Discovery Pitfalls: The discovery process for electronically-stored information (ESI) from enterprise systems is complex due to numerous factors, including but not limited to:
- Volume: Data sets for a mid-sized company commonly contain hundreds of millions of records across terabytes of data.
- Diversity: Each system is highly customized for the unique needs of each organization, requiring customer and system specific discovery solutions.
- Complexity: Responsive data identification requires an understanding of the system’s internal structure, relationships to other systems that may span organizational business units.
- Functionality: These systems were not designed with litigation in mind and have no easy means to transform the data into a format suitable for review and production.
- Sensitivity: These systems often contain sensitive information such as customer information, financial records, health records and credit card numbers, etc.
Identify Systems: The first task is to identify the potentially relevant systems vital in supporting the litigation. This information can frequently be obtained from resources across the organization such as IT, engineering, compliance, etc. Organizations that are frequent targets of litigation or regulatory investigations will likely have some version of a systems inventory detailing major data repositories.
