Information Life Cycle Management: Insights from Base Camp
Here's a good chance you've never been asked this question. However, consider that as a CIO of a large pharmaceutical corporation - one with a global footprint - you're moving as fast as you can to address the fact that your board of directors:
- Is concerned about the exposure of its American operations to compliance obligations emerging from the Sarbanes-Oxley Act (given its requirement that SEC registrants retain all relevant documents for up to seven years after an audit);
- Is aware that the Act isn't specific about what types of documentation it considers relevant; and
- Given the possibility that the company may need to retrieve certain documents during an audit, has just set aside $2.5 million to fund your development of the document retention policies and technologies required to meet these obligations.
Additionally, you have a two-month deadline. Your CEO is talking enthusiastically about information life cycle management (ILM) - which is fine - but it means you have some expectations to manage.
Today, many vendors and consultants would support your CEO's inclination to believe that ILM is the best way of answering the board's needs. At some level - in the same manner, for example, that many climbers aspire to ascend Switzerland's Eigerwand - it is. However, while software and hardware tools exist to manage key segments and workflows that govern the entire information life cycle (including creation, storing, editing, approving, archiving and disposition), no single vendor solution - and no aggregation of different vendor solutions - is available today to deliver the full promise of a comprehensive ILM solution. A one-size-fits-all, shrink-wrapped ILM solution simply doesn't exist.
To really appreciate the draw and the drawback of ILM - for both data management professionals and business-unit executives - you must understand that while the real value of ILM resides at the intersection between content management and storage technology, ILM's Achilles' heel, at least today, is in interoperability - and the risks inherent in prematurely attempting to holistically integrate ILM on an enterprise scale.
Your gut instincts aren't wrong: at a basic level, ILM is just another name for what your data management team has been working toward for years. However, if it takes a fancy moniker to make common sense more broadly compelling to a newly attentive executive audience, run that one out as far as you can. You must admit, the potential of ILM is exciting. After all, if it reaches maturity, ILM will include fully scalable systems for structured and unstructured content generation, standardized across the enterprise and feeding retention servers performing long-term storage and disposition services. Additionally, it's difficult to argue with the payoffs: improved compliance, risk reduction and optimization of storage cost structures.
Does the Approach Route Need Another Look?
Let's revisit this scenario for a moment. Clearly, the board is focused on Sarbanes-Oxley. However, from the perspective of how best to begin implementing a process-driven ILM solution, particularly with respect to optimizing return on investment, a different point of entry might prove more promising. For example, the information retention requirements for Basel II or the EU's Data Protection Directive may be more stringent. In effect, maybe your ILM initiative for Sarbanes-Oxley compliance should be driven by what your call center in Zurich requires.
Base Camp Preparations: Stay Realistic
Not all ascents go to the summit: know your requirements. Do you really need a full-featured automated ILM workflow solution? Applying a new technology layer over an immature data management infrastructure isn't the best idea. Does this document really require six approval layers or can we whittle them down? Is there a way we can avoid a technology fix with a simplification of processes? Don't overbuy.
Pick a route you can climb: stay focused on realistic objectives. You decide that compliance with Sarbanes-Oxley is the objective, but the EU's Data Protection Directive is both the standard and the point of entry. Keep the team focused. Tie the investment to quantifiable results. Manage project scope with fiscal discipline.
Achievement depends on understanding the business impacts. Perhaps your ILM solution is intended to replace the time it takes a manager to cross the hall and manually deliver a report to a colleague. Automation drives efficiency, right? Maybe, but what other information are they exchanging? What's the value of that daily rapport on the rest of your productivity? A commitment to ILM requires aggressive change. Does your team understand the business and communication impact?
"Summitting" takes many skills: don't underestimate what's required. Strapping on crampons is one thing - manning belay in an oxygen-weak environment at 15,000 feet is entirely different. Think about it. Planning and implementing an ILM solution requires integrating expertise in understanding your business; data management and data quality; governance, risk and regulatory compliance; security and privacy; and business continuity planning. Leverage in-house skills. Import expertise if needed. Get strategy right. Secure executive buy-in, and consider implementing a pilot program - it gives you a chance to demonstrate results, test assumptions, calibrate return expectations and train internal staff.
ILM: don't be fooled by the name. It's easy to believe that the "I" in ILM stands for "information," but it doesn't. It stands for "Is-data-quality-one-of-your-highest-priorities?" The best component of any ILM solution is only as good as the quality of the data underlying it. While you're still in base camp, set up a governance structure that will anchor the accountability, metrics, ownership, roles and rules that will define whether or not the ILM solution gains any altitude.
Get There First
One last thing. The $2.5 million issue isn't whether you can answer that question about Zurich's requirements. Far more important is whether your team has the experience to ask that question themselves - well before the board even thinks of it.
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