The management of the electronic data lifecycle shouldn’t be left to chance. It must be precisely managed with clear policies and procedures to govern the data and ensure the data’s security and compliance. When managing electronic data, several phases are apparent — creation or capture, distribution, use and maintenance, storage and retention, as well as disposal, for example. With the world becoming more and more digital, and the amount of electronic information consistently growing, good information governance and management is vital.
Policies and procedures
Information governance consists of the required stack of policies and procedures focused around the management, control, and access of a company’s information assets. These policies and procedures include physical and electronic records; however, it is not limited to these.
Executing an effective way to govern the secure, correct use and access to these assets falls under the remit of information governance and electronic records management. There is a strong drive to digitize physical documents, and countless organizations across numerous sectors have initiated projects to reduce their physical records and move to a digital-only platform where possible.
With the increase in remote working collaboration tools, organizations are producing data in the form of recordings, both video and audio, and these can be transcribed and stored in the organization’s cloud. It’s important to note that the jurisdiction that the organization operates in, and the attributed privacy and compliance responsibilities the organization is required to observe, will impact how the records are appropriately handled. So, the management of these types of records will need to be considered in the governance approach too.
Electronic records management
There is a myriad of policy requirements for proper electronic records management, including:
- Analysis of the organization’s business context and identification of records requirements.
- Overarching policies to govern information assets.
- The generation of and implementation of standards relating to processes for creating records and controls of records as well as good digital storage practices.
- Retention policies on how long this data can be stored.
- Classification policies to classify data for searchability so that the organization can better manage the data.
- Policies relating to documents, records, metadata, databases, physical records, statistics and analytics, records systems, and derived records.
- Policies relating to elements including security, continuity, availability, access rights, metadata structures, retention schedules, audit requirements, content repositories, monitoring, and disaster recovery plans.
Management of electronic records
The management of electronic records constitutes the following:
- Creation and capture
Mapping out where the record is, who has access, and how the record is handled is essential. The authentication, identification, integrity, and presentation of the record mean that its part of the record collection of an organization and will be deemed to form part of the dataset. These records require the lifecycle to be applied, and keeping an electronic register of all records is recommended so that appropriate controls can be applied.
- Maintenance, use, and storage
Electronic records, the data, and information generated must be used responsibly and for the intended purpose. The records must be maintained and be accurate and searchable. The labeling and classification of these records is now a requirement for proper electronic record management. A constant review of the technological controls around the data ensuring its security is key to providing confidentiality, integrity, and availability of the record.
- Transfer
The transfer of the record from one system or one party to another should be kept showing a data flow of where the data was, where the data resides, and the contents of the record. This management of metadata is useful for tracking and managing data in the future and for assuring that data is being handled properly. The transfer system should give a verbose audit facility that can be monitored to ensure reports for the governance of record management. It is possible to automate a lot of this to reduce the onus on already stretched personnel resources.
- Retention and disposal
This is part of the data lifecycle and the management thereof. Organizations tend to keep information for long term use; this is often unsustainable. In some cases, regarding specific regulations, like GDPR, personal data should only be kept for the period for which the data is required and if the organization has consent to do so. Even if the organization is not required to comply with the GDPR, it should implement data management best practices like data retention and data disposal for improved data management.
- Metadata
The metadata should be managed and controlled with the same level of security as the data to which it belongs. This metadata can help in the management of the data and is useful as a historical log of the record transfer and data lifecycle management process.
- Reporting
To be able to provide comprehensive reporting on the electronic records, organizations will require adequate monitoring of the integrity, access control, availability, and confidentiality of the records.
- Additionally — compliance
This could be seen as an added component! However, it is essential for compliance with specific regulations, laws, and requirements. This area should be investigated in detail and mapped out from a compliance perspective to ensure the organization aligns with the needs. If not considered, the organization risks falling foul to potential fines and civil proceedings.
Aspects to consider when implementing a suitable process
- Know where the data is and who has access to it.
- Implement the rule of least privilege to ensure access is limited to the people and systems that require access.
- All third-party access must be governed with the same or higher security than your internal controls for internal staff members.
- Prevent unauthorized access by having the appropriate level of access controls to the electronic records. Controls like file integrity monitoring, comprehensive permissions, and proper backup processes are key to ensure the data is not destroyed or changed in an unauthorized manner.
- Ensure that an audit trail is available. This is evidence that the organization and the people are complying, not just for the audit’s sake, but for the benefit of the organization.
- Ensure the data is disposed of in its entirety. This includes the live, archived data, data that’s been transferred to third parties, and data that is residing on remote devices. A comprehensive destruction policy is a good practice, and it’s vital to ensure that it’s appropriately formulated to reduce risk.
- The ability to immediately locate and manage the electronic record is required. Management may include being able to lock access to, destruct, delete, change permissions, archive, move, and transfer the electronic record.
Data lifecycle management is a discipline organization must heed
Since digital records are a primary part of everyday business, and organizations are continuously producing more and more records, organizations must get this right.
Not only does the appropriate management of electronic records ensure a reliable audit trail of data creation, capture, management, and accessibility, but it’s essential for regulatory compliance too. A gap analysis is often an excellent place to start, to help an organization get on track with regards to developing a roadmap to remediating the gaps to implement effective information governance and records management.
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