Our client needed to improve its data lifecycle management, specifically the preservation and subsequent deletion of data required in support of legal matters. Defining the set of legal holds and fully scoping the data to be preserved was a slow and manually intensive process. A team of 100+ eDiscovery technologists was using ill-suited internal and third party tools in a globally inconsistent manner, whilst elsewhere in the organisation, a strategic refresh of the client’s Records Management archiving platform was underway. All this was happening under the spotlight of the EU General Data Protection Regulation (GDPR) implementation.
How Citihub Consulting Helped
Citihub Consulting helped scope and deliver a Defensible Disposal programme over an 18 month period. This included the establishment of programme governance, communications and planning. Citihub Consulting subsequently managed the “front to back” project workstream, tasked with identifying the requirements of the legal, eDiscovery and technology teams to then define the target state for legal hold management and the preservation and disposal of data.
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The solution had to take into consideration the client’s existing retention and disposal policies, as well as mapping data types to the client’s detailed and complex record retention taxonomy already in place. Consideration also had to be given to the appropriate method of data preservation for both structured and unstructured data: an architecture was needed for systems which could “preserve in place”, as well as other systems which required a “collect to preserve” capability, with data being copied into a dedicated legal hold preservation store.
Citihub Consulting also worked closely with the client’s Records Management team to ensure the solution successfully integrated the needs of the legal team with those of the strategic archiving platform, whilst also incorporating the effective management of Personally Identifying Information (PII) relating to the EU GDPR.
The outcome was a successful scoping of all legal holds within the bank (some dating back over 50 years), along with a vendor shortlist which the client’s vendor management partner could take to RFP for final selection and deployment. A deployment roadmap and delivery project plan was established for the client’s internal team to deliver over the remainder of the 3 year programme.