IG, Regulations & Compliance

The Psychology of Records Management: Energize Compliance with Forcing Functions

IG, Regulations & Compliance

The Psychology of Records Management: Energize Compliance with Forcing Functions

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With what? Never heard the term “Forcing Functions” used in Records Management (RM) or Information…

With what? Never heard the term “Forcing Functions” used in Records Management (RM) or Information Governance (IG). Well, Forcing Functions are THE most powerful tool at your disposal in Energizing Compliance. I first learned the term “Forcing Function” in a Systems Engineering course. It was likened to a battery “pushing” current around a circuit. Wikipedia offers the following applicable definition “Any task, activity or event that forces you to take action and produce a result”. So the point is to take an Information Governance or Records Management action that forces departments and individuals to respond with an action that improves their compliance.

As a Corporate Records Manager, there was a time when we had just approved our new Records Management policy that required active workforce compliance. The workforce was tasked with moving their electronic Official Records into an Approved Recordkeeping System (ARS), or assigning Record Class Codes and the year of creation to their departmental shared drive folders (effectively another ARS) (Note: a prerequisite for this type of initiative is a comprehensive Records Retention Schedule [RRS] so that there is an assignable Record Class [and therefore a retention requirement] for each and every record. The workforce was predictably slow in complying, and there were any number of sub-drives and folders for which a current owner could not be identified.   In partnership with the Chief Information Officer, a forcing function was set in place to force the workforce to comply. We determined to close all of the existing Shared Drives, and open a new directory of Shared Drives for new and transferred files – requiring assigned Record Class Codes with the year of creation. We set a one year termination of the existing shared drives to allow plenty of time for individuals and departments to carry on their primary business activities as well as migrate the needed records to the new shared drive(s). If you didn’t move it; by definition you didn’t need it, the business didn’t need it, and it would be deleted.

As you have likely concluded by now, Forcing Functions commonly require strong support from the business, so a Records Manager typically would not be able to take the initiative and do this on their own. If you have a Steering Committee or a Governance Council, these would be great places to plan, support, promote, and monitor the implementation of a Forcing Function.

We also used a Forcing Function to change our email practices and achieve compliance. In reality, Forcing Functions are almost a requirement when it comes to changing email behavior. We choose to use a Forcing Function on the existing email system, retaining the same account structure, but gradually, through a series of incremental steps, establishing new requirements and forcing compliance. Our starting point (might sound familiar) was individual email accounts with no limits, no standardized structure, and personal choice for disposal. If some individuals chose (and a few did) to keep all of their emails from the date of their employment, they would have a very large account. Our end point was to establish a common maximum account size for all, provide a “safe haven” for Official Records, and subject the rest of the emails to an auto-delete function.

To begin, we reviewed the size of the email accounts and set an initial limit that only impacted a small percentage of accounts. We allowed sufficient time for those accounts to reach those limits with a good faith effort, and also (very important) provided some email management tips to identify email reduction strategies to help individuals dispose of or relocate emails. We also established an exception process, whereby for business reasons, individuals, on a case by case basis, could temporarily be granted an exception to the current requirements until their business need subsided and they were able to rejoin the schedule of email maximums. Each time the maximum was lowered, new tips were provided to facilitate individual compliance. During this process, individuals with Official Records in their email accounts were able to set up within their email account, identifiable retention folders identifying the Official Record contents, exempting that folder from the auto-delete functionality. Allowing sufficient time for individuals to reduce their email, providing guidance on how to reduce email, providing a “Safe Haven” for Official Records, and providing an email limit exception process for business reasons, proved to be a potent and successful approach in achieving our objective.

Forcing Functions, while the most intrusive approach into normal business operations to energizing compliance, are sometimes necessary where a significant change in process for improved business efficiency and consistency is required. Introduction of new technology such as a Document Management System (DMS) or an Enterprise Content Manager (ECM) is a type of forcing function that usually meets with minimal cultural pushback. People typically like new technology. Pushback for new technology typically comes from an unprepared workforce and/or an overly aggressive implementation. I’ll talk about that next time as I conclude this sub-series with “Energize Compliance with Technology”.


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