International Records Retention

Optimize your global records management effort, reduce cost and mitigate risk

A challenging regulatory environment has emerged within the past decade impacting the way global organizations handle their data. Many laws and regulationsmandate that companies manage their electronic and physical records more carefully and in a more sophisticated manner than ever before.

In developing and advancing an enterprise records management strategy,organizationswith global operations are nowrequired to develop retention rules that reconcile domestic e-discovery with foreign privacy law requirements. Companies must also contend with an avalanche of information spread across many jurisdictions and technology platforms, all while juggling competing legal requirements, diverse organizational processes and priorities, and limited financial and human resources.The task is daunting, even for companieswith strong domestic records management programs.

Your Current Challenges

Risk: The risks familiar to companies in the United States have world-wide relevance. Many, if not all countries, have commercial codes, tax, HR, and environmental laws that affect records retention and several have enacted ethics laws similar to Sarbanes-Oxley, including Japan, Australia, and Canada. Wherever business is conducted, failure to comply with the local laws regarding recordkeeping can put your company at risk of fines, sanctions, and other penalties. Equally important is the risk of brand impact, where organizations have much to lose in the public eye and can suffer significant losses at the hands of customers and investors.

Cost: The traditional approach to recordsmanagement froma legal records retention perspective is an exhaustive multi-jurisdictional legal review. Where many countries are involved, this can be prohibitively expensive. Performing country-specific legal research in all the countries where the client does business, in order to ascertain records retention requirements, may be an unnecessarily costly method of mitigating risk. Instead, Iron Mountain' s approach is to determine international records retention requirements by balancing risk and cost.

Complexity: Organizationsmust address the complexities of working with different legal systems, languages, and business practices across the globe. They must account for challenges associated with the processing and retention of information, which include data privacy, cross-border data transport, security standards, and restrictions on certain media storage formats. Many physical records that were managed locally have now become digital records that are managed globally.

Iron Mountain: Your Global Partner

With over 55 years of storing, managing and protecting information of all kinds, Iron Mountain is a trusted partner to more than 100,000 corporate clients throughout North America, Europe, Latin America and Asia Pacific, and recognizes the challenges of getting and staying compliant with international retention requirements. Iron Mountain' s Consulting Services complements our core services by helping you organize,manage and control your information and specifically address the challenges with building an International Records Retention Schedule.

Baker & McKenzie: Global Law Firm Partner

Iron Mountain partners with the global law firm Baker & McKenzie to review and finalize the retention requirements. Baker & McKenzie has been providing legal advice to global organizations for over 50 years in 38 countries. Their role is to review the international “baseline” retention schedule using in-country attorneys who have the requisite knowledge about local laws and regulations.

CONSULTING SERVICES APPROACH

Iron Mountain' s Consulting Services will help your organization build an International Records Retention Schedule by:

• Establishing the existing United States records retention schedule as the “baseline” for identifying business functions, record classes, and retention conclusions
• Determining the record classes that are relevant to the business functions performed in the targeted countries
• Receiving retention validation and/or exceptions with the legal authority and the supplemental guidance from local experts
• Enabling consistent global compliance by identifying exceptions based on specific countries and risk
• Performing a legal review of the specific record classes relevant to the targeted countries, and either confirming the “baseline” retention requirement or identifying where longer retention is required
• Providing web access to the legal research documentation, and
• Reviewing the relevant recordkeeping requirements and business practices and provide a report of its findings for each of the countries,utilizing the expertise of Baker & McKenzie.

IMPLEMENTATION SERVICES

Once the international Retention Schedule is finalized, Iron Mountain' s Consulting Services provides a variety of services to assist in its implementation. These services include:

• Implementation of international retention schedules into Iron Mountain' s SafeKeeperPLUS records management system
• Development of eLearningmodules that communicate to employees how to use the Retention Schedule and adhere to records policies
• Assistance in integrating the retention schedules of acquisitions
• Guidance on international records program infrastructure, communications, and training.

Iron Mountain' s Consulting Services enable businesses to retain and dispose of records in compliance with your organization' s relevant laws and regulations to develop an International Records Retention Schedule that is comprehensive and legally credible. This can help your organization to comply with recordkeeping and privacy requirements to control email to reduce litigation risks, protect confidential data to reduce reputation risks, and manage escalating paper and electronic record volumes to reduce storage costs and complexity. For more information about building an International Records Retention Schedule, please contact your Iron Mountain Consulting Services representative at 800-899-IRON.

Iron Mountain operates in major markets worldwide, serving thousands of customers throughout North America, Europe, Latin America, and Asia Pacific. For more information, visit ourWeb site at www.ironmountain.com