Risk & Compliance

“If you think compliance is expensive, try noncompliance.”
- Former U.S. Deputy Attorney General Paul McNulty

Businesses in virtually every industry are facing mounting regulatory compliance issues driven by legislation, financial audits and litigation, yet companies continue to retain and store critical business records on paper despite the risks that it poses. Here is where technology begins to play an important role.

Beefing up information access control

Even a locked file cabinet or file storage room can be broken into. A robust document management application requires robust user authentication with IDs and passwords to retrieve, view or share documents.

Auditing is an essential component to compliance and risk mitigation

To protect your business from compliance violations and penalties, it's essential to have the ability to track and report which users viewed, annotated or deleted a document. Simply scanning documents onto a server or filing images in encrypted folders won't cut it - you need a comprehensive document management system that provides user or document tracking and reporting.

Putting these monitoring and auditing capabilities in place is more than half the battle in ensuring compliance. A centralized document management system helps streamline any potential needs that may stem from audits or litigation (e-discovery) and limits the possibility of missing documents, which could expose your business to fines or judgments. A well-maintained document management system can offset considerable legal discovery and audit costs by making relevant business records readily available.

Regulatory need-to-knows

  • HIPAA: This security rule for affecting any business offering or managing healthcare plans, effective April 21, 2005, requires best practices for assuring the confidentiality of electronic patient data, available as needed and maintained with integrity intact. Penalties for non-compliance: fines up to $250,000 and imprisonment up to 10 years.
  • Sarbanes-Oxley Act: For public companies, provides requirements for audit committees, financial reporting, insider trading, executive loans, change disclosure and management's assessment of controls. Penalties for non-compliance: fines to $5 million and 20 years' imprisonment for destroying e-mails.
  • Gramm-Leach-Bliley Act: Requires financial services companies to implement safeguards for customers' current and legacy information. Penalties for non-compliance: fines of up to $10,000 and up to five years' imprisonment.
  • Payment Card Industry: Requires that any company collecting credit card information keep cardholder data secure and have processes in place for protecting and monitoring access to data. Penalties for non-compliance: fines between $5,000 and $100,000 per month.
  • SEC 17a-4: Gives retention periods for securities broker/dealer records; stipulates requirements if electronic record-keeping systems are used. Penalties for non-compliance: fines up to $500,000 and imprisonment.
  • The Patriot Act: Requires that identifying information used to open bank and credit card accounts must be maintained for five years after the date the account is closed. Penalties for non-compliance: fines of up to $1 million and imprisonment.
  • IRS Rev. Proc. 97-22: States that an electronic storage system must ensure an accurate and complete transfer of the hardcopy or computerized books and records to an electronic storage media. An electronic storage system must also index, store, preserve, retrieve, and reproduce the electronically stored books and records.
  • 21 CFR 11: Defines the recommendations for managing audit trails, access control and electronic records retrieval for healthcare and pharmaceutical companies.

How We Ensure Compliance: Curlew Hills Case Study 

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What would happen if a disaster struck tomorrow - or an auditor paid you a visit?