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Delivering a Defensible Disposal Continuance Compliance Platform For a Tier-1 Bank

Our Tier-1 bank client needed to improve its data lifecycle management, including 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, while elsewhere in the organization, a strategic refresh of the client’s Records Management archiving platform was underway. All this was taking place in the spotlight of the implementation of the EU General Data Protection Regulation (GDPR).

The solution had to take into consideration the client’s existing retention and disposal policies, as well as mapping data types to the bank’s detailed and complex existing record retention taxonomy. Consideration was also necessary for 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.

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Enabling Data Lifecycle Management and eDiscovery

Citihub’s (a Synechron company) delivery of this program included:

  • Helping scope and deliver a Defensible Disposal program over an 18-month period, including establishment of program governance, communications and planning 
  • Subsequently managing 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/disposal of data
  • Partnering with the Records Management team to ensure successful integration of the needs of the legal team with those of the strategic archiving platform
  • Incorporating the effective management of Personally Identifying Information (PII) relating to the GDPR
  • Identifying and ratifying by legal counsel all legal holds across the bank for 2,000+ active matters, dating back over 50 years
  • Production of a vendor shortlist for three products (whittled from 80+ vendors) using Citihub’s Accelerated Vendor Discovery process, which the bank’s vendor management partner could use for RFPs and final selection 
  • Capturing the requirements and defining the target state for legal and eDiscovery teams, and establishing Business Requirements Documentation and User Story details
  • Establishing a deployment roadmap and delivery project plan for the internal team to deliver over the remainder of the 3-year program
GRC Capabilities
Remediation to achieve
Heightened system maintainability
Increased ROI by 25
Reduced overall complexity by 45

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