Driven’s Phil Favro and Tara Emory review nine factors the US DOJ will consider when evaluating antitrust compliance programs. Tara Emory leads the EDRM Revision team.
The guidance provided by the DOJ includes a focus on information governance, document retention, destruction, risk assessments and the training of staff.
Favro and Emory conclude:
After an assessment is complete, companies without current or workable IG measures can map company data, implement or update information retention policies, and determine whether and when affected data should be eliminated pursuant to the corporate records retention schedule. They can also lay out appropriate use cases for ephemeral messaging or other encrypted communication applications. Companies can also set appropriate education and training intervals for employees, along with monitoring, audits, and enforcement of information related policies and procedures.