“Our team has conducted data migrations for highly regulated enterprises that range anywhere from one to ten petabytes, which is billions of files,” explains Rohit Khanna, the Chief Customer Officer at Smarsh. This immense amount of data cannot be handled with a simple drag-and-drop action.
Despite technological advancements and the availability of sophisticated cloud infrastructures, the process of moving and storing such vast quantities of information is anything but straightforward. Each step carries the risk of costly errors that can cause irreparable damage to an organisation. Data migrations can be especially complex for organisations in highly regulated sectors, such as financial services, where the stakes for data integrity and security are even higher.
Why are archive data migrations so complex? Specifically electronic communications compliance archive migrations.
This complexity results from the need to handle the data in a way that ensures a faithful copy of the original message in accordance with regulatory guidelines and FRCP (Federal Rules of Civil Procedure). Additionally, stringent data privacy regulations such as GDPR (General Data Protection Regulation), POPIA (Protection of Personal Information Act), and CCPA (California Consumer Privacy Act) mandate strict protocols for the handling, transfer, and storage of personal data. Non-compliance can result in significant financial penalties and reputational damage. It is important to note that mistakes here are extremely costly, and organisations might not get a second chance. An organisation’s process design must be legally defensible if challenged by regulators or during litigation. Fines for defensibility failures can range from the millions to over a billion dollars.
The challenge of migrating electronic communications data should not be underestimated. The vast volumes of data stored for compliance purposes have slowed enterprise archival architectures for decades, making these six steps essential for successful electronic communications archive migration:
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Data Harvest / Extraction
This first step is critical to ensure a successful data migration. It requires meticulously extracting data from diverse sources ranging from various legacy products and standard file formats to custom-built sources. Given the high stakes of compliance archives, it’s paramount that this step is executed precisely, ensuring that a faithful representation of the original data is maintained. This precision is crucial for meeting regulatory guidelines and maintaining the integrity of the data throughout the migration process.
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Processing
Once data is harvested, it undergoes processing. Unlike traditional data manipulation, which may involve transformation, this step focuses on producing a copy of the data that is faithful to the original. This nuance is critical in electronic communications compliance archives, where any alteration could compromise the data’s defensibility. The challenge lies in maintaining the integrity of the message while preparing it for the following stages of migration without any transformation that could be challenged under legal scrutiny.
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Ingestion
The third step involves securely transmitting the data to its new archive destination, where it is archived and indexed appropriately. Ingestion must be conducted to ensure not only the technical relocation of data but also its accessibility and searchability post-migration. This requires a thorough understanding of both the source and destination environments to preserve data integrity and usability, in accordance with the stringent requirements of regulatory bodies.
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Reconciliation
Reconciliation is the process where each message is accounted for to achieve 100% accountability and minimise exceptions to as close to 0% as possible. This step is fundamental in confirming the migration’s accuracy and completeness. The reconciliation process demands meticulous attention to detail to ensure no data is misplaced, altered or lost during migration, maintaining its legal defensibility.
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Chain of Custody
Establishing a defensible chain of custody involves creating a complete, auditable trail for each message. This trail must be robust enough to withstand scrutiny under regulatory standards set by the FCA, FRCP, SEC and FINRA, among others. Achieving this requires close collaboration with customer compliance and legal teams to ensure the audit trail meets regulatory requirements and is explicitly approved by all involved stakeholders.
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Validation
The final step of the migration process includes a thorough validation of the migrated data. This responsibility is shared jointly with the customer and their legal and compliance teams. Validation confirms that the entire migration project meets the agreed-upon standards and regulatory requirements. This collaborative effort ensures that any potential issues are identified and remedied early, securing the project’s successful completion and the data’s ongoing compliance and integrity.
This migration process would be fast, straightforward and simple if organisations didn’t have petabytes of data in various formats and managed by various tools. However, the reality is that they do, creating a significant potential for things to go wrong.
Khanna emphasises that Smarsh has industry-leading experience migrating archives because it understands the importance of maintaining access to the archive data throughout the migration process. Smarsh data migration experts provide a bespoke service that gives customers the best solution for their archive requirements, says Khanna.
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