Caroline Morgan featured in CSO article on best and worst record retention practices

Culhane Meadows’ New York partner Caroline Morgan was recently interviewed for an article by CSO about record retention do’s and don’ts.

Here are a few excerpts from the article:

While sports records are made to be broken, enterprise records are made to be retained—at least until they’ve outlived their usefulness. As regulatory mandates rapidly multiply, enterprises are facing a document tsunami, as current and outdated records begin overwhelming the human and IT resources necessary to securely store, track, manage and eventually destroy them.

Each records class has a retention period that’s defined by a combination of corporate policy, business risk tolerance, external legal advice, regulatory requirements and legal obligations, says Sean Riley, a principal at Deloitte Risk and Financial Advisory. “Some records only need to be kept for three years, others may need to be kept indefinitely for business value or legal reasons,” he notes.

Records retention is really all about records destruction, says Dan Frank, also a principal at Deloitte Risk and Financial Advisory. “Most organizations are very good—too good—at retaining data,” he says. “The CISO’s primary responsibility is to ensure that the organization has secure data and records destruction capabilities, as well as corresponding technologies that securely delete data and records when appropriate.” Preserving obsolete records can lead to wasted time and needless confusion as researchers find themselves plowing through outdated files as they search for the records they actually need. Failing to properly curate records also drives up storage and backup costs.

The regulatory landscape is constantly changing and CISOs need to be prepared to quickly adjust record retention periods whenever regulatory or legal changes demand a change. Failing to act promptly can lead to serious financial and litigation consequences when still-needed records are automatically purged via inaction. It’s important to maintain tight oversight on retention periods, advises Caroline Morgan, a partner in the New York offices of national law firm Culhane Meadows. “You have to find your records retention sweet spot,” she adds.

Morgan also urges CISOs to monitor exactly how management and staff are accessing and handling records. Keep your ear to the ground,” she says. “No matter how perfect a record retention policy is on paper, if people don’t comply with it, it’s useless.”

To view the article, click HERE.


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