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Q: How are you seeing the role of records management, content management, knowledge management and document management changing as electronic communications evolves to play an increasingly important role in business?
A: I've always viewed these areas as somewhat inter-related and, in fact, they are all embraced as part of an enterprise content management (ECM) continuum of shared information throughout the enterprise, with records management providing the compliance role, content management covering the publishing role, document management providing the repository and library services aspects, and the practice of knowledge management providing the ability to access all relevant information when needed. I do believe that a unified repository or at least a well-connected set of information repositories are part and parcel of the enterprise content management infrastructure and electronic communications provide a dual role of enabling process while at the same time becoming the artifact in all these related areas.
E-mail has been initially viewed as an efficient way to pass information from one person to another and many organizations have attempted to harness e-mails to provide a window into corporate memory and help to effectively manage projects (i.e. Lotus Notes). But it has been increasingly been put in the role of a document that can be used as a reference or as evidence in an investigation, making the need to save these communications in a more rigorous fashion than just creating a serious of file folders on one's Outlook mailbox.
Instant messages take this one step further by "documenting" conversations - substantial business conversations. These in turn have been subject to regulatory scrutiny as well. Text messages and other forms of electronic communications are following suit and should be viewed as ECM objects as well. This will have a tremendous impact on storage utilization and increase the sophistication of the definition of a content, document, record and/or knowledge repository.
Q: What are the biggest issues faced by enterprise content management (ECM) professionals in dealing with electronic communications including email and IM?
A: The most intimidating issue is volume. E-mail and IM volume is escalating in business use at a dramatic rate and that will only get higher as the years progress. Unfortunately, we all know that a good portion of e-mail is not worth keeping for long term retrieval such as spam, and advertising but there is plenty of relevant e-mail that must be saved for any number of reasons. Eliminating duplicate e-mails within a shared and regulated repository is one way to de-escalate the rate of storage resources that organizations will need to store this information.
How to get consistent compliance with respect to regulatory policy is another big issue. Even when educated to corporate policy, if the effort to file an e-mail or instant message takes more than 5 seconds of thought for a user, more than likely that activity will not take place. It tends to be a matter of priority and just like all the filing that you might have piled up on a corner of your desk, office desktops are loaded with e-mails and IMs that need to be filed
Even if you address these issues and have a repository or set of repositories that can serve all your content, records, document and knowledge management needs (and that's a VERY BIG IF in this market) and achieve compliance, you still have to have a reasonable fast mechanism for retrieving this information across this repository. And, in most business environments the potential for mergers and acquisitions is quite high these days. Rationalizing multiple repositories can be a significant challenge.
Finally, because these electronic communications are not just ECM artifacts but also part of the business process those processes also need to be monitored in a more rigorous fashion so that the process components of some regulations such as Sarbanes-Oxley are complied with. This goes beyond managing repositories into the realm of business process management and workflow auditing - a somewhat less mature technology territory.
Q: Do you see ECM professionals playing a significant role in setting corporate compliance policy for electronic messaging?
A: I see ECM professionals playing a role that should be no less or no more significant than records managers, compliance officers, legal council, e-mail and electronic communications administrators. They should be heavily involved in the discussion but not necessarily be the ones completely steering the direction. They should be helping to set reasonable expectations as to what can realistically be accomplished with ECM technologies and what cannot so that policies are not created that are inherently impossible to implement.
Q: Has recent focus on industry regulations for electronic communications changed the nature of the role records & information management must play in an organization? How?
A: I don't personally see the role as having changed but I do see the role as being much more visible than it has in recent years. Many records managers have been trying to educate their organizations on the need to maintain appropriate records repositories for electronic documents (including e-mails) for quite some time. The challenge was nobody really wanted to deal with the issue if they didn't have to - compliance cost money and time. The industry regulations have changed that. Records and information management professionals are the "go-to" guys for guidance on implementing and automating for compliance and they are now deluged with responsibility, usually with limited resources and even less funding.
Q: Who do you think should be ultimately accountable for compliance with electronic communications policy and implementation?
A: It's really not what I think that counts these days. Some regulations make it abundantly clear the at the CEO and President of the company are ultimately responsible for compliance of all aspects of these regulations and that includes electronic communications policy and implementation. We've just seen evidence of this in the Boeing incident. If accountability does not start at the top of the organization, there is very little incentive for employees to feel that their "small" indiscretion or violation of the rules will be considered a problem. It sends a strong message that if the Chairman is just as subject to the policy as everyone else then everyone else will be dealt with just as severely. Of course, compliance should be monitored not by the Chairman or President but by designated staff within the organization. But this function should be taken very seriously and should be reporting any issues to senior management on a regular basis so that no one is blindsided by renegade staff activities.
Q: How can businesses minimize risk in an evolving regulatory and legal environment?
A: Educate, evaluate and enforce.
Educate staff and senior management on why compliance is important, what the rules of engagement are and what steps are required to be taken by staff members to be compliant.
Evaluate and benchmark the organization's efforts to comply with regulations and monitor areas that need improvement.
Enforce policies consistently and appropriately.
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