Information Governance Group

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“Garbage in, garbage out” – we know that already, right?  Well … what we know about information quality and what we do are not always in sync. Just for kicks, consider information quality through the lens of the industrial quality movement. Looking down from 30,000 feet, the history of industrial quality goes something like this – Medieval Guild craftsmanship, then Industrial Revolution product inspection, and then the post-World War II focus on quality process management.  It sounds arcane, until one remembers…
It lingers on – that vaguely guilty feeling that there’s something sanctionable, even illegal, about routinely destroying business data.  That’s nonsense.  It is well-settled United States law that a company may indeed dispose of business data, if done in good faith, pursuant to a properly established, legally valid data retention schedule, and in the absence of an applicable litigation preservation duty. Even the courts themselves dispose of their data.  Federal courts are required by U.S. law to follow a …
As the information tide relentlessly rises, many organizations simply see an IT problem, to be fixed with a purely IT solution – more storage capacity, more tools, or both.  But merely adding more storage is a reaction, not a strategy.  And adding technology tools without the right governance rules invariably makes things worse, not better. This is not a criticism of your IT team.  Instead, the problem lies in a misunderstanding of the fundamental challenge.  Just as you shouldn’t bring…
The “business case” for information governance often focuses solely on quantifying specific costs for data management and exposures for data security and ediscovery.  Number crunching is of course important, but it misses something bigger, more strategic, and ultimately more crucial to the organization – its brand.  Companies, regardless of industry, are fundamentally in the information business.  It follows that how an organization manages its information assets reveals how the organization manages itself.  And that matters, a…
Having too much data causes problems beyond needless storage costs, workplace inefficiencies, and uncontrolled litigation expenses.  Keeping data without a legal or business reason also exacerbates data security exposures.  To put it bluntly, businesses that tolerate troves of unnecessary data are playing cybersecurity roulette … with even larger caliber ammunition. Surprisingly few U.S. data security laws and standards expressly require that protected data be compliantly disposed of once legal and business-driven retention periods expire.   PCI DSS v3.2.1, Requirement 3.1, provides “[k]eep cardholder data…
Being a CISO is a tough gig.  The perpetual deluge of news items on hack after hack, breach after breach, has finally conveyed that data security is an imperative for all companies, large and small.  But the perception still lingers that the Chief Information Security Officer (or her InfoSec team) will single-handedly prevent breaches at “our” company – and if one should occur, will take care of the response.  For some CISOs, it may feel like High Noon, all over again. This is unfair to the…
Dr. Stephen Covey reminded us that “important” is not the same thing as “urgent.”  Records retention reminds us that important is not the same thing as exciting.  I get it – records retention schedules are boring.  But the fact remains that literally thousands of records retention requirements apply to your organization’s information.  I know, because my firm finds and tracks these laws as part of our decades of retention schedule work for clients across industries.  And your regulators…
In today’s landmark ruling, the Illinois Supreme Court held that private lawsuits seeking statutory damages and injunctions for violation of the Illinois Biometric Information Privacy Act (BIPA) may be pursued by “aggrieved” persons without alleging any actual injury or adverse effect. BIPA, enacted in Illinois back in 2008, was the seminal state statutory privacy law for individuals’ biometric data.  The law protects individuals’ biometric identifiers (a retina or iris scan, voiceprint, or scan of…
“If your clients don’t have a records management system, they may as well take their money out into the parking lot and set it on fire.” – Former U.S. District Court Magistrate Judge John Facciola We all know that ediscovery is expensive, and various research reports have so confirmed. The definitive Rand study, Where the Money Goes: Understanding Litigant Expenditures for Producing Electronic Discovery, found that median costs for collection, processing, and review are $17,507…
Most people have elevated stress during the holiday season — work, travel, family, money, time.  And holiday stress can make people inattentive, tired, frustrated, and willing to take short cuts, especially when it comes to computer and Internet use.  This is when mistakes happen.  It’s when we decide to evade policy by emailing work home or by using the unsecured airport Wi-Fi because our plane is delayed.  It’s also when malicious acts of information theft,…