Why do organizations mismanage their information assets? Some of the reasons arise out of the natural result of market correction or contraction (compliance wasn’t a priority during the “tech bubble”), putting aside compliance issues as companies rushed to adopt the latest technology in order to “keep up with the Joneses,” the failure of compliance issues to be considered in the development of new technology, or the failure to designate responsibility for electronic records as the volume of such records grew in the enterprise.
Randolph Kahn developed a framework for an organization to solve this problem. Called the Seven Keys for Information Management Compliance, the framework is based upon the Federal Sentencing Guidelines. The Guidelines provide seven criteria that courts will look at when sentencing a company found guilty of a criminal act.
The Guidelines have had a significant influence on how companies design and implement compliance and corporate ethics programs. Not only do the Guidelines tell companies how fines and penalties will be assessed, but they help companies determine what they can do to help avoid or reduce sanctions for wrongdoing.
The Seven Keys are described in detail in the second edition of Information Nation, available from John W. Wiley & Sons. For more information, see www.informationnationbook.com. Stay tuned for more blog posts on the Seven Keys.
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