Novartis AG

Global companies face global headaches when it comes to complying with diverse country regulations for record keeping, privacy and compliance, and legal holds on data for litigation and regulatory inquiries. Not only do regulations differ from country to country— information and business needs for it vary widely from business unit to unit. Scott Bancroft, group head of Information Governance and Management and chief information security officer at Novartis AG (Novartis) understands this challenge and how to overcome it. At Novartis, Bancroft implemented a holistic information governance program with a global retention program at its backbone to scale across 154 countries with 256 corporate entities. The program complements the company’s rigorous eDiscovery process. The multinational pharmaceutical company, based in Basel, Switzerland, ranks three in sales among the world-wide industry with US$50.624 billion in 2010. The company has 119,418 employees and a diverse portfolio of healthcare products, including innovative pharmaceuticals, eye care products, generics, consumer healthcare products, and vaccines and diagnostic tools.

Information growth outpaced governance and records processes
Like other large companies, Novartis was experiencing tremendous information growth and already had enormous amounts of electronic and physical content, including paper and other physical materials such as lab samples. Novartis had an inefficient records and retention schedule originally designed for physical records that no longer applied to the company’s business and information environment.

“We have thousands of people around the world fractionally engaged in records management activities,” says Bancroft. The records management and schedule management processes were cumbersome and created challenges with audit findings. The inefficient use of resources across divisions and functions left employees unsure of their obligations. Inaccurate identification and declaration of records and unnecessary indefinite retention incurred excess risk and cost as information growth outpaced retention management and governance processes and capabilities.

“We kept almost everything,” says Bancroft. “Over-retention is as big or bigger problem than under-retention for us. By keeping documents beyond their legal retention period, we increase our risk and our costs. We needed a legally defensible disposition solution that addressed our information, regulatory and business environment; it needed to work seamlessly with our legal holds system because litigation can encompass large amounts of information and last eight to ten years. The IBM Retention Policy and Schedule Management and Defensible Disposal solution was a perfect fit and is seamlessly integrated with our legal hold system.”

IBM solution enables information governance efficiency and defensible disposal
Novartis initially evaluated a number of vendors. Says Bancroft, “We selected the IBM® Global Retention Policy and Schedule Management because it met all our requirements and it was easy to use and intuitive. When we tested it on our end user community, they found it easy to use and very convenient. We were also impressed by the professionalism and the knowledge of the IBM team.”

The system ensures that records disposal complies with national laws, regulations and company policies. It is a corporate-wide, cross-function, “electronic rule-book” to manage the retention and disposition of information assets. Novartis’ Global Master Retention Management System (GMRM) system enables individual teams and business groups to fulfill their legal and regulatory obligations and prevent over retaining (saving substantially on storage cost). It establishes a consistent ontology and records classification scheme globally and cross-divisionally while supporting the natural variations across business units and geographies. GMRM ensures a legally defensible retention and disposition scheme of information assets. “We have the evidence to show that we kept a document for the required period of time according to the geography and the local regulation that is in place, and we disposed of it in line with those regulations,” says Bancroft. “The adoption rate of disposition requests is somewhere below 9.1 percent at the moment. With the new system the current estimate is more than 90 percent because we have a legally defensible disposition schema.”

Achieving fast time to value
The implementation took less than four months, ahead of plan and exceeding expectations. For the initial focus of the GMRM project, Bancroft’s team examined corporate intellectual property using a maturity model with ratings from one to five, where one is a manual process with inconsistencies and five an automated, complete, transparent process that is integrated into the operation.

“In six weeks, we transformed the quality of records management and records retention in corporate intellectual property from maturity level one, the lowest, to maturity level five, the highest,” says Bancroft. “The head of corporate intellectual property has since become an ambassador for rolling this out to all the divisions and other functions.”

The system is now enabling Novartis to mitigate major information management risks and establish harmonized, globally functional retention schedules for both electronic and physical records. It helps Novartis ensure stakeholders have sufficient knowledge of information location, use and value, and it enhances its ability to meet internal audit standards and respond to legal requests. Effective disposition of records is already significantly reducing risk.

For more information
Contact your IBM sales representative or IBM Business Partner, or visit
us at: ibm.com/software/ecm/global-retention/

For more information on Novartis AG visit: www.novartis.com