Categorize Transitory DataBy Anne Kershaw | Posted 2012-04-16 Print
Eighty percent of ostensibly “active” files and folders have not been accessed for three to five years, resulting in unnecessary IT expenditures. Yet, most of the costs associated with unnecessary data hoarding are hidden.
Categorize Transitory Data
The next step is to categorize the transitory electronic data that is not currently on records retention schedules. This involves different processes for different types of data. File shares should be reviewed to determine the dates of last use of the folders and files.
Physical data containers, such as drives, servers, tapes and other media, are inventoried, and reasonable efforts made to determine their source. If the data is required for business, regulatory or legal hold purposes, it should be placed on retention schedules; if not, it can be disposed of.
For maximum protection, an insured and experienced expert should draft an opinion letter explaining the process and directing the final disposition of unneeded data. If there is ever a challenge to the disposition of the data, the corporation can point to this process and its associated documentation as evidence of their good-faith effort to comply with its recordkeeping obligations.
Such e-housecleaning efforts have a tremendous ROI. Some clients have been able to take thousands of backup tapes off hold, and others have freed up significant percentages of their available file share space—all of this in addition to avoiding discovery and data breach costs.
It is important to be aware of, and prepared for, the executive or business unit that insists on holding onto unused data, claiming that they may someday need to access that data. The most effective way of dealing with just-in-case hoarders is to let the them keep their data, but with the understanding that they are now in fact the "owner" of the data with all the incidents of ownership.
That means they will be allocated all the costs of ownership, including data storage, backup and data breach responsibility, and all legal costs associated with the review and production of the data if it is ever swept into litigation discovery or governmental investigations. Once they understand the full costs associated with owning the data, executives or business units inevitably opt to dispose of unused and unneeded data.
Anne Kershaw in an attorney and legacy data management consultant who has guided many corporations through electronic records housecleaning efforts. She can be contacted at firstname.lastname@example.org.
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