As with most large businesses, BNY Mellon’s paper-based governance processes were not designed for the large volumes of electronic information we now depend on. Legal found it difficult to define and execute legal holds. Records & Information Management (RIM) was equally challenged to apply retention schedules across the organization. Information Technology (IT) had difficulty seeing legal obligations or the business requirements for the information, which led to a difficulty in disposing of information -- despite studies showing that only about 31 percent of all data has any legal, compliance or business value. This led to a year-over-year increase in storage spend despite the decline in retail storage costs.
To overcome these challenges, BNY Mellon has embraced a cross-functional Information Lifecycle Governance (ILG) program that will align information stakeholders in Legal, RIM, IT and the business to enable the defensible disposal of information that has no legal, compliance or business value. Based on practices codified in the Information Lifecycle Governance Leader Reference Guide recently published by the Compliance, Governance and Oversight Counsel (CGOC) , the multi-year ILG journey is beginning to transform our legal, records and IT practices to improve our information economics while reducing risk.
The goal of our ILG program is to align the needs of all information stakeholders, providing:
- Legal with the ability to automatically place and track legal holds.
- RIM with the ability to centralize and automate global retention schedules, based on up-to-date law and business value, for all information: paper and electronic, records and non-records, structured and unstructured.
- Business users with easier access to information while transparently satisfying the needs of Legal and RIM.
- IT with the ability to defensibly dispose of all information that has no value.
A successful ILG journey can be significant for BNY Mellon in terms of economics, reduced risk and increased business value.
The Steps in the Journey:
1. Bringing Together the Right People. ILG requires broad and deep support from executives and managers. The ILG Executive Steering Committee includes our Chief of Staff as executive sponsor, Global head of Client Management, Global head of Operations & Technology, Chief Risk Officer, Chief Financial Officer, General Counsel, and our Chief Information Officer. Our Senior Advisory Group is composed of business leaders who provide staff and support for the program. We have also staffed a Program Office that drives and measures progress toward our ILG goals and directs the efforts of a Working Group, which is developing the specific processes.
2. Creating a Framework for Unifying Processes. Our first task was to develop a strategy for unifying the disparate processes and practices in Legal, RIM, IT and the businesses. We leveraged the Information Governance Reference Model (IGRM), to provide a framework for linking information duties and business value to actual data assets. This is necessary to ensure the availability of valuable information, reduce risk, and enable disposal of unnecessary information.
3. Translating Strategy into Tactics and Goals into Results. Next, we established clear connections between business objectives, the processes and actions required to achieve them, the capacity to execute those actions and the measurement needed for accountability. Without clear business goals, processes and metrics, it would be impossible to evaluate whether we have the capacity for successful execution.
4. Implementing the Right Technology. We are also implementing technology to support creating a global standard taxonomy and retention policy, cataloging the business value of all information, automating legal holds and syndicating this information to the IT systems with custody of the information. We are also implementing a shared data source catalog across all the stakeholder organizations and a secure repository where records can be managed and disposed.
5. Measuring Success. As part of this journey, we are implementing constant and consistent measurement and reporting. Using our cost- and risk-reduction goals and timeline, we have created executive dashboards and management reports. We are also measuring our operational capacity to ensure we have the resources we need to succeed.
6. Auditing the Program. The key final step of the journey will be to engage Internal Audit to report on process failures, help identify failure causes, and ensure accountability for fixing issues.
Defensible disposal, made possible by our ILG program, creates shareholder value for BNY Mellon by substantially improving information economics and aligning information stakeholders across legal, records, research, business and IT to lower systemic risks and achieve greater financial performance.
Allen Cohen is Managing Director & Chief Information Officer, BNY Mellon International, and is a CGOC Faculty Member. He has been with BNY Mellon since August 2000. He currently is the Chief Information Officer for International technology reporting to Suresh Kumar, Global CIO for BNY Mellon. Cohen is also a faculty member of the Compliance, Governance and Oversight Counsel (CGOC) and recently presented at the 2012 CGOC workshops in New York City and London on “Aligning Information Stakeholders to Improve Information Economics.”