today are increasingly subject to state and federal regulations
governing which electronic records they must retain, how long they
should be retained, and how readily they should be made accessible to
regulators. SharePoint users must be aware of the regulations that
affect stored documents and should know how to use and apply the
information management policies and records management features
available for documents stored in SharePoint that have legal
requirements. An example of two federal acts that apply to record
Health Insurance Portability and Accountability Act (HIPPA)
Requires organizations that have access to personal health information
to adopt security policies to safeguard the confidentiality of the data.
Organizations must also monitor and control access to the data and
maintain an audit trail available to regulators.
Sarbanes-Oxley Act (SOX)
Applies to publicly traded companies and requires that companies put in
place extensive policies and procedures to control their financial
information and to prevent fraud. It also requires that executives
certify the validity of company financial statements and that
independent auditors verify the financial controls put in place.
In addition to the
rules and regulations that organizations must comply with for legal
reasons, companies have found that defensive business practices also
call for good data management to protect the company during litigation.
Companies are often required to produce copies of documents and files
deemed to be relevant to a lawsuit or prosecution. In some cases in
which companies could not produce the requested documents, courts have
ruled that documents that are not available are assumed to support the
plaintiff’s arguments. Organizations cannot afford to lose control of
critical documents and e-mail messages.
1. What Is Records Management?
enables a company to effectively manage a content item, or record, from
inception to disposal in accordance with applicable laws, such as the
federal regulations mentioned previously. A record is a physical or
electronic document, an e-mail message, or some other form of digital
information, such as an instant message transcript, that serves as
evidence of an activity or transaction performed by the organization.
Records management is the
process by which an organization defines what type of information it
needs to classify as a record, how long it needs to retain the
information, and how it will manage the information throughout its life
cycle. Part of the challenge of records management is to identify and
track information items that are legally or economically vital to the
business. For example, an e-mail message that contains some reference to
financial information about the company or about a client might well be
considered a record. The other part of the challenge is to filter and
purge items that do not
need to be stored as records. As an example, an exchange of e-mail
messages in which two employees of an organization decide where to have
lunch might not be considered record material.
Although setting a policy that
declares everything to be a record might seem to be a safe approach for
an organization, this policy could be almost as harmful as not declaring
any content item a record. For example, if a legal action requires that
a company deliver the approximately one hundred e-mail records that
pertain to a court case, and the best that the company’s IT department
can do is provide the 10,000 e-mail messages sent within a specific time
frame, then the court may rule that delivering the relevant items
buried within a mass of irrelevant data to be a form of obstruction. An
additional benefit can be obtained from creating policies that determine
what a company record is, rather than trying to store everything as a
record—because records are stored based on content types, narrowing the
definition of what constitutes a record can improve the ability of users
to perform targeted searches that avoid returning irrelevant data.
A well-designed records
management plan is essential for data retention policies to mesh with
actual data management processes. For example, if a company’s retention
policy specifies that a document should be purged and destroyed after
one year, then backups should be designed so that no backup more than a
year old has a copy of the file on it. On the other hand, a retention
policy that dictates that a document must be readily available for
review for a period of three years requires that a live copy of any
document be kept in a storage location from which it can be pulled
without restoring it from backup. These types of organization-specific
requirements dictate a need for every company to not only develop the
appropriate policies but to implement and enforce those policies as
well. There have been cases in which organizations have not followed
their own policies and were required to retrieve specific data from
archival backups and restore it onto their network, which is generally a
very time-consuming and costly process.
A records management plan should contain the following elements.
requirements document that defines the policies the organization must
implement to ensure compliance with legal and regulatory requirements,
along with the practices that employees must adhere to in accordance
with the policies
A chart that indicates who will be responsible for the different roles that must be filled in the records management process
file plan that identifies which types of information are considered
records, where they are stored, the permissions and policies that govern
them while they are active, and how and when to dispose of records
2. Compliance Requirements Document
requirements document explains the purpose of a compliance program and
its benefits together with its essential components. It identifies the
legal or business criteria to which the compliance plan must adhere and
the metrics or other objective criteria that will be used to measure the
effectiveness of the compliance plan. The compliance requirements
document includes the formal policies that represent the organization’s
internal statement of the regulatory rules it must follow.
requirements document should also include specifications for ongoing
training for employees at all levels and guidelines for the roles
and involvement of senior management in the compliance process.
Although it may not be practical for every organization, a formal
compliance audit should also be carried out at regular intervals to
ensure that the records management plan is meeting its objectives.
3. Records Management Roles
When developing the
records management plan, it is important to consider who is responsible
for the various roles that are involved in the creation and
implementation of the plan. Since SharePoint 2010 is a content-rich
application, some of these roles will include the SharePoint
administrator, content managers, records managers, and compliance
3.1. SharePoint Administrator
Administrators are responsible for the installation and configuration of the SharePoint 2010 servers that provide records
management services to the enterprise. They create the Web applications
and the Records Center site and configure the connection to the
official file that lets users submit documents to the records center.
3.2. Compliance Officers
are usually associated with an organization’s legal department and are
often lawyers. They are responsible for understanding and interpreting
the regulations and rules that the organization must follow. They
develop the formal compliance policies that the company will implement
and, as a result, they are the primary authors of the compliance
requirements document and perform internal monitoring and auditing to
ensure that the organization closely follows the records management
3.3. Records Managers
Records managers are responsible for developing the file
plan that applies the compliance requirements document to the different
types of information items that the organization produces. The records
managers may also be members of the organization’s legal department or
may be senior administrative staff members who have a thorough
understanding of the organization’s business practices and workflow.
After the SharePoint
administrators have created the Records Center site, records managers
are in charge of configuring the document libraries and retention rules
in the site. Records managers should be consulted at all points in the
design of the records management system
3.4. Content Managers
Content managers work
on the teams that create information items that will be designated as
records. If necessary, the content managers configure team sites with
the appropriate content types and workflows to facilitate the effective
and efficient categorization of documents so that they can be routed to
the appropriate location.
3.5. Information Workers
Information workers are
the employees in an organization who create new documents and e-mail
messages that need to be classified and routed to the records center for
safeguarding. The goal of a reliable records management system should
be to make it relatively easy for information workers to classify
information accurately, or even automatically, as it is produced.
4. The File Plan
The file plan is a written
document or set of documents that lists all of the types of information
that an organization receives or produces and how each one should be
classified and handled. Some information will be classified as a record
when it is created, other information will be treated as a record only
when it reaches a certain stage in its life cycle, and then there will
be information that is either temporary or unimportant enough that it is
not considered a type of record. The criteria used to classify a record
will come from the organization’s compliance requirements document
produced by the compliance officer.
As part of your effort to
train and educate your end users about how to use SharePoint
Technologies, be sure to educate them about the file
plan and any information management policies that apply to them. Users
need to know when a document or record moves from being unofficial
communication to being official communication, and they also need to
know your company’s policy to properly consume, store, and dispose of
Although the details of
what enters into the file plan will depend on the type of information
that your organization is managing, there are usually some common
elements in most plans. As shown in Table 1,
these elements include a list of record types and the key information
that must be associated with each type to ensure that it is filed
properly. After an information item is classified as a record, it can be
copied or moved into a SharePoint 2010 site based on the Records Center
site template. This site serves as the storage area for both active and
inactive documents that must be readily available as either an
information resource for staff or as evidentiary material in litigation.
Active documents are those that are still in use as part of a project
or an ongoing e-mail discussion. These documents may continue to be
updated over time, and new versions will be submitted to the repository
as they are generated. The file plan will specify whether older versions
of the same document are retained and for how long. Inactive documents
are those that have reached their final version or have been submitted
formally to an agency. Although employees will probably not generate any
further versions of the document, the last version must be retained as
an official record of the transaction.
Table 1. File Plan Elements
classification of the information item. Each record type corresponds to
a set of typical documents or messages that need to be tracked and
managed in the same way.|
|Required Fields||Any additional information that will be required when the document is submitted to the repository.|
|Retention||How long the document will be retained.|
|Disposal||How the document will be handled when it expires.|
access to the document will be tracked and logged along with the types
of actions on the document that have to be logged.|
It is important to
distinguish between documents that are retained as records and those
that are retained in an archive. Archived information is not classified
as a record after the period for which it needs to be retained as a
record has expired. At that point, the information is usually
transferred to tape or printed out and placed in long-term storage with
the expectation that it will be kept mainly for historical purposes.
Archived data is generally not readily available for search and
retrieval and it is not expected to be required for current research or
legal discovery. But keep in mind that the legal discovery process can
request any information deemed appropriate for the matter at hand,
another reason to make sure expired data is properly archived.
In Table 2, you can see an example of a standard file
plan filled out for several record types in an organization. As you can
see, different document types have different record management
requirements. For example, financial statements will be kept
indefinitely in archival storage because of their historical value to
the company, but e-mail correspondence is considered too voluminous and
of too little value to archive in the long term.
Table 2. Sample File Plan
|RECORD TYPE||FINANCIAL STATEMENTS||INVOICES||E-MAIL CORRESPONDENCE|
|Required Fields||Statement Date (date field)||Delivery Date (date field)||Subject (string property, single line of text)|
|Expiration||Retain for 7 years after Statement Date||Retain for 5 years after Delivery Date||Retain for 3 years from date created|
|Disposal||Archive and delete on expiration||Archive and delete on expiration||Delete on expiration|
|Audit||Audit View events only||None||None|
organization’s legal department provides you with the storage and
archive requirements for any documents in SharePoint that have legal
requirements associated with them or that are considered important
enough to require some form of records management.
5. What Are Information Management Policies?
management policies are sets of rules governing the automated management
of documents, such as how long a file should be retained or which
actions on the file should be audited. Each rule in a policy is called a
Policies in a records management system are configured by records
managers to reflect the file plan requirements. The value of storing
files in separate document libraries becomes obvious when you start
designing the information management policies that you will apply to
There are two
recommended approaches for implementing policies in the repository: (1)
create individual policies for each document library if the requirements
are unique to the content in each library, or (2) create site
collection policies to cover an entire set of record types and apply
them to several document libraries as needed. You can either apply one
policy for the entire document library, or if you configure the document
library to allow multiple content types, then you can apply a separate
policy to each content type. Figure 1 shows the four features available when defining an information management policy.
Figure 1. Information management policy features
After creating a policy,
you implement it by associating it with a site collection, content type,
list, or library. This association to a content type, list, or library
can be accomplished using one of the three following methods.
Site Collection Policy
Associate the policy features with a site collection policy and then
associate that policy with a content type, list, or library.
Content Type Policy
Associate a set of policy features directly with a content type and
then use that content type in one or more lists or libraries.
List or Library Policy
Associate a set of policy features directly with a list or library.
However, you can only use this method when the library or list is not
using more than one content type.
A policy feature might use one
or more policy resources, which are programs that provide functionality
to a policy feature. For example, a custom policy resource for the
barcode policy feature could be used to generate a unique barcode value
for a document.
6. Planning Document Policies
The use of policies can be
simplified by planning how and where they will be used. This can be
accomplished by first determining your organization-wide policy needs
and then designing your site collection policies to meet those needs and
distribute those policies for use as site collection policies for all
relevant site collections. If any policy requires custom policy features
or resources, those features and resources have to be installed and
enabled on all server farms using that solution.
7. Policy Metadata
Policies often require
the use of additional document properties or metadata. It is important
to create consistent metadata properties that can be used throughout
your entire farm. SharePoint 2010 introduces a service application
called MMS (Managed Metadata Service) that is used to create
enterprise-wide content types and metadata. This service application
will host a Web application with a site collection that you can use to
create your farm level content types and metadata properties, which
eliminates the need to create them as a feature and deploy them to each
site collection, as was the case in Microsoft SharePoint Server 2007.
All Web applications that are associated with the Managed Metadata
Service can consume any content type as well as metadata from the MMS
For instance, when you
configure the retention period of a document, you may need to use a
SharePoint-provided date property or create a custom date property that
will be used to determine when an action is performed on that document.