Information Governance Maturity for Financial Services
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The document discusses information governance maturity in the financial services industry. It notes key regulatory changes like those in Dodd Frank that require new record keeping. It also discusses typical drivers for information governance like risk/cost containment, reputational risks, and intellectual property protection. The document provides an overview of HP Autonomy's information governance solution for classification, policy management, and retention of records across different repositories and locations.
Information Governance Maturity for Financial Services
- 1. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice. InformationGovernance MaturityinFinancialServices
- 2. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.2 Key Regulatory Changes • Record Keeping in Dodd Frank and EMIR Multi - Jurisdictional Regulatory Requirement • FINRA (Financial Industries Regulatory Authority), SEC (Securities & Exchange Commission), CFTC (Commodities & Futures Trading Commission), BoE (Bank of England) Past Legal or Regulatory Issues or Fines • Data Protection, Collusion, Corruption, Harassment, Insider Trading, Money Laundering, 80+ others Reputational or Event Risk • Keep out of the headlines Intellectual Property (IP) or Non-Public Info (MNPI) Leaks Cost Containment • Storage • Discovery Typical Information Goverance Drivers in Banking
- 3. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.3 Risk & Cost Impact Increasing Year on Year
- 4. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.4 Example Regulation - Dodd Frank Background • Regulations under Dodd Frank introduced new requirements for reporting and record keeping of Swaps and Derivatives related content • Generally require that relevant records be duplicated and retained for 5 years following termination, execution, or expiration a contract • Includes all of the information that is associated with execution of an agreement, and provide basis for economic terms of a deal • Retain records according to specific regulatory requirements for immutability and third-party access within 24 / 36 / 72 hours
- 5. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.5 HP Autonomy’s Information Governance Solution Business Analytics Search & Collaboration Information Governance Legal Hold & eDiscovery Deal Reconstruction Supervision IBM CMOD Symantec EV EMC Centera NICE Other SourcesFile Shares Social Media Video Audio Email Texts Transactional Data IT/OT Search Engine ImagesDocumentsMobile HP Bi-directional Connector Framework RainStor
- 6. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.6 Information Governance Defined HP Autonomy Information Governance A portfolio of modular solutions that help organisations access and understand human and computer-generated information without bias to repository or location, organise and control this data with a centralised policy engine, and intelligently manage and take action upon this data in accordance with business, legal/compliance, and data management objectives. © Copyright 2013 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.
- 7. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.7 Unaware: unmanaged Aware: formative Aware: developing Aware: competent Stages of Competency • Vital records at risk • Non-compliance • Duplication of work • High storage and e-discovery costs • No authoritative versions • No info sharing • Uncontrolled retention • Decisions based on incomplete info • Incomplete chain of custody • No recognisable business context • Poor information security • Duplication of work • High e-discovery cost • No authoritative versions • No sharing of information • Poor retention • Decisions based on incomplete information • Incomplete chain of custody • No recognisable business context • Poor information security • Duplication of work • No authoritative versions • Minimal sharing of information • Decisions based on incomplete information • No recognisable business context • Poor information security • Cost of manual capture • Distributed silos of records
- 8. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.8 Stages of Competency – ARMA GARP Maturity Model • There is no clear definition of the records that the organisation is obligated to keep • Records and other business documentation are not systematically managed according to records management principles • Business groups define this to the best of their ability based upon their interpretation of rules and regulations • There is no central oversight and/or consistently defensible position • There is no defined or understood process for imposing ‘holds’ Sub Standard In Development Essential Proactive Transformational • The organisation has identified the rules and regulations that govern its business • The organisation has introduced some compliance policies and recordkeeping practices around them • The policies are not complete • There is no apparent or well defined accountability for compliance • There is a hold process, but it is not well integrated with the organisations information and discovery processes • The organisation has identified all relevant compliance laws and regulations • Record creation and capture are systematically carried out in accordance with record management principles • The organisation has a strong code of business conduct which is integrated into its overall information governance structure and record keeping policies • Compliance and the records that demonstrate it are highly valued and measurable • The hold process is integrated into the organisations information management and discovery processes for the “most critical” systems • The organisation has defined specific goals related to compliance • The organisation has implemented systems to capture and protect records • Records are linked with the metadata used to demonstrate and measure compliance • Employees are trained appropriately and audits are conducted regularly • Records of the audits and training are available for review • Lack of compliance is remedied through implementation of defined correctiveactions • The hold process is well managed with defined roles and a repeatable process that is integrated into the organisations information management and discovery processes • The importance of compliance and the role of records and information in it are clearly recognised at the senior management and board levels • Auditing and continuous improvement processes are well established and monitored by senior management • The roles and processes for information management and discovery are integration • The organisations stated goals related to compliance have been met • The organisation suffers few or no adverse consequences based on information governance and compliance failures
- 9. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.9 ARMA – Generally Accepted Recordskeeping Principles Accountability Transparency Integrity Protection Compliance Availability Retention Disposition A senior executive (or person of comparable authority) oversees the recordkeeping program and delegates program responsibility to appropriate individuals. The organisation adopts policies and procedures to guide personnel and ensure the program can be audited. The processes and activities of an organisation’s recordkeeping program are documented in a manner that is open and verifiable and is available to all personnel and interested parties. A recordkeeping program shall be constructed so the records and information generated or managed by or for the organisation have a reasonable and suitable guarantee of authenticity and reliability. A recordkeeping program shall be constructed to ensure a reasonable level of protection to records and information that are private, confidential, privileged, secret or essential to business continuity. The recordkeeping program shall be constructed to comply with applicable laws and other binding authorities, as well as the organisation’s policies. An organisation shall maintain records in a manner that ensures timely, efficient and accurate retrieval of needed information. An organisation shall maintain its records and information for an appropriate time, taking into account legal, regulatory, fiscal, operational, and historical requirements. An organisation shall provide secure and appropriate disposition for records that are no longer required to be maintained by applicable laws and the organisation’s policies.
- 10. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.10 Our Value Proposition Enterprise Retention Management Global policy and metadata management Manage in Place Single Pane of Glass View Robust Out of Box Functionality Manage in Place
- 11. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.11 HP Autonomy Information Governance Framework Ensure Retention & Disposition HP Information Governance A platform approach for effectively managing all information, enterprise-wide, in accordance with corporate policy and business goals Gain Full Understanding Automate Policy Application Prepare & Respond: legal & regulatory Store & Manage in Place
- 12. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.12 HP Information Governance Solution Stack HP Records Manager CompleteRM Lifecycle ControlPoint File Analytics, Policy Management HP e- Discovery Complete discoverylifecycle management HP Legal HoldEnd-to-endlegal hold Structured Data Manager Structured content archiving HP Information Governance Application Architecture Core Application Logic CFS Intelligent Data Operating Layer Connectors Enterprise Repositories Indexing Services Connection Services The Power of the Platform
- 13. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.13 HP Information Governance Logical Architecture Connector Framework Enrich meta Name lookups Speech to text OCR Email IM Voice HP ControlPoint - Classification HP RM - Records Management HP Structured Data Manager Compliance Front Office Compliance Files Persist ReviewManage policy Report Unstructured Applications Scan/Fax Structured WORM / Disk
- 14. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.14 Making retention an enterprise reality HP Information Governance Process Flow • Allows organizations to identify “dark data: • Understand its meaning and significant • Classify and categorize Control • Treat related information consistently • Apply policy to content typeApply Policy • Make management decisions on access, availability, location and disposition • Complete audit trail Take Action
- 15. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.15 ControlPoint is an application that provides a user interface and an ‘engine’ for: HP ControlPoint Introduction Configuring the classification of files Reviewing the results of classifications Configuring and applying policies that take actions, ‘about’ files that it manages
- 16. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.16 HP Records Manager Introduction HP Records Manager Interactive Document Management SharePoint Governance ControlPoint Auto-Declare In-Place Management SAP ArchiveLink AIO Structured Records Physical Records COM/.NET SDK Services API Custom Solutions ControlPoint Legacy Data Cleanup
- 17. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.17 HP Structured Data Manager Introduction Reduce data footprint & storage costs Enhance operational efficiency Retire outdated applications Subset & Masking for Test Improve search and eDiscovery SDM Customized Solutions Groovy SDK Application Integrations
- 18. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.18 In Place Management Content repositories Content repositories Know what information you have Know where the information is located Know your information is protected Know the information is managed appropriately IDOLConnectorFramework Manage in Place • Content Creation • Business Processes • Collaboration • Projects • Events ControlPoint HP Records Manager Index, Analyze, Auto-Classify Declare Retain and manage active information where it provides the best business value
- 19. HP and Autonomy Confidential © Copyright 2012 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.19 Information Governance Functionality Policy Management Content Collection Source Repositories ConnectorFrameworkServer On Demand FileShares RainStor SEV SharePoint Exchange HP RM • No additional content store • Metadata Management • Retention • Search • ILM • Approval routing • Legal Hold Mgmt and Support • Notification and alerts • Reporting • Audit CP • Indexing Services • MIP • Collect Insert • Delete/Remove • Hold/Release • Hold • Synchronize • View • Audit Basic Available Custom Enterprise Retention Management
- 20. Copyright © 2013 HP Autonomy. All rights reserved. Other trademarks are registered trademarks and the properties of their respective owners. Craig Adams, EMEA Sales Director – Information Governance Craig Adams, EMEA Sales Director – Information Governance Email: [email protected] [email protected] Mobile: +44 7717 850527 LinkedIn: www.linkedin.com/in/craigadamsuk
Editor's Notes
- #12: HP’s Meaning Based Information Governance framework consists of 5 pillars spanning the full information management lifecycle. Gain Full Understanding of all information including its location, business meaning and governance state Automate Policy Application across all repositories, data types and social media interactions in a consistent and effective manner Prepare for and Respond to audits, discovery & compliance (e.g. FOI Requests) obligations to reduce costs & mitigate systemic risk exposure Protect, Archive, and Secure information to meet business SLA’s based on its meaning and value Ensure Retention and Disposition assets in a defensible manner in accordance with all applicable policies and workflows
- #14: AIO: Can render data back based on the view that was used to capture. Don’t need application to exist. No one else can do this.
- #17: .