A Four Step Methodology for Defensible Disposition

Does defensible disposition intimidate you? Follow these four steps to banish your fears.

Defensible disposition primarily consists of developing and then executing four pieces:

1. The Defensible Disposition Policy
2. The Technology Plan
3. The Assessment Plan
4. The Disposition Plan

1. Develop your Defensible Disposition Policy

The first step is to develop your Defensible Disposition Policy. This is the design specification that states very clearly the objectives that your methodology will fulfill. You should be able to defend your actions by pointing at your policy for defensible disposition, which shows what you intend to do and then showing that you are following it.

Here’s how to develop the Policy:

First, recognize that you must satisfy 4 demands, 3 of which concern retention:

1. You have Regulatory retention requirements
2. You have Hold retention requirements
3. You have Business retention requirements
4. And then you must address the negative or positive Cost impact of anything you do.

Second, note that everything you do has an impact, whether you do nothing at all or take action aggressively. The impacts result from 1) what you do, and 2) the effects of what you do. In the defensible disposition scenario there are two relevant types of activities. You can sort your files (or assess them — same thing). And you can dispose of your files. Disposition here means the two extremes in the range from purge immediately to keep forever, with many points between.

You can now state your mission in two equivalent ways:

• A. Your mission is to assess and dispose of your organization’s information in order to satisfy your retention demands (1-3) while also minimizing bad cost impact (4)
• B. Your mission is to assess and dispose of your organization’s information in order to maximize good cost impact (4) while also satisfying your retention requirements (1-3)

The two mission statements mean the exact same thing depending on how you specify what the terms mean, but lawyers and records managers like version A more than B because it focuses attention on satisfying retention demands. IT folks like version B more than A because it focuses attention on reducing costs and increasing savings.

Note that your mission statement still needs to be a lot more specific. You need to determine the extent of your regulatory, hold and business retention requirements. (To pick just one example: is your company clear on what’s a record versus a high value non-record versus a low value non-record?) You also need to determine what “satisfy your retention demands” really means for you. And you need to clarify what your organization means by bad or good cost impacts. You don’t have to write down specific dollar amounts but you have to be pretty clear about this e.g. when the costs of storage or a deeper level of document classification are burdensome.

The good news is that you don’t need to be perfect — you don’t have to perfectly satisfy your retention demands. You do need to use the Principle of Reasonableness and act in Good Faith.

So clarify the vague parts of the mission statement and you have your Defensible Disposition Policy. To review, the Policy is the design specification that lays out very clearly the objectives that your methodology will fulfill. The next four pieces of your methodology succeed or fail solely by how well they together fulfill the Policy.

2. Develop your Technology Plan

Using technology for the heavy lifting in the file assessing and disposing processes is absolutely necessary. But there are two sources of complexity in finding and using the right tools that make it a challenge:

First, the “analysis, classification and disposition” market is young and a mess.The relevant vendors and products come from file analytics, content analytics, content classification, ECM, e-Discovery, search, document capture (!), data loss prevention and storage management. The delivery channels include products and modules you install at your site, hosted solutions, and service providers who may use a variety of products. The variety of vendors includes IBM, HP/Autonomy, EMC Kazeon, SAS, Kofax, Equivio, Rational Retention, StoredIQ, Recommind, Index Engines, and many others.

I just did an analysis of classification and archiving solutions for a client that covered 41 tools in 5 different technology categories. Most of these vendors have a sweet spot or spots where they can succeed but it’s not easy to locate that spot and successfully match it up with your needs. And that leads to the second complexity.

 

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Source : cmswire[dot]com