At the centre of document related processes in any organisation is the core function of “How to produce the statutory documents that all business must have and send to their clients”. In most companies the ‘money related’ documents are produced directly out of the core business driving IT systems. This task is often called various things. Commonly used names include document generation, document composition, report production, word processing / mail merge and document management. Essentially they are all the process through which data (information about the recipient) and communications content are intelligently put together to automatically produce a business document.
Common documents produced in by insurers include quotations, policies, statements, reporting, renewals, wordings, reminders, cheques and remittance advices, and statutory letters. Typically the underwriting, broking and claims processing systems generate these documents and use an output generation tools supplied with those systems. Where there exist multiple lines of business systems, you will often find multiple ways of creating documents.
Risk Mitigation for Insurers Document Generation, Archiving and Records Management Abstract: This paper discusses some of the key issues for document generation, archiving and records management in the insurance industry and in particular reflects on the impact of recent UK FSA Insurance Conduct of Business Regulations (ICOB) and the impact this is having on these disciplines. Tim Nelms Principle Consultant, ERM and Archiving - EMEA EMC September 20, 2006Untitled DocumentUntitled DocumentRisk Mitigation for Insurers 1 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Contents Contents 1 Business Issues 3 Overview 3 Purpose 4 Document Generation Issues 5 Document Generation Compliance with ICOB 7 Commentary on ICOB Rules and Guidelines and Relevance to Document Generation 8 Quality of Communications 9 Personalization 10 Marketing - Up selling and Cross selling 10 Volume Issues 11 Trends in Document Generation 11 ASCII Line Printer Output 11 AFP and Metacode 11 Output Management and Reporting 12 Dynamic Content 13 Archiving Issues 14 UK Insurance Records Compliance with ICOB 14 Commentary on ICOB Rules and Guidelines and Relevance to Document Archiving 15 Trends in Archival 16 Paper Archival 16 Computer Output to Microfiche (COM) 16 COLD 17 Mainframe Silos 17 Enterprise Report Management 17 Archiving Standards Review 18 Digital Archival Requirements 18 Untitled Document2 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Adobe Portable Document Format as a Digital Archival Standards 19 Volume Issues 19 Records Management Issues 21 Access and Retrieval Compliance with ICOB 21 Volume and Scalability - Search and Retrieval Issues 21 Reprinting 22 Records Management 22 Version Management and Auditing 22 Integrating Document Generation, Archival and Records Management 22 Summary and Contact Information 24 EMC 24 EMC Centera Storage Solutions 24 Document Sciences 24 Further Information 25 Untitled DocumentRisk Mitigation for Insurers 3 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Business Issues Overview The insurance industry has its own unique pressures in addressing the diverse needs of customers, shareholders and regulators. This document does not address the subject of the wider business challenges for UK insurers but instead focuses on specific issues in relation to the document management and creation processes and reflects on how these disciplines impact on some of the wider business issues particularly around risk management and compliance. Risk management is what the insurance industry is all about, however now there are new risks posed by regulatory changes that are affecting insurers all over the world. In the UK the FSA s Insurance Conduct of Business rules came into force in January 2005 and give rules and guidance for the conduct of non-investment related insurers. In particular the guidance effects how companies create and manage correspondence with customers, which means it must meet content guidelines set by the FSA and be retained in case of possible litigation. ICOB compliance records management guidelines mean that insurers must have in place corporate policies for records retrieval and retention and understanding of these issues for all the different types of business document. For example generic corporate product collateral will have different record retention characteristics than individual policy records. FSA guidelines in particular provide some minimum criteria by which these policies should be defined. It is now more important than ever to have electronic access to all kinds of documents, but the fact is that electronic media make the chances of litigation more likely rather than less likely. Last year alone US insurers faced on average 130 legal actions in relation to policies and spent between 20-100m each on handling discovery in relation to these actions. Such discovery challenges are not unique to the US - European insurers face similar demands to produce information whether it is in paper or electronic format. The process of sifting through electronic records such as customer correspondence, scanned documents, emails and office documents held in IT systems has been termed eDiscovery. eDiscovery represents a significant challenge to businesses needing to find documents which are often held across separate information silos. The ability to find and retrieve such documents is often limited to skilled IT personnel which makes the process of discovery both more costly and time consuming. Without better information management of electronic documents such costs will rise as information held in these electronic formats multiplies. What businesses need is an integrated process covering document capture, classification, records management and retrieval that covers all their information. One of the big exposure areas for insurance companies globally is "sales practices", i.e.., making sure the sales force/brokers are not misrepresenting insurance products. Content management, forms management, and BPM technologies can come together to create an auditable sales processes which can be used to demonstrate a companies 'best efforts to be compliant with the law. In fact the ability to use technology to create standard processes for information management directly addresses a long standing request from corporate council and compliance managers alike for defensible business practices in all of the key areas of the insurance business. Untitled Document4 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Purpose This paper discusses some of the key issues for document generation, archiving and records management in the insurance industry and in particular reflects on the impact of recent UK FSA Insurance Conduct of Business Regulations (ICOB) and the impact this is having on these disciplines. We also seek to look at the positive benefits of well managed documents and how they can help improve customer services and reduce costs associate with difficult to manage paper-based processes. This paper covers these topics through the following sections " Document generation issues - meeting the expectation of customers and ICOB content and presentation guidelines " Archiving issues - understanding archiving trends and how modern archiving needs to be integrated with customer centric document processes " Records management looks at how integrated content repository and records management satisfied regulatory requirements for records retention and can also provide a 360 view of information for the entire organisation Untitled DocumentRisk Mitigation for Insurers 5 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Document Generation Issues At the centre of document related processes in any organisation is the core function of How to produce the statutory documents that all business must have and send to their clients . In most companies the money related documents are produced directly out of the core business driving IT systems. This task is often called various things. Commonly used names include document generation, document composition, report production, word processing / mail merge and document management. Essentially they are all the process through which data (information about the recipient) and communications content are intelligently put together to automatically produce a business document Common documents produced in by insurers include quotations, policies, statements, reporting, renewals, wordings, reminders, cheques and remittance advices, and statutory letters. Typically the underwriting, broking and claims processing systems generate these documents and use an output generation tools supplied with those systems. Where there exist multiple lines of business systems, you will often find multiple ways of creating documents. There are also the subsidiary systems that insurers will need in order to support client facing functions, marketing and sales support, training and technical publications. Documents produced by such systems include: " client communications and marketing letters and information direct mail included " customer relationship management documents from the CRM system " web generated documents that might be sent to the client still on-line or followed up with in the post, or both from the web portal " training manuals The central point is this - when you consider that all these documents, applications, sources and destinations have a mixture of required individual content elements it is important that all the required content is consistent, compliant, managed, version controlled, accessible, and, meets corporate standards for image, look and feel. In an average sized insurance company this usually amounts to between 5,000 and 10,000 individual pieces of content (standard paragraphs, images, variable data elements, clauses, headers/footers, signatures, etc) across the organisation. In smaller organisations this may only be 500-1000 components but the compliance requirements are fundamentally the same. Finally, if you add the fact that many companies have operations in multiple countries then the content elements to be managed can be multiplied but the number of countries requiring their own language in the documents produced. Another area for consideration is: How else do documents need to be generated in your organisation? For example: " If you have a call centre, how do your customer service operatives generate their responses to customer calls? Is it from standard word templates? Do those templates use the same source of standard content pieces as the underwriting or claims systems? Can they automatically include relevant marketing materials for cross or up-selling purposes? If the customer wants to have special extra words in the response being generated, how are those extra wordings validated and secured? Is there an approval workflow in place to manage the approval process? Untitled Document6 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. " If you have documents coming into your company that result in business generation, which will then require responses to be produced, how is that managed? Do you scan inbound documents in? Is data automatically captured? Can that data generate the responses automatically in turn? In other words: Are all the parts of the document generation and management process linked intelligently together? . If they are, and you have a seamless process of management from input, straight through composition or document generation, validation, archive, distribution and receipt then you have succeeded in providing your company with a Straight Through Processing model. The challenge is for insurers to automate the processes needed to deliver high-volumes of complex documents to customers, while achieving the highest levels of document personalization and quality. Traditionally the costs associated with delivering high quality and highly personalized customer communications, relevant to risk type, client and product has been too high to justify such improvements. As always the need to control operational costs whilst maintaining operational flexibility and responsiveness to new business lines is a fine balancing act. The diversification of product portfolios and the requirement to comply with regulatory guidelines that govern what information must be provided to customers has had a dramatic impact on document generation processes. Delivering compliant, branded mass communications without manual intervention or Straight Through Processing (STP) as it is known is a significant challenge In this section we look at the following issues in relation to document generation for insurers: " Document Generation compliance with ICOB a commentary " Quality of modern communications " Personalisation " Volume issues " Trends in document generation practices Untitled DocumentRisk Mitigation for Insurers 7 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Document Generation Compliance with ICOB ICOB 1introduces rules and guidance for the UK which have a direct impact on the content and presentation of documents generated in support of non-investment insurance related products. The areas of guidance and the general area of interest are shown in the following table and as always it is best to refer to the specific guidance for detailed information about each of these areas. In general however it should be noted that the effect of ICOB on content is wide reaching this table can only give a flavour what is present in the full rules and guidance: ICOB Ref Summary General Rules 2.2.3 Clear, fair and misleading communications 2.2.6 Prominence of information 2.2.7 Legibility rules including use of colour, fonts and paper size 2.6.1 Durable medium guidelines (ie. Paper) 2.6.2 Electronic communications 2.8.6 Promotions and statements Advising and Selling standards 4.2.2 Durable medium requirements 4.2.6 Information contained in the contract 4.2.21 Durable medium requirements for mid-term adjustments 4.8.1 National language of documents provided to customers Product Disclosure 5.3.1 Before conclusion of non-distance contract information for customers 5.3.2 On conclusion of non-distance contract information for customers 5.3.3 Exclusions or limitations 5.3.4 After conclusion of non-distance contract information for customers 5.3.6 Before conclusion of a distance contract information for customers 5.3.8 On conclusion of a distance contract information for customers 5.3.9 Claims handling information for customers 1 Insurance Conduct Of Business published by the United Kingdom Financial Services Authority (FSA) revsion 37 Untitled Document8 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. 5.3.10 & 11 Repetition of information 5.3.12 & 13 Cancellation information and legibility 5.3.18 Renewal document timing requirements and durable media 5.3.21 Renewal document information requirements 5.3.24 Mid-term adjustment information requirements 5.3.29 Group policy information for retail customers 5.5.27 & 28 Policy document information requirements Table 1: ICOB rules and guidelines related to document generation Commentary on ICOB Rules and Guidelines and Relevance to Document Generation The ICOB rules enshrine recent European Legislation with respect to the Financial Services industry and as such ICOB represents an implementation of these European requirements. ICOB also includes UK requirements but in general it can be taken as a useful guide for pan-European implementation of insurance best practice. The ICOB rules and guidelines begin with some general principles: (1) When a firm communicates to a customer, it must take reasonable steps to communicate in a way that is clear, fair and not misleading (ICOB 2.2.3) The guidelines continue with specific advice on the presentation style of customer documents and how they should present information according to these principles: Prominence of relevant information can play a key role in ensuring that a communication is clear, fair and not misleading. Where this is the case, the FSA will assess prominence in the context of the communication as a whole. Use can be made of the positioning of text, background and text colour and type size to ensure that specified information meets the requirements of ICOB. (ICOB 2.2.6) A firm should make every effort to ensure that information is presented clearly, fairly and in a way that does not mislead, whether it is to be viewed as a hard copy, as an electronic document on screen or presented on some other medium (such as audio-tape for visually-impaired customers). A firm should: (1) use materials and design (including paper size, colour, font type and font size, tone and volume) to present the information legibly and accessibly, and in a balanced way; &. (ICOB 2.2.7) Reference is made to the need to use durable medium in certain circumstances to comply with the Distance Marketing Directive (DMD). In other words the document will need to be provided to the customer on paper. Much of the content of ICOB sections 4. and 5. deal with the substance or content of the various documents associated with insurance contracts in particular and not limited to quote packs, policy documents and mid-term adjustments. Untitled DocumentRisk Mitigation for Insurers 9 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Quality of Communications The introduction of new print technologies has allowed high volume printing of quality documents including the use of techniques not previously available in administrative customer communications such as graphics, colour and font. Generally consumer expectations regarding the quality of output have risen significantly in recent years and the difference between old style and new style documents are visible in the administrative documents we receive through the post: In particular the use of sidebars and highlighting has become a part of standard customer communications although the use of colours, fonts and graphics is still a subject for regulation under ICOB to ensure that these presentation devices are not abused or used to mislead consumers. The use of the modern presentation techniques can also help save space and reduce the size of documents produced, in particular ICOB places significant emphasis on the content of policy documents. These include cancellation rights, key features of policies, claims handling process, offers/ promotions, cancellation rights and statements of price. In all these regulatory changes to the content of policy documents has led to an average increase in size of policy documents by 30%. Untitled Document10 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Post R enewal R eminder(1 Page)N ew B usiness Policy Pack(8 Pages)R enewal Acceptance Pack(1 Page)R enewal Invitation Pack(8 Pages)Pre-renewal R eminder(1 Page)G uidelines on policy content have led to a 30% increase in policy document size Personalization Personalisation plays an increasingly important role in document generation processes because marketing groups must strive to provide more targeted communications to prospects and customers. It has long been the aim to differentiate between communications with the use of language and message in order to provide relevant and interesting communications. The goal of content personalisation is to achieve optimal levels of relevance by matching customer information and context with business rules and logic to establish context quickly, present information more efficiently and streamline the communication process. Customers should receive exactly the information they need, at the time they need it, using a communication channel that both reflects their personal preferences but which is also appropriate to the purpose of the communication, ie the right words the right information, at the right time and through the right channel. The communications are manifest in the myriad letters, statements and reports that form the basis of much customer communication, as well as interactive channels such as call centres, web portals and electronic messaging. A further issue for personalisation in a consolidating European market is the need to personalise language for cross-border communications. In particular the European directives upon which ICOB is based require insurers to provide administrative communications in the relevant European language. Marketing - Up selling and Cross selling The improvements in the quality of communications has also enabled insurance companies to be more sophisticated about how to up sell ad cross-sell products to customers although care must be taken to ensure that such offers comply with ICOB guidelines or other FSA guidelines for investment related products. Untitled DocumentRisk Mitigation for Insurers 11 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Volume Issues Generating documents for large number of customers can pose its own logistical problems. Consider a typical insurance company with 500,000 policy holders holding on average 1.5 policies per customer. Assuming each customer requires a standard range of communications each year between 10 and 15 pages of communication will need to be produced. The volume of pages per day can be expressed as follows and would equate to around 20,000 pages of output a day for the above example: ingDaysNumberWorkageAveNumberPcyHoldersNumberPoligesVolumeofPa= The volume of documents per day can be expressed as and would be around 6,500 per day for the above example or approximately 2 million each year: rkingDaysNumberofWocumenTypesNumberofDocyHoldersNumberPolicumentsNumberofDo= Clearly producing documents in quantity and ensuring that they are printed and dispatched is a significant issue for insurers. Trends in Document Generation Document generation is the class of application that captures the output of IT systems and presents it in a format suitable for delivery to devices such as printers. Because document generation has traditionally been built into core business applications it received relatively little recognition as a function in most enterprise software applications until the early 1990 s. ASCII Line Printer Output Early reporting and document generation processes produced reports with ACII line printer style presentation qualities with very limited opportunities for techniques like graphics and variable fonts. Reports would usually be output on pre-printed forms to company standards with the result that many companies had to have large amounts of stock paper for different purposes. Even today many corporate reports and output still use ASCII line printer style output. The applications which produced this output were often handcrafted in 3GLs such as Cobol, PL/1, SQL and C and whenever changes to the report were required programmers would need to be involved to customise the program. AFP and Metacode Advanced Function Printing (AFP) was introduced by IBM to allow high-end printers to produce output with high quality presentation characteristics such as graphics, fonts and barcodes. The techniques employed by AFP even allowed forms to be customised through configuration although programming was often required. The ability to address all parts of the page is known as All Points Addressable (APA) and other manufacturers have since introduced their own APA formats such as Xerox's Metacode, Hewlett Packard's Page Command Language (PCL) and Adobe s PostScript. These Page Description Languages have made it possible to add rich graphics and presentation qualities to printed documents. Untitled Document12 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Without separate document generation processes however these features are difficult to utilise and can be costly to run and maintain. Output Management and Reporting Over the past 15 years there has been a growth in the market for stand-alone document generation or output management tools that make it possible to extract and capture data from line of business systems and produce high quality printed output without needing to make costly changes to core business applications. There are many applications that provide output management capabilities, however, the growing demand for localisation, personalisation and even more demanding presentation qualities had led to the need for a new generation of application. Untitled DocumentRisk Mitigation for Insurers 13 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Dynamic Content Dynamic content is the term used to describe the requirements of modern document generation systems. Dynamic content marries the disciplines of producing high quality output with the ability to personalise content according to business needs. Dynamic content is the only way to meet the ever increasing demands of the consumers and regulators by fusing content and data into variable length documents. ASCII Text APA Output Output Management Dynamic Content High Volume Printers 3GL Programming Graphics Fonts 4GL Tools Distribution Personalisation Assembly Advanced Layout Untitled Document14 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Archiving Issues On the one hand document generation processes produce more documents in ever more sophisticated ways, but on the other call centres and customer services teams need timely access to customer communications so that they can deal with customer queries and comply with regulatory requirements to store and access information. The challenge is to automate the process of storing customer communication and make them readily accessible for compliance purposes and to customer services. Document archiving is the process through which computer generated documents (created by document generation processes) are stored and indexed in document management systems. Document archiving solutions typically incorporate the ability to convert print data into archival documents and extraction processes to burst and index large print runs. It is important to remember that 90% of the content volume which must be managed by UK insurers is produced by document generation systems and hence the same volume of information must be stored in document management by archiving systems. This chapter discusses some of the archival issues for insurers and begins by discussing some recent regulatory changes that companies must respond to. This paper examines the issues for archival process in the following topics areas: " Compliance with ICOB " Trends in archival technologies " Review of archive standards including PDF " Volume issues UK Insurance Records Compliance with ICOB ICOB has specific rules and guidance which determine the archiving requirements for documents generated in support of non-investment insurance related products. The areas of guidance and the general area of interest are shown in the following table and the specific guidance should be consulted for detailed information about each of these areas: ICOB Ref Summary General Rules 2.8.1 Rules regarding adequate records keeping 2.8.2 Inspection requirements by FSA 2.8.3 Time limits for FSA access 2.8.4 Generic documents 2.8.5 Method of storing records 2.8.6 Record retention periods Financial Promotion Untitled DocumentRisk Mitigation for Insurers 15 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. 3.9.3 Reproducing accurate representations of documents Product Disclosure 5.7.1 Record keeping 5.7.2 Generic document retention requirements 5.7.3 Record retention recommendations Schedule 1 1.1 to 1.3 Recommended retention periods Commentary on ICOB Rules and Guidelines and Relevance to Document Archiving ICOB includes Record Keeping rules guidelines which include some stringent requirements for companies regarding customer documents. In particular it is incumbent upon the insurer to be able to reproduce communications produced over a period specified in the rules. General provisions of the rules require that a paper copy of the contract should be capable of being reproduced at the customer. During the course of a distance contract with a retail customer, the making of which constitutes or is part of a non-investment insurance contract: (1) the firm must, at the retail customer's request, provide a paper copy of the contractual terms and conditions of the non-investment insurance contract; and& (ICOB 2.7.1) A particularly demanding area of the rules is the requirement for records to be accessible to the FSA within strict timescales. The records required in ICOB must be readily accessible for inspection by the FSA. (ICOB 2.8.2 ) A record would be "readily accessible" if it was available for inspection within two business days of the request being received. (COB 2.8.3) Records may include both specific customer communications such as policy documents or generic documents where the following rules apply. Where a firm keeps standard, generic documents as records it should be able to identify which version, by date or reference number, was provided to the customer. (ICOB 2.8.4) Specific guidelines to cover the keeping of electronic records and focus on the fidelity of the retained record being an accurate representation of the original document: (1) A firm may arrange for records to be kept in such form as it chooses provided the record is readily accessible for inspection by the FSA. (2) Where a firm chooses to maintain records in electronic form, it should take reasonable steps to ensure that: (a) the electronic record accurately records the original information; and (b) the electronic record cannot be subject to unauthorised or accidental alteration. (ICOB 2.8.5) Untitled Document16 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. A significant rule is ICOB 2.8.6 which covers retention periods and the need to substantiate that communications comply with content guidelines that could give rise to regulatory censure or claims some time after the inception of the contract. Each rule in ICOB that requires a record to be made and retained specifies that the record must be kept for a minimum period of three years. A firm should consider retaining records for longer periods in case customers complain or take legal action against the firm. A firm should, in particular, consider what constitutes an appropriate retention period for records which relate to non-investment insurance contracts which may give rise to claims some time after the inception of the contract (e.g. employers' liability insurance). (ICOB 2.8.6) Trends in Archival Archival and records management is by no means a new discipline and attempts by businesses to keep records of importance have been regularly under review since technology began to have an impact on records management in the early 1960 s. The need to store documents is driven by many factors, which vary from industry to industry. In Insurance the most demanding of information to store are communications with customers, which of course represent the vast majority of documents handled by any insurer. The following sections trace the history of enterprise report management back to the introduction of computer output to microfiche, discussing trends and innovations that have shaped archival solutions as they exist today. Paper Archival Many businesses still rely on hard-copy documents stored in filing cabinets and sometimes in long term depots to store information. Pound for pound it is the least efficient, most expensive method of storage however hard-copy archival does benefit from readily available media and a well-established set of guidelines for protecting the authenticity and security of documents. Few insurers could cope archiving the volume of customer documents generated as paper and require systems for archiving and accessing this information as follows. " Advantages availability of media, authenticity of documents " Disadvantages short lifespan, requires most physical storage space Computer Output to Microfiche (COM) The introduction of computer-enhanced microform technology in the late 60 s ushered in the first attempts to strategically replace paper storage with alternate media: Computer Output to Microfiche, or COM. Microfiche, flat sheets of film can hold the equivalent of 270 standard pages (there are a number of different storage densities). COM has the advantage of low reproduction and storage costs, but requires special devices for reading the text. Physical compression of data was a significant innovation, but improvements in accessibility were negligible. In addition, the earlier incarnations of COM were view only which meant that there was no print reproduction or distribution based off of COM. " Advantages long lifespan " Disadvantages relatively low density, requires investment in viewing aids Untitled DocumentRisk Mitigation for Insurers 17 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. COLD Computer Output to Laser Disk (COLD) was a radical innovation that still sees moderate use today. COLD replaced the analogue, photographic based reproduction of data with a more direct, digital transferral of data. Optical platters are managed using a mechanical jukebox device. Optical preserved data more accurately, and enabled data to be printed using information stored on disks, further reducing the role that printed archives played in archival retrieval. The most prominent disadvantage to COLD is the physical limitations of jukebox technology a mechanical serving arm prone to failure and poor retrieval performance. As companies accumulate high-volumes of data over time, mature platters have to be moved out of the jukebox, and manually reloaded when data is requested. Frequently COLD users expect to submit a written archival request and wait several days to data returned to them. " Advantages higher density, high volume " Disadvantages costly to maintain, proprietary competing systems Mainframe Silos Optical technology faces competition from Mainframe storage. Mainframe storage offered a greater storage capacity, reducing the amount of data that would have to be stored offline (mainframe silos frequently accessed off-line data in tape format). Mainframes also provided a more accessible medium, via terminals. These systems are still in use in many large corporations today. While mainframe storage was long held as the only viable solution for high-volume archival and distribution, server- magnetic disk storage has been steadily increasing in scalability and dropping in price. As the cost of disk storage has dropped, the accessibility and versatility of server-based archival forecasts the diminishing market share of COM, COLD, and Mainframe legacy storage. For these older systems, access is simply too limited and cost-prohibitive to extend access to users and application throughout the enterprise. " Advantages higher density, higher volume " Disadvantages costly to maintain, proprietary solutions, uses mainframe mips Enterprise Report Management The introduction of this term points to a shift in focus from applications and hardware that support only report management to addressing enterprise content management solutions that include report management. ERM applications are generally part of an integrated Enterprise Content Management infrastructure that benefits from being a unified platform for all enterprise content whether it be corporate documents, web content, other digital assets or customer communications. " Advantages high volume, unified ECM architecture " Disadvantages lower costs, based on open systems Untitled Document18 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Archiving Standards Review The issues of report capture largely revolve around the formats of information to be captured. For many years reports and communication were produced as ASCII or EBCIDIC line printer output that were transferred onto pre-printed forms. Examples of ASCII output are still common how many communications do you receive through the post that still uses a mono-spaced courier font? The quality of customer communications took a significant step forward with IBM s Advanced Function Printing (AFP) which provided a sophisticated all points addressable (APA) format (much like today s PostScript) for high end, high volume IBM printers. Xerox s equivalent technology was Metacode/DJDE. Most customer communications today are produced as AFP, Metacode, PostScript or PCL. Although these formats offer high fidelity printing they are generally unsuitable for archiving for the following reasons. " Size of print spool file - print formats generally use a verbose syntax that is more suited to the need for size and speed of processing for the print device a rather than being optimised for archival. In particular print spool files can be very large " Indexing and random access print files are not usually designed to allow random access i.e. to page 235. Their linear layout makes them unsuitable as an archive standard format because retrieval can be slow " Ease of viewing although viewing aids exist for many formats they are often proprietary and do not offer sophisticated caching and searching facilities. In addition the size and indexing characteristics of spool files makes them unsuitable for viewing In most cases print formats need to be converted to an archive standard format to support retrieval. In the past archival standards have been largely proprietary however new standards have become available since the early 1990 s that support the digital archival of documents. Some insurers still use print spool files as the archiving format for customer communications. Although these can be used to meet the requirements of ICOB it is unlikely that solution is scalable outside of users in the IT department. Digital Archival Requirements Until the 1990s, large numbers of insurers continued to store copies of communications in hard copy archives. Since 1990 the use of electronic document creation and archiving has increased considerably and these practices have created several new requirements for electronic archiving. " Document Authenticity - it must be possible to prove the authenticity of a document, assertions about the contents and origin, such as creator or sender and time of origin. " Content/Process Reliability - A system must be in place to ensure the contents of a document are authentic and that it is accurately documenting the transaction or information to which it attests. To this effect, electronic archival capture must be capable directly from the application that original creates the document. " Content Security - Archived electronic documents must be stored in a format that offers protection from unauthorized alterations of the document. Untitled DocumentRisk Mitigation for Insurers 19 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. " Persistent Accessibility - Digitally archived documents must maintain a continuous, consistent appearance over time, independent of viewing circumstances. This requires that the format include self-describing information (such as fonts) that can preserve a fixed composition. Adobe Portable Document Format as a Digital Archival Standards Adobe were the originators of the PostScript printer language and developed Portable Document Format in the early 1990s as a means by which documents could be viewed on a computer screen much as they could be seen on paper. The idea was popular because it provided a standard way in which documents could be distributed electronically and gained popularity with the rise of the internet. PDF is the first commonly accepted, open-standard solution for digitally preserving and accessing documents PDF is mandated by many government agencies and is the most popular standard for publishing and archiving unstructured data. The vision realized through PDF is a document archival format that retains full fidelity, independent of device or operating system. In recognition of PDF s archival attributes and its widespread use, the ISO (international standards organization) is currently in the process of finalizing a digital archival standard around PDF. The body currently reviewing PDF/A specifications is proposing a version of PDF designed specifically to protect archived content. " Full Fidelity - Using PDF as the standard format for all content all archival ensures full-fidelity presentment of stored documents. PDF supports a rich set of presentation characteristics that provide a superset of features commonly found in other APA print stream formats. Converting traditional print stream formats into PDF will all full fidelity digital replicas of the original printed document " Universal Accessibility - Thanks to the proliferation of Adobe s free PDF viewer (over 700 millions downloads as of Sept 14, 2004), Adobe Reader, and a number of 3 rd party PDF viewing applications, accessibility can be extended outside a closed network, across the web to desktop and palmtop computer users. Users can view archived PDF with the confidence that a consistent appearance will be maintained for every user who views a document. " Accelerated Retrieval and Scalability - PDF leverages random file access, which is critical for high-volume search and retrieval. Unlike random access, sequential access formats must sequentially parse the entire file until it reaches the data in question. For customers archiving files up to 10 GB in size, the necessity for random access searching becomes clear. This ability allows large reports to be stored in a single PDF instead of bursting documents into individual files. The key advantage is that common resources are shared among many documents (PDF intelligently eliminates redundant object storage and retains these resources within the file). By using single object storage, file systems are spared the overhead of managing individual file objects. " Ownership of Open Standard Content - legacy COLD/ERM systems use proprietary formats to access to their content. Proprietary storage requires that the owner of content continue to support the system that created and manages the archive. With PDF, customers can access, manage and transfer their archives independent of any one product or vendor. Volume Issues Archiving and indexing large numbers of customer documents can require a large amount of storage. Print stream formats are a relatively costly format to store because they are not optimised for size. Untitled Document20 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. A PDF benefit form supporting standard compression techniques within the file format and typically offers compression ratios for various formats as follows: Format Compression Ratio of Original ASCII/EBCIDIC Up to 20% AFP 50%-70% Metacode/DJDE 50-70% PostScript 60% PCL 60% Compression ratios depend on the nature of a document including use of graphics and text. When calculating the volume requirements for archiving solutions the following calculations should be made to assess both the size of the index and document storage: cumentsNumberOfDodexSizeDocumentInBIndexSizeK ntLengthxAveDocumeKBgesDocumentPatSizeKBAveDocumen = cumentsNumberOfDotSizeKBAveDocumenePerDayContentSiz Taking our previous example and assuming an average page size of 25Kb would require approximately .5GB of storage per for content. It is not unknown for archiving solutions to be able to store several hundred terabytes of unstructured content each year. Untitled DocumentRisk Mitigation for Insurers 21 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Records Management Issues Research by Fulcrum found that forms, email attachments, records, customer documents, scanned images, documents, claims, invoices, policies accounted for 80% of information created and retained by businesses. This type of information is known as unstructured data and it is no surprise to learn that quantity of this type of information is growing and that only 3% of deployed IT systems were capable of dealing with it. There are many business issues when dealing with unstructured data because there are rarely systems in place to help track, manage, archive and store this information over time. At EMC we call this Information Lifecycle Management. In this section we examine how document management can be used to manage large volumes of unstructured content and provide access to this information over time and in particular we examine the following issues: " Access and retrieval ICOB compliance issues " Volume and scalability search and retrieval issues " Reprint management " Records management " Version management and auditing for generic documents " Integrating Document Generation, Archival and Records Management Access and Retrieval Compliance with ICOB ICOB Ref Summary General Rules 2.7.1 Providing copies of documents for distance contracts Financial Promotion 3.9.3 Reproducing and displaying documents Advising and Selling Standards 4.2.14 Information to be provided to customers on request Claims Handling 7.7.1 Record management requirements Volume and Scalability - Search and Retrieval Issues In most cases access to document will need to be provided through a search and retrieval interface. Agents typically need to find documents using criteria including policy number, customer number, issue date and name/address details. The search criteria should be identified through analysis of the meta-data available in the document types to be archived. Indexes should be implemented so that a result set can be quickly supplied. Untitled Document22 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Indexes should be able to identify the file and page number in the file at which the relevant document occurs. Two alternative approaches allow documents to be returned to users: " Physical bursting allows print streams to be stored in sections or even per document to support easy retrieval of data. Otherwise users will need to search through large files to find individual document. The side effect of this is that this can create large numbers of content objects in the repository " An alternative approach is to store a single archive document but provide logical indexes into the file. The relevant part of the file will then need to be extracted before being passed to users Some systems may have limits to the number of physical documents that can be stored so care should be taken when selecting bursting strategies. Reprinting A common use of accessing and retrieval systems is for reprinting customer documents on demand. Policy holder may request replacement documents for lost ones and indeed under ICOB the insurer must be able to provide policy documents to customers on request. Records Management Documents stored as part of an archiving process will need to be managed over time so that they are retained whilst regulatory or contractual obligations require them, but may be disposed of thereafter. It is also important to note that records should be disposed of, as under certain legislation discovery may look through all records whether required by regulations or not to be disclosed. Record management and retention policies determine the optimal length of time to keep data and in particular ICOB 7.7.1 emphasises the requirements in this area. Policy documents and policy summaries are the documents subject to most regulatory scrutiny and are required to be retained for 3 years. At this point the content becomes protected in a secure, unchangeable state and managed according to a retention schedule, which defines how long the content is kept, and what steps are taken to depose the record at the end of its lifecycle. Records management allows companies to organize define and implement retention policies. If litigation or regulatory compliance requires it records management limits risk and shortens expensive discover processes. Version Management and Auditing Many generic documents connected with insurance contracts will need to be subject to version control and auditing. Versioning helps us to understand the changes made when documents are edited and it is essential that for documents used in contracts that correct documents and their effective dates are monitored for compliance purposes. Integrating Document Generation, Archival and Records Management For many insurers the processes of generating, archiving and records managing customer communications remains a disjoint and separated process developed over many years and integrating the functions of several IT solutions. Untitled DocumentRisk Mitigation for Insurers 23 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Genuine integration of such processes is necessary not only to meet new regulatory demands but to ensure that customers are serviced in keeping with their expectations through modern delivery channels. By far the most important factor in ensuring that such business needs are met is the need to choose technologies and processes that meet these demands in high volume situations. At EMC the vision for such integration of technologies is Information Lifecycle Management (ILM) and the following section provides a brief introduction to our integrated products and partners with whom we deliver these solutions. ArchiveDocument GenerationRecords ManagementRecords ManagementStore/ TransferExpungeLegal RulesRegulatory ComplianceBusiness RulesAccess ControlRetentionDispositionTime Untitled Document24 Risk Mitigation for Insurers Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Summary and Contact Information The EMC approach to document generation, archiving and records management is continually being reviewed to incorporate best practice from our customers and consultants in the field. Together with partners we are developing processes and techniques to support UK insurers in their implementation of industry best practice. EMC and Document Sciences provide an integrated set of business tools that are scaleable through the Documentum content repository to support insurers of any size. A summary of these tools and services to support them follows: EMC EMC Documentum provides a scalable, secure and extensible platform that enables customers to standardize all their content applications on a common infrastructure. The core product provides the common content repository, collaboration, workflow, records management and archiving platform that are used as the focus of content centric processes for insurers. EMC Documentum s report management services provide specific features for archiving the high volume output of document generation processes. These products are designed to provide a complete infrastructure for document generation, archiving and Enterprise Content Management and it is our aim to ensure that EMC Documentum can offer market leading products in this field. www.software.emc.com EMC Centera Storage Solutions EMC Centera provides a simple, scalable, secure storage solution for cost-effective retention, protection, and disposition of a wide range of fixed content including electronic documents, e-mail archives, check images, and other media formats. Exceptional performance, seamless integration, and proven reliability make Centera the online enterprise archiving standard for virtually any application and data type. Centera is ideally suited to the demands of storing large quantities of archived customer communications in a solution that is integrated fully with EMC s Documentum and Acartus ApertureONE. www.emc.com Document Sciences Document Sciences is a Global EMC/Documentum partner specialising in document generation processes and technologies. Document Science s, xPression document design and generation engine, is designed to deliver to insurers the ability to develop and manage business communications based on the Documentum platform. xPression simplifies personalisation, and market segmentation, by applying business rules and conditions to any part of any business document requiring content certainty. xPression uses the latest design technologies and standards through Document Sciences' BEA, IBM, Microsoft and Adobe partnerships. Document Sciences products are deployed widely amongst insurers in the UK, Europe and the US. www.docscience.com Untitled DocumentRisk Mitigation for Insurers 25 Copyright 2006 EMC, Inc. All Rights Reserved Worldwide. Further Information If you have any comments or suggestions regarding our work in this area or if you would like further information on any of the solutions outlined above please contact: Tim Nelms ERM and Archiving Specialist EMC EMC Tower, Great West Road Brentford TW8 9AN Nelms_Tim@emc.com General enquiries Tel: +44 (0)20 8758 6810