If you are looking to invest, it would be nice to know if the broker who has been recommended to you has a history of complaints by his/her customers or employers. If you are the prospective broker, it would be good to be able to present a clean record, even if your record isn’t clean.
“Brokers Purge Their Records,” The Wall Street Journal, November 19, 2018 B1. Brokers can request that complaints be expunged from the records of the industry-funded regulator. So, were you to ask you would be told there’s no record.
So, what is a clean record worth, when a dirty record can be so easily laundered? I guess there may be multiple definitions of “record,” one of which is documentation of a business activity or decision, and the other of which is a conviction.
On the internet, no one knows you’re a dog.
A Tesla employee is indicted for creating fake documents to cover up a fake-payment scheme. “Former Tesla Employee Is Indicted,” The Wall Street Journal, November 12, 2018 B5.
Companies have a lot of controls to prevent fraud by employees, and often these controls work. Why are there more such controls to prevent financial fraud than to prevent violations of other company procedures, such as those related to document creation, retention, and storage?
One wonders whether, in the aggregate, companies lose more money through poor document management and control than they lose through financial fraud. How would one conduct such a study?
Filed under Accuracy, Compliance, Compliance (General), Controls, Corporation, Directors, Duty, Duty of Care, Employees, Governance, Information, Internal controls, Oversight, Protect assets, Records Management, Security, Third parties, Value, Vendors
This blog explores, from time to time, the outer reaches of the intersection(s) of Information, Governance, and Compliance.
Consider, for a moment, a fingerprint. Not what you normally consider “information.” And one seldom thinks of “managing” a fingerprint. Who owns your fingerprint? But consider the value of a fingerprint, and both the failure to “manage” or control where that fingerprint can be found and the ability to find that fingerprint and locate its owner. How much information governance is involved in this process?
“Fingerprint Leads to Arrest Of Bomb Suspect in Florida,” The Wall Street Journal, October 27, 2018 A1. Alleged mail bomber’s fingerprint in a package sent to a legislator leads to arrest of suspect.
Which leads me to the question,”What is there that isn’t information that is managed or controlled in our lives, or a least directly related to information that is managed?” I struggle to find an example of something that isn’t information, or directly related (perhaps somewhat remotely) to information that is managed or controlled.
Filed under Access, Accuracy, Analytics, Collect, Compliance, Controls, Data quality, Definition, Duty of Care, Governance, Information, Management, Oversight, Ownership, Records Management, Risk assessment, Use, Value
“Delete Old Digital Haunts,” The Wall Street Journal, October 15, 2018 B4. A how-to guide on how to clear out the electronic information and the applications you don’t use any more.
Part of information governance is getting rid of data that we no longer need (and that is no longer required by law) – goes by the catchy title Defensible Disposal. A part of governance is how we manage this (or not) in our own lives. If you don’t do it in your own life, how can you be expected to do it at work?
Sometimes tracking is a good thing.
“Tech to Track Errant Kegs,” The Wall Street Journal, June 21, 2018 B4. Sensors installed to reduce 10% shrinkage rate from theft or misplacement of beer kegs. Could also track temperature.
Do you track similar information? Is this more or less valuable than knowing what records you have and where you have them?
When decision-makers want information upon which to make decisions, they would like to that that information be current, accurate, and complete. Don’t we all?
“Court Backs Purge of Voter Rolls,” The Wall Street Journal, June 12, 2018 A3. Supreme Court allows Ohio to prune its voter rolls of people who haven’t voted in a long time and who don’t reply to an inquiry as to their status.
One would expect the government would take some care in maintaining its voter rolls. Helps provide some integrity to the process. Is that information governance? But we want to make sure there’s a robust process to prevent inappropriate pruning.
Is this an analog for defensible deletion?
A fascinating area for exploration is the drafts that led to the final version. The dates, the wording, the recipients. Why do people keep drafts? Just because?
“Comey Originally Tougher On Clinton, The Wall Street Journal, November 7, 2017 A5. A Republican Senator discloses that Comey’s early draft of the exoneration document used the language “grossly negligent,” the statutory test.
I’ve referred to July 5, 2016 as the Day that Information Governance Died. That’s when the Director of the FBI announced his decision not to prosecute someone who had routinely violated the rules on handling secret documents, because “no reasonable prosecutor would bring charges.” Not to get into the politics of things, but how can you argue that following the rules is required when the Secretary of State isn’t held to the standards that apply to a Navy seaman?
That being said, why do people hold on to drafts? Because it’s easy? Or because it’s hard to get rid of them? There is seldom a reason to retain them beyond when the document is final. Maybe a phrase or a paragraph. But the entire document? How can we convince people not to keep drafts?
Filed under Compliance, Controls, Corporation, Discovery, Duty, Employees, Governance, Internal controls, Legal, Records Management, Risk