few examples Managing litigation and regulatory holds Complying with retention requirements Making information available Minimizing storage costs Destroying records that you don’t need to run the business The first three are retention goals; the last two are risk and cost mitigation goals Identifying these goals helps ensure that you can manage the obvious tension between them Failing to identify them can cause grave error – see what happened to Arthur Andersen Potential Goals

10. Don’t develop your goals in a vacuum This is not an academic exercise Your goals will drive every decision you make thereafter Review the goals with executive management and get their sign-off Executive support is critical for success – you’re going to be making lots of demands on the business and you need management to back you up Being able to relate specific elements of your program back to approved goals will help sell your implementation plans Review the program with your regulator Whatever you do, to the extent you can, don’t lock yourself in Get Buy-Off

11. Be ready to re-assess your goals when you develop your implementation plans and go to implement When you sit down to think about implementation, or when you’re monitoring and evaluating your program, be open to rethinking your goals You may discover that you don’t have the resources or time to achieve your goals You may discover that no one can reasonably achieve those goals You may need to prioritize Tackle retention first, to avoid losing necessary records Then go after cost and risk mitigation Don’t Put on a Straightjacket

12. Q&A Questions?