A Change for Business

FST speaks with Mike Sullivan about information governance and the importance of shifting from a reactive to a proactive strategy.

FST. How should technology contribute to a financial institution’s information governance strategy?  
MS. Financial institutions need to comply with a variety of regulations that deal with the storage, retention and supervision of electronic content. Fortunately, the technology exists to automate and optimize these activities.

The best systems will intelligently archive only the correct information on compliant storage according to predefined policies. A centralized policy management system is a must as they make these systems easy to audit and administer.

For example, tools exist to prevent and detect any unauthorized or inappropriate communications even before they go out. Autonomy’s software has the ability to discern meaning from the content and automatically flag inappropriate communications that would violate corporate policy.

FST. You’ve been in the business a long time. Are you starting to see a shift from a reactive to a proactive approach to these business issues? 
MS. The benefits of a proactive approach are too compelling now for companies to ignore. And the December 2006 amendments to the Federal Rules of Civil Procedure (FRCP) essentially require a proactive approach.

The real benefits of a proactive approach come in the form of massive cost savings on storage and electronic discovery, and substantial risk reduction. In addition, Legal Holds are easily managed and audit trails exist for the entire process.

FST. How does Legal Hold play into an Information Governance strategy?
MS. Financial institutions already have programs that manage records retention in order to comply with various regulations. However, these systems are often not equipped to handle retention of information that’s subject to a Legal Hold. Ultimately, a Legal Hold should just be a new policy that’s deployed and enforced utilizing the same policy management systems. Having multiple systems managing retention of information introduces extra cost and a great risk that information will be mismanaged due to conflicting policies.

Legal Hold is a bit more complicated because it can apply to any information in an enterprise, not just corporate records. This information needs to be managed where it sits regardless of the format, language or security applied. In the past, companies relied on email notifications and spreadsheets to track requests that go out to custodians asking them to refrain from deleting certain information. Most experts agree that this approach is no longer sufficient.

Advanced software is now available to manage notifications, enforce legal holds in place, and automatically collect information if necessary. And all of this can be centrally managed within a single interface.

FST.What are some of the considerations that a financial institution should take into account when evaluating vendor services?
MS. I think it’s critical to avoid point solutions and choose a vendor that can provide a single, unified platform for Information Governance and Discovery management. There are tremendous advantages to using a single engine for searching and managing information throughout the enterprise. Recently, there is a clear trend amongst the largest and most successful financial institutions to standardize on a single platform.

In addition to advanced technology features, performance, scalability and security should be key considerations. Consider whether a vendor will offer their solutions on a hosted as well as a license basis for flexibility.

Finally, it’s important to choose a vendor that is trusted and has proven success within the financial industry.

FST.What does Autonomy offer that is unique?
MS. Autonomy offers a single comprehensive platform for Information Governance and Discovery Management. The platform is based on our IDOL engine, which is used by more than 17,000 customers worldwide. The engine is language independent and can handle virtually any data type with connectors to over 400 repositories. With 6,000 servers across five world-class data centers, processing more than one billion documents a month for global organizations, Autonomy provides industry-leading solutions for the largest and most complex legal and regulatory matters all on a single, powerful platform.

Mike Sullivan is SVP of Operations and Services at Autonomy and manages all aspects of the worldwide hosting and data processing business. Sullivan was a pioneer in the electronic discovery industry and most recently, served as Senior VP of Operations at ZANTAZ.