CHAPTER 1

The Onslaught of Big Data and the Information Governance Imperative

The value of information in business is rising, and business leaders are more and more viewing the ability to govern, manage, and harvest information as critical to success. Raw data is now being increasingly viewed as an asset that can be leveraged, just like financial or human capital.1 Some have called this new age of “Big Data” the “industrial revolution of data.”

According to the research group Gartner, Inc., Big Data is defined as “high-volume, high-velocity and high-variety information assets that demand cost-effective, innovative forms of information processing for enhanced insight and decision making.”2 A practical definition should also include the idea that the amount of data—both structured (in databases) and unstructured (e.g., e-mail, scanned documents) is so massive that it cannot be processed using today's database tools and analytic software techniques.3

In today's information overload era of Big Data—characterized by massive growth in business data volumes and velocity—the ability to distill key insights from enormous amounts of data is a major business differentiator and source of sustainable competitive advantage. In fact, a recent report by the World Economic Forum stated that data is a new asset class and personal data is “the new oil.”4 And we are generating more than we can manage effectively with current methods and tools.

The Big Data numbers are overwhelming: Estimates and projections vary, but it has been stated that 90 percent of the data existing worldwide today was created in the last two years5 and that every two days more information is generated than was from the dawn of civilization until 2003.6 This trend will continue: The global market for Big Data technology and services is projected to grow at a compound annual rate of 27 percent through 2017, about six times faster than the general information and communications technology (ICT) market.7

Many more comparisons and statistics are available, and all demonstrate the incredible and continued growth of data.

Certainly, there are new and emerging opportunities arising from the accumulation and analysis of all that data we are busy generating and collecting. New enterprises are springing up to capitalize on data mining and business intelligence opportunities. The U.S. federal government joined in, announcing $200 million in Big Data research programs in 2012.8

The onslaught of Big Data necessitates that information governance (IG) be implemented to discard unneeded data in a legally defensible way.

But established organizations, especially larger ones, are being crushed by this onslaught of Big Data: It is just too expensive to keep all the information that is being generated, and unneeded information is a sort of irrelevant sludge for decision makers to wade through. They have difficulty knowing which information is an accurate and meaningful “wheat” and which is simply irrelevant “chaff.” This means they do not have the precise information they need to base good business decisions upon.

And all that Big Data piling up has real costs: The burden of massive stores of information has increased storage management costs dramatically, caused overloaded systems to fail, and increased legal discovery costs.9 Further, the longer that data is kept, the more likely that it will need to be migrated to newer computing platforms, driving up conversion costs; and legally, there is the risk that somewhere in that mountain of data an organization stores is a piece of information that represents a significant legal liability.10

This is where the worlds of Big Data and business collide. For Big Data proponents, more data is always better, and there is no perceived downside to accumulation of massive amounts of data. In the business world, though, the realities of legal e-discovery mean the opposite is true.11 To reduce risk, liability, and costs, it is critical for unneeded information to be disposed of in a systematic, methodical, and “legally defensible” (justifiable in legal proceedings) way, when it no longer has legal, regulatory, or business value. And there also is the high-value benefit of basing decisions on better, cleaner data, which can come about only through rigid, enforced information governance (IG) policies that reduce information glut.

Organizations are struggling to reduce and right-size their information footprint by discarding superfluous and redundant data, e-documents, and information. But the critical issue is devising policies, methods, and processes and then deploying information technology (IT) to sort through which information is valuable and which no longer has business value and can be discarded.

IT, IG, risk, compliance, and legal representatives in organizations have a clear sense that most of the information stored is unneeded, raises costs, and poses risks. According to a survey taken at a recent Compliance, Governance and Oversight Counsel summit, respondents estimated that approximately 25 percent of information stored in organizations has real business value, while 5 percent must be kept as business records and about 1 percent is retained due to a litigation hold. “This means that [about] 69 percent of information in most companies has no business, legal, or regulatory value. Companies that are able to dispose of this data debris return more profit to shareholders, can leverage more of their IT budgets for strategic investments, and can avoid excess expense in legal and regulatory response” (emphasis added).12

Big Data values massive accumulation of data, whereas in business, e-discovery realities and potential legal liabilities dictate that data be culled to only that which has clear business value.

Only about one quarter of information organizations are managing has real business value.

With a smaller information footprint, it is easier for organizations to find the information they need and derive business value from it.

With a smaller information footprint, organizations can more easily find what they need and derive business value from it.13 They must eliminate the data debris regularly and consistently, and to do this, processes and systems must be in place to cull valuable information and discard the data debris. Daily. An IG program sets the framework to accomplish this.

The business environment has also underscored the need for IG. According to Ted Friedman at Gartner, “The recent global financial crisis has put information governance in the spotlight…. [It] is a priority of IT and business leaders as a result of various pressures, including regulatory compliance mandates and the urgent need for improved decision-making.”14

And IG mastery is critical for executives: Gartner predicts that by 2016, one in five chief information officers in regulated industries will be fired from their jobs for failed IG initiatives.15

Defining Information Governance

IG is a sort of super discipline that has emerged as a result of new and tightened legislation governing businesses, external threats such as hacking and data breaches, and the recognition that multiple overlapping disciplines were needed to address today's information management challenges in an increasingly regulated and litigated business environment.16

IG is a subset of corporate governance, and includes key concepts from records management, content management, IT and data governance, information security, data privacy, risk management, litigation readiness, regulatory compliance, long-term digital preservation, and even business intelligence. This also means that it includes related technology and discipline subcategories, such as document management, enterprise search, knowledge management, and business continuity/disaster recovery.

IG is a subset of corporate governance.

IG is a sort of superdiscipline that encompasses a variety of key concepts from a variety of related disciplines.

Practicing good IG is the essential foundation for building legally defensible disposition practices to discard unneeded information and to secure confidential information, which may include trade secrets, strategic plans, price lists, blueprints, or personally identifiable information (PII) subject to privacy laws; it provides the basis for consistent, reliable methods for managing data, e-documents, and records.

Having trusted and reliable records, reports, data, and databases enables managers to make key decisions with confidence.17 And accessing that information and business intelligence in a timely fashion can yield a long-term sustainable competitive advantage, creating more agile enterprises.

To do this, organizations must standardize and systematize their handling of information. They must analyze and optimize how information is accessed, controlled, managed, shared, stored, preserved, and audited. They must have complete, current, and relevant policies, processes, and technologies to manage and control information, including who is able to access what information, and when, to meet external legal and regulatory demands and internal governance policy requirements. In short, IG is about information control and compliance.

IG is a subset of corporate governance, which has been around as long as corporations have existed. IG is a rather new multidisciplinary field that is still being defined, but has gained traction increasingly over the past decade. The focus on IG comes not only from compliance, legal, and records management functionaries but also from executives who understand they are accountable for the governance of information and that theft or erosion of information assets has real costs and consequences.

“Information governance” is an all-encompassing term for how an organization manages the totality of its information.

According to the Association of Records Managers and Administrators (ARMA), IG is “a strategic framework composed of standards, processes, roles, and metrics that hold organizations and individuals accountable to create, organize, secure, maintain, use, and dispose of information in ways that align with and contribute to the organization's goals.”18

IG includes the set of policies, processes, and controls to manage information in compliance with external regulatory requirements and internal governance frameworks. Specific policies apply to specific data and document types, records series, and other business information, such as e-mail and reports.

Stated differently, IG is “a quality-control discipline for managing, using, improving, and protecting information.”19

Practicing good IG is the essential foundation for building legally defensible disposition practices to discard unneeded information.

IG is “a strategic framework composed of standards, processes, roles, and metrics, that hold organizations and individuals accountable to create, organize, secure, maintain, use, and dispose of information in ways that align with and contribute to the organization's goals.”20

IG is how an organization maintains security, complies with regulations, and meets ethical standards when managing information.

Fleshing out the definition further: “Information governance is policy-based management of information designed to lower costs, reduce risk, and ensure compliance with legal, regulatory standards, and/or corporate governance.”21 IG necessarily incorporates not just policies but information technologies to audit and enforce those policies. The IG team must be cognizant of information lifecycle issues and be able to apply the proper retention and disposition policies, including digital preservation where records need to be maintained for long periods.

IG Is Not a Project, But an Ongoing Program

IG is an ongoing program, not a one-time project. IG provides an umbrella to manage and control information output and communications. Since technologies change so quickly, it is necessary to have overarching policies that can manage the various IT platforms that an organization may use.

Compare it to a workplace safety program; every time a new location, team member, piece of equipment, or toxic substance is acquired by the organization, the workplace safety program should dictate how that is handled. If it does not, the workplace safety policies/procedures/training that are part of the workplace safety program need to be updated. Regular reviews are conducted to ensure the program is being followed and adjustments are made based on the findings. The effort never ends.22 The same is true for IG.

IG is not only a tactical program to meet regulatory, compliance, and litigation demands. It can be strategic, in that it is the necessary underpinning for developing a management strategy that maximizes knowledge worker productivity while minimizing risk and costs.

Why IG Is Good Business

IG is a tough sell. It can be difficult to make the business case for IG, unless there has been some major compliance sanction, fine, legal loss, or colossal data breach. In fact, the largest impediment to IG adoption is simply identifying its benefits and costs, according to the Economist Intelligence Unit. Sure, the enterprise needs better control over its information, but how much better? At what cost? What is the payback period and the return on investment?23

IG is a multidisciplinary program that requires an ongoing effort.

It is challenging to make the business case for IG, yet making that case is fundamental to getting IG efforts off the ground.

Here are eight reasons why IG makes good business sense, from IG thought leader Barclay Blair:

  1. We can't keep everything forever. IG makes sense because it enables organizations to get rid of unnecessary information in a defensible manner. Organizations need a sensible way to dispose of information in order to reduce the cost and complexity of the IT environment. Having unnecessary information around only makes it more difficult and expensive to harness information that has value.
  2. We can't throw everything away. IG makes sense because organizations can't keep everything forever, nor can they throw everything away. We need information—the right information, in the right place, at the right time. Only IG provides the framework to make good decisions about what information to keep.
  3. E-discovery. IG makes sense because it reduces the cost and pain of discovery. Proactively managing information reduces the volume of information exposed to e-discovery and simplifies the task of finding and producing responsive information.
  4. Your employees are screaming for it—just listen. IG makes sense because it helps knowledge workers separate “signal” from “noise” in their information flows. By helping organizations focus on the most valuable information, IG improves information delivery and improves productivity.
  5. It ain't gonna get any easier. IG makes sense because it is a proven way for organizations to respond to new laws and technologies that create new requirements and challenges. The problem of IG will not get easier over time, so organizations should get started now.
  6. The courts will come looking for IG. IG makes sense because courts and regulators will closely examine your IG program. Falling short can lead to fines, sanctions, loss of cases, and other outcomes that have negative business and financial consequences.
  7. Manage risk: IG is a big one. Organizations need to do a better job of identifying and managing risk. The risk of information management failures is a critical risk that IG helps to mitigate.
  8. E-mail: Reason enough. IG makes sense because it helps organizations take control of e-mail. Solving e-mail should be a top priority for every organization.24

Failures in Information Governance

The failure to implement and enforce IG can lead to vulnerabilities that can have dire consequences. The theft of confidential U.S. National Security Agency documents by Edward Snowden in 2013 could have been prevented by properly enforced IG. Also, Ford Motor Company is reported to have suffered a loss estimated at $50 to $100 million as a result of the theft of confidential documents by one of its own employees. A former product engineer who had access to thousands of trade secret documents and designs sold them to a competing Chinese car manufacturer. A strong IG program would have controlled and tracked access and prevented the theft while protecting valuable intellectual property.25

Law enforcement agencies have also suffered from poor IG. In a rather frivolous case in 2013 that highlighted the lack of policy enforcement for the mobile environment, it was reported that U.S. agents from the Federal Bureau of Investigation used government-issued mobile phones to send explicit text messages and nude photographs to coworkers. The incidents did not have a serious impact but did compromise the agency and its integrity, and “adversely affected the daily activities of several squads.”26 Proper mobile communications policies were obviously not developed and enforced.

IG is also about information security and privacy, and serious thought must be given when creating policies to safeguard personal, classified or confidential information. Schemes to compromise or steal information can be quite deceptive and devious, masked by standard operating procedures—if proper IG controls and monitoring are not in place. To wit: Granting remote access to confidential information assets for key personnel is common. Granting medical leave is also common. But a deceptive and dishonest employee could feign a medical leave while downloading volumes of confidential information assets for a competitor—and that is exactly what happened at Accenture, a global consulting firm. During a fraudulent medical leave, an employee was allowed access to Accenture's Knowledge Exchange (KX), a detailed knowledge base containing previous proposals, expert reports, cost-estimating guidelines, and case studies. This activity could have been prevented by monitoring and analytics that would have shown an inordinate amount of downloads—especially for an “ailing” employee. The employee then went to work for a direct competitor and continued to download the confidential information from Accenture, estimated to be as many as 1,000 critical documents. While the online access to KX was secure, the use of the electronic documents could have been restricted even after the documents were down-loaded, if IG measures were in place and newer technologies (such as information rights management [IRM] software) were deployed to secure them directly and maintain that security remotely. With IRM, software security protections can be employed to seal the e-documents and control their use—even after they leave the organization. More details on IRM technology and its capabilities is presented later in this book.

Other recent high-profile data and document leakage cases revealing information security weaknesses that could have been prevented by a robust IG program include:

  • Huawei Technologies, the largest networking and mobile communications company in China, was sued by U.S.-based Motorola for allegedly conspiring to steal trade secrets through former Motorola employees.

    Ford's loss from stolen documents in a single case of intellectual property (IP) theft was estimated at $50 to $100 million.

  • MI6, the U.K. equivalent of the U.S. Central Intelligence Agency, learned that one of its agents in military intelligence attempted to sell confidential documents to the intelligence services of the Netherlands for £2 million GBP (S3 million USD).

And breaches of personal information revealing failures in privacy protection abound; here are just a few:

  • Health information of 1,600 cardiology patients at Texas Children's Hospital was compromised when a doctor's laptop was stolen. The information included personal and demographic information about the patients, including their names, dates of birth, diagnoses, and treatment histories.27
  • U.K. medics lost the personal records of nearly 12,000 National Health Service patients in just eight months. Also, a hospital worker was suspended after it was discovered he had sent a file containing pay-slip details for every member of staff to his home e-mail account.28
  • Personal information about more than 600 patients of the Fraser Health Authority in British Columbia, Canada, was stored on a laptop stolen from Burnaby General Hospital.
  • In December 2013, Target stores in the U.S. reported that as many as 110 million customer records had been breached in a massive attack that lasted weeks.

The list of breaches and IG failures could go on and on, more than filling the pages of this book. It is clear that it is occurring and that it will continue. IG controls to safeguard confidential information assets and protect privacy cannot rely solely on the trustworthiness of employees and basic security measures. Up-to-date IG policies and enforcement efforts and newer technology sets are needed, with active, consistent monitoring and program adjustments to continue to improve.

Executives and senior managers can no longer avoid the issue, as it is abundantly clear that the threat is real and the costs of taking such avoidable risks can be high. A single security breach is an IG failure and can cost the entire business. According to Debra Logan of Gartner, “When organizations suffer high-profile data losses, especially involving violations of the privacy of citizens or consumers, they suffer serious reputational damage and often incur fines or other sanctions. IT leaders will have to take at least part of the blame for these incidents.”29

Form IG Policies, Then Apply Technology for Enforcement

Typically, some policies governing the use and control of information and records may have been established for financial and compliance reports, and perhaps e-mail, but they are often incomplete and out-of-date and have not been adjusted for changes in the business environment, such as new technology platforms (e.g., Web 2.0, social media), changing laws (e.g., U.S. Federal Rules of Civil Procedure 2006 changes), and additional regulations.

IG controls to safeguard confidential information assets and protect privacy cannot rely solely on the trustworthiness of employees and basic security measures.

Further adding to the challenge is the rapid proliferation of mobile devices like tablets, phablets, and smartphones used in business—information can be more easily lost or stolen—so IG efforts must be made to preserve and protect the enterprise's information assets.

Proper IG requires that policies are flexible enough not to hinder the proper flow of information in the heat of the business battle yet strict enough to control and audit for misuse, policy violations, or security breaches. This is a continuous iterative policy-making process that must be monitored and fine-tuned. Even with the absolute best efforts, some policies will miss the mark and need to be reviewed and adjusted.

Getting started with IG awareness is the crucial first step. It may have popped up on an executive's radar at one point or another and an effort might have been made, but many organizations leave these policies on the shelf and do not revise them on a regular basis.

IG is the necessary underpinning for a legally defensible disposition program that discards data debris and helps narrow the search for meaningful information on which to base business decisions. IG is also necessary to protect and preserve critical information assets. An IG strategy should aim to minimize exposure to risk, at a reasonable cost level, while maximizing productivity and improving the quality of information delivered to knowledge users.

But a reactive, tactical project approach is not the way to go about it—haphazardly swatting at technological, legal, and regulatory flies. A proactive, strategic program, with a clear, accountable sponsor, an ongoing plan, and regular review process, is the only way to continuously adjust IG policies to keep them current so that they best serve the organization's needs.

Some organizations have created formal governance bodies to establish strategies, policies, and procedures surrounding the distribution of information inside and outside the enterprise. These governance bodies, steering committees, or teams should include members from many different functional areas, since proper IG necessitates input from a variety of stakeholders. Representatives from IT, records management, corporate or agency archiving, risk management, compliance, operations, human resources, security, legal, finance, and perhaps knowledge management are typically a part of IG teams. Often these efforts are jump-started and organized by an executive sponsor who utilizes third-party consulting resources that specialize in IG efforts, especially considering the newness of IG and its emerging best practices.

So in this era of ever-growing Big Data, leveraging IG policies to focus on retaining the information that has real business value, while discarding the majority of information that has no value and carries associated increased costs and risks, is critical to success for modern enterprises. This must be accomplished in a systematic, consistent, and legally defensible manner by implementing a formal IG program. Other crucial elements of an IG program are the steps taken to secure confidential information by enforcing and monitoring policies using the appropriate information technologies.

Getting started with IG awareness is the crucial first step.

CHAPTER SUMMARY: KEY POINTS

  • The onslaught of Big Data necessitates that IG be implemented to discard unneeded data in a legally defensible way.
  • Big Data values massive accumulation of data, whereas in business, e-discovery realities and potential legal liabilities dictate that data be culled to only that which has clear business value.
  • Only about one quarter of the information organizations are managing has real business value.
  • With a smaller information footprint, it is easier for organizations to find the information they need and derive business value from it.
  • IG is a subset of corporate governance and encompasses the policies and leveraged technologies meant to manage what corporate information is retained, where, and for how long, and also how it is retained.
  • IG is a sort of super discipline that encompasses a variety of key concepts from a variety of related and overlapping disciplines.
  • Practicing good IG is the essential foundation for building legally defensible disposition practices to discard unneeded information.
  • According to ARMA, IG is “a strategic framework composed of standards, processes, roles, and metrics that hold organizations and individuals accountable to create, organize, secure, maintain, use, and dispose of information in ways that align with and contribute to the organization's goals.”30
  • IG is how an organization maintains security, complies with regulations and laws, and meets ethical standards when managing information.
  • IG is a multidisciplinary program that requires an ongoing effort and active participation of a broad cross-section of functional groups and stakeholders.
  • IG controls to safeguard confidential information assets and protect privacy cannot rely solely on the trustworthiness of employees and basic security measures.
  • Getting started with IG awareness is the crucial first step.

Notes

1. The Economist, “Data, Data Everywhere,” February 25, 2010, www.economist.com/node/15557443

2. Gartner, Inc., “IT Glossary: Big Data,” www.gartner.com/it-glossary/big-data/(accessed April 15, 2013).

3. Webopedia, “Big Data,” www.webopedia.com/TERM/B/big_data.html (accessed April 15, 2013).

4. World Economic Forum, “Personal Data: The Emergence of a New Asset Class”(January 2011), http://www3.weforum.org/docs/WEF_ITTC_PersonalDataNewAsset_Report_2011.pdf

5. Deidra Paknad, “Defensible Disposal: You Can't Keep All Your Data Forever,” July 17, 2012, www.forbes.com/sites/ciocentral/2012/07/17/defensible-disposal-you-cant-keep-all-your-data-forever/

6. Susan Karlin, “Earth's Nervous System: Looking at Humanity Through Big Data,” www.fastcocreate.com/1681986/earth-s-nervous-system-looking-at-humanity-through-big-data#1 (accessed March 5, 2013).

7. IDC Press Release, December 18, ,2013, http://www.idc.com/getdoc.jsp?containerId=prUS24542113 New IDC Worldwide Big Data Technology and Services Forecast Shows Market Expected to Grow to $32.4 Billion in 2017

8. Steve Lohr, “How Big Data Became So Big,” New York Times, August 11, 2012, www.nytimes.com/2012/08/12/business/how-big-data-became-so-big-unboxed.html?_r=2&smid=tw-share&

9. Kahn Consulting, “Information Governance Brief,” sponsored by IBM, www.delve.us/downloads/Brief-Defensible-Disposal.pdf (accessed March 4, 2013).

10. Barclay T. Blair, “Girding for Battle,” Law Technology News, October 1, 2012, www.law.com/jsp/lawtech-nologynews/PubArticleLTN.jsp?id=1202572459732&thepage=1

11. Ibid.

12. Paknad, “Defensible Disposal.”

13. Randolph A. Kahn, https://twitter.com/InfoParkingLot/status/273791612172259329, November 28, 2012.

14. Gartner Press Release, “Gartner Says Master Data Management Is Critical to Achieving Effective Information Governance,” www.gartner.com/newsroom/id/1898914, January 19, 2012

15. Ibid.

16. Monica Crocker, e-mail to author, June 21, 2012.

17. Economist Intelligence Unit, “The Future of Information Governance,” www.emc.com/leadership/business-view/future-information-governance.htm (accessed November 14, 2013).

18. ARMA International, Glossary of Records and Information Management Terms, 4th ed., 2012, TR 22–2012.

19. Arvind Krishna, “Three Steps to Trusting Your Data in 2011,” IT Business Edge, posted March 9, 2011, www.itbusinessedge.com/guest-opinions/three-steps-trusting-your-data-2011. (accessed November 14, 2013).

20. ARMA International, Glossary of Records and Information Management Terms, 4th ed., 2012, TR 22–2012.

21. Laura DuBoisand Vivian Tero, “Practical Information Governance: Balancing Cost, Risk, and Productivity,” IDC White Paper (August 2010), www.emc.com/collateral/analyst-reports/idc-practical-information-governance-ar.pdf

22. Monica Crocker, e-mail to author, June 21, 2012.

23. Barclay T. Blair, Making the Case for Information Governance: Ten Reasons IG Makes Sense, ViaLumina Ltd, 2010. Online at http://barclaytblair.com/making-the-case-for-ig-ebook/ (accessed November 14, 2013).

24. Barclay T. Blair, “8 Reasons Why Information Governance (IG) Makes Sense,” June 29, 2009, www.digitallandfill.org/2009/06/8-reasons-why-information-governance-ig-makes-sense.html

25. Peter Abatan, “Corporate and Industrial Espionage to Rise in 2011,” Enterprise Digital Rights Management, http://enterprisedrm.tumblr.com/post/2742811887/corporate-espionage-to-rise-in-2011. (accessed November 14, 2013).

26. BBC News, “FBI Staff7 Disciplined for Sex Texts and Nude Pictures,” February 22, 2013, www.bbc.co.uk/news/world-us-canada-21546135

27. Todd Ackerman, “Laptop Theft Puts Texas Children's Patient Info at Risk,” Houston Chronicle, July 30, 2009, www.chron.com/news/houston-texas/article/Laptop-theft-puts-Texas-Children-s-patient-info-1589473.php. (accessed March 2, 2012).

28. Jonny Greatrex, “Bungling West Midlands Medics Lose 12,000 Private Patient Records,” Sunday Mercury, September 5, 2010, www.sundaymercury.net/news/sundaymercuryexclusives/2010/09/05/bun-gling-west-midlands-medics-lose-12-000-private-patient-records-66331-27203177/ (accessed March 2, 2012).

29. Gartner Press Release, “Gartner Says Master Data Management Is Critical to Achieving Effective Information Governance.”

30. ARMA International, Glossary of Records and Information Management Terms.

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