Configuring fixed content device (FCD) disposition sweep

IBM Enterprise Records 5.2.1.2 now provides support for the SEC 17a-4 rule of the US Securities Exchange Act. Compliance with this rule ensures that the content of documents is tamper-proof during their life cycle. This capability facilitates coordination of records management with the SEC requirement to store documents on Write Once Read Many (WORM) devices. This document has information on the steps involved in using this new feature.

Before you begin

The software required to use this feature is:
  • IBM Enterprise Records 5.2.1 fix pack 2 (5.2.1.2) or later
  • Content Platform Engine 5.5.2 interim fix 1 or later

About this task

The fixed content device sweep utility is a utility for configuring disposition settings and running disposition sweep on categories defined in an fixed content device file plan.

IBM Enterprise Records 5.2.1.2 is equipped for managing records on fixed content devices even when retention is enabled on the device. This new capability facilitates the coordination of retention dates between IBM Enterprise Records and the fixed content device.

In IBM Enterprise Records 5.2.1.2 a new Fixed Content Plan option has been added to identify that a file plan is to be used with a fixed content device. The fix pack also introduces a new sweep to be used with Fixed Content Plans. When the fixed content device sweep is run, retention dates are set on the document. This setting is then propagated to the fixed content device if the Content Platform Engine is configured in aligned mode. With this new type of file plan, per SEC requirements, retention dates can be extended but not reduced.

How the fixed content device functionality works

The fixed content device functionality is similar to the functionality available for the basic disposition sweep, with some deviations to deal with the specifics required to meet the SEC-required use of fixed content storage devices. When the fixed content device sweep is run, the following intermediate operations are performed:

  1. For each container, the retention period is determined.
  2. Calculations are made to determine the retention date for each document.
  3. The retention date is set on the actual document (not the record) for the relevant documents. When the retention date is set on the document, the value is passed to the fixed content device by the content platform engine.
  4. After setting the retention date, sweep identifies all the records eligible for deletion by comparing the retention date with the date on which the sweep is run.
  5. Then all the eligible records are deleted by sweep.
As the fixed content device sweep is modeled after the basic disposition sweep, it does not support many of the advanced disposition features such as:
  • Cut-off date
  • Out-of-the-box (OOTB) workflows
  • Alternate phases
  • Initiation of disposition
  • Grouping items by reviewer

There are some scenarios in which the fixed content device sweep fails to update the retention date:

  • The existing retention date set on the document is later than the one that the sweep needs to set on the document.
  • The document has been marked for permanent retention.

To use this capability, the fixed content device should be configured:

  • In aligned mode so that the content platform engine passes the retention settings to the device.
  • For event-based retention or with minimum retention settings that are compatible with the expected record life cycle of the document.

In addition, consider using the hold capability that can be assigned to storage areas in the content platform engine administrative console. A device hold ensures that documents cannot be deleted from the storage side even if retention is not set on the document. Refer to the following topic in the IBM FileNet® Content Manager documentation for more information on the device hold facility: (V5.5.2 and later) Using device holds.

Assumptions

The following sections of this document assume that:

  • IBM Enterprise Records 5.2.1.2 is installed
  • There is at least one Record Object Store (ROS) and one File Plan Object Store (FPOS) configured
  • The IBM Enterprise Records desktop in IBM Content Navigator has been configured
  • A suitable fixed content device has been configured
  • Document classes in the Record Object Store (ROS) have been updated to ensure content is stored on the WORM (fixed content) device

Overview of steps

  1. If one is not already configured, use the IBM Administration Console for Content Platform Engine (ACCE) to add a Fixed Device definition to your P8 domain.

    Refer to the Fixed Content Device topic in the IBM FileNet Content Manager documentation for more information: Fixed content devices.

  2. If a Record Object Store (ROS) is not already configured, use IBM Administration Console for Content Platform Engine (ACCE) to add an object store.
  3. Configure the record object store to:
    1. Include new storage areas that use the fixed content device configured in step 1.
    2. Set the device hold option on each storage area.

      If this option is set on an existing storage area, then only newly ingested content will be place on hold.

      Refer to the IBM FileNet Content Manager documentation for more information: (V5.5.2 and later) Using device holds.

    3. Assign the storage areas to the document classes that will be used to store content that needs to be declared as records.
  4. Add a File Plan Object Store (FPOS) if one is not already configured.
  5. If this is a new installation, complete the IBM Enterprise Records installation and configuration steps and then install IBM Enterprise Records 5.2.1.1 followed by 5.2.1.2.

    Refer to the IBM Enterprise Records documentation, as well as the fix pack Readmes for more information: IBM Enterprise Records installation and upgrade.

  6. If this is an existing IBM Enterprise Records installation, upgrade to IBM Enterprise Records 5.2.1.2 and install the fixed content device add-on provided with IBM Enterprise Records 5.2.1.2.
  7. Add a fixed content device file plan and declare records that use this file plan.
  8. Use the fixed content device sweep utility to manage the life cycle of the records in the fixed content device file plan.
  9. Generate reports to validate records are being handled correctly.

Known issues and limitations

To ensure SEC 17a-4 compliance ensure the following:

  • Do not decrease the retention period once it is set.
  • Do not file records in multiple categories.
  • Only use the new fixed content device disposition sweep with categories that are in an fixed content device file plan.