Vital Records Management: Don't Get Distracted by SOX
Carlisle points out that not all records have the same value to a firm. To be distinguished as “vital,” a record must contain information that is essential to the organization in the event of a disaster. Also records regarding certain key business transactions need to be saved to legal and other reasons.
Best practice leaders, according to Carlisle, have long had effective ways of keeping their data and records, both electronic and paper-based, safe. There are always businesses in all industries relying on paper records kept piled away in boxes or in poorly organized filing cabinets, and, in the case of electronic records, on tape drives which aren’t easily searched.
Right now businesses are functioning in the “Sarbanes-Oxley” era where there will probably be an over-reaction and a “micromanagement effect.” There will be a higher standard of records maintenance given the new regulatory climate, particularly with Sarbanes-Oxley, which is being interpreted broadly regarding records protection. Companies will need processes and controls in place to mitigate compliance and legal risks.
Records management, as a discipline, tends to pertain to infrastructure issues like the durability of the medium, the ease of retrieval, or when and how to destroy older records that no longer have value. A vital records approach, which Carlisle advocates, takes that sort of organizational thinking one step further and encompasses the administrative aspect of records management.
“These records have value for the following reasons” is the premise of the vital records approach to records management. This allows records to be organized and prioritized. Firms can also develop methods for searching records, allowing the records to function more like a library for easy legal research, say, and less like a general repository that requires a lot of manual searching. When you make records searchable, you make them easier to interact with and, in the larger sense, easier to validate. You can say “I stand behind these financial records” because you can find all the supporting line item detail easily and quickly.
“I would argue that the only reasonable way to begin making decisions [about data and records management] is to know what you have overall, in terms of data, and to keep it all in a highly organized way—like a library—as a necessary first step.