Created by OuterBay Marketing

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Data Compliance Roadmap A New Approach to
Retain and Manage Data
Jan Brown OuterBay OAUG OATS June 2003
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Agenda

• Challenge 1 Compliance
• Challenge 2 Unmanaged data growth
• How to solve both with one solution

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What started the compliance rush?

• Blatant book-cooking at Enron Corp., WorldCom and
  elsewhere
• Sparked Public outrage
• Sarbanes-Oxley Act
• The biggest overhaul of corporate accounting
  since the Great Depression
• Investors Business Daily

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What is Sarbanes Oxley?

• ??? Maryland
• US Senator
• Paul S Sarbanes
• Marylands Democratic Senior Senator
• ??? Ohio
• Congressman Fourth District
• Michael G. Oxley

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5 Things you need to know

• Governs publicy traded firms
• Audit of internal controls and processes is
  mandated
• It will reach beyond financial processes
• Get ready for real-time disclosure
• Timely and accurate disclosure of material
  events.
• Within 48 hours
• It is a process not an event

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Shameless Giveaway!

• According to Sarbanes-Oxley, how long do you need
  to keep your information?
• What are some of the bad things that happen to
  you if you are not compliant?
• According to SEC Rule 17a-3, how long do you need
  to keep your customer account records?

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What happens if I am not compliant?

• Fines
• January 2003, the SEC fined Salomon Brothers,
  Morgan Stanley, Piper Jaffrey Hopwood, Deutsche
  Bank and Goldman Sachs a total of 8.2M for
  failure to comply with Rule 17a-4.
• Imprisonment
• Bad Press
• Missed sales opportunities

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Compliance The new Y2K

• Consume valuable resources
• Delay company critical business initiatives
• No positive impact to revenue, market share, etc.
• Not just a one time event, its ongoing

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The key issues with compliance

• SEC definition
• email and instant messages customer complaint
  handling and disposition records, etc
• Electronic Documents
• SEC focus areas
• Record Creation
• Record Retention
• Auditing, Reporting, Tracing

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Rule 17a-3 and 17a-4 Books and Records
Requirements for Brokers and Dealers Under the
Securities Exchange Act of 1934

• Record Retention
• customer account records must be retained for 6
  years
• customer communications and complaints must be
  kept for 3 years
• internal exception reports must be retained for
  18 months.
• When these records are retained in electronic
  form, Rule 17a-4 requires broker/dealers to
  preserve the electronic data on non-rewritable,
  non-erasable media. For the first two years after
  a transaction, firms must make records, indexes
  and audit logs available to regulatory
  authorities promptly when requested typically
  within 24 hours.

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Rule 17a-3 and 17a-4 Other requirements

• Must be accurate and safe
• Quality and accuracy of the storage media
  recording process
• Duplicate copies
• Accurate index of all information
• Adequate audit system
• Readily available for regulatory agency review
• Third Party download provider
• Storage instances must be serialized
• The storage system must preserve electronic
  records exclusively in a non-rewritable and
  non-erasable format

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What does it mean to become compliant
successfully?

• Meet the compliance deadline(s)
• Establish a compliance lifecycle.
• Compliance is a process not an event
• Use the same methodologies and best practices for
  all your data retention needs

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Electronic records management

• Electronic records management is the common
  element in all these rules sets.
• You must keep what you are obliged to keep, and
  you must not throw it out until and unless you
  have permission to do so according the official
  rules.
• Bruce Miller, IBM

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Whats the big deal about compliance?

• The answer is SO simple!

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• Keeping your data compliant, means keeping
• A LOT of data
• Uncontrolled data growth can lead to exponential
  problems

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The Data Growth Wave
Data growth up to 125 per year crippling IT
budgets
80 of data is inactive
Compounded by compliance and upgrades
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The Data Growth Paradox

• Unmanaged Application Data Growth
• Decrease in application performance and stability
• Increase in infrastructure costs
• Detracts resources from strategic initiatives

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The Effect of Unmanaged Data Growth

• The Ripple Effect
• Application performance outages
• Backup size time
• Upgrade costs
• Instance de-consolidation
• Test development time to production
• Server upgrade costs, SW license costs
• Total Storage costs procurement, management, 
  backup.
• Cost of new initiatives Test and Development
  growth

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Current IT Alternatives

• Spend more money
• Servers, Infrastructure (SAN, Filers)
• Add more complexity
• Application clustering (RAC), System partitioning
  
• Un-consolidate
• Add more risk
• SQL tuning, Proprietary caches
• Add more processes
• Inconsistent band-aid solutions

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The Choices

• ...keep buying more ...
• Disks
• Networks
• Servers
• Processes
• People

• or, implement a best practice
• and manage data growth.

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A New Approach To Manage Data

• Identify Inactive Data
• Relocate Inactive Data to Live Archive
• Retain Application Transparency

Active
Inactive
History
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Application Data Management
Support Projects
Production
Integration Test
Unit Test
Development
Archive
X(n) Parallel Initiatives
Production
Application Resource Management Software
Application Data Archive Software
Subsetting / Instance Creation
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Application Aware

• Application Aware Rules
• Application specific optimized
• Transparent to users
• Oracle certified
• Policy based

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Bottom Line Impact
43 reduction in production database
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Sun Microsystems

• Business Issue
• MRP system could not keep up with orders. Missed
  number.
• IT Challenges
• Performance
• Traditional Options
• Hardware treadmill, expensive tuning
• OuterBay Solution
• Application Resource Manager and LiveArchive
• Benefits
• 10 Quarters of growth with same server (actually
  smaller. From 32 to 24 CPU)
• 40 system-wide performance improvement
• No outages since go live in 1999

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Tektronix and LiveArchive

• Business Issue
• No worldwide view of customers orders
• IT Challenges
• 11i upgrade Financials and Manufacturing
• 1.25GB monthly database growth
• Traditional Options
• Tuning and hardware upgrades
• OuterBay Solution
• LiveArchive
• Benefits
• 73 performance improvements for order processing
  and receiving
• 67 reduction in size of production database

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Parsons Brinckerhoff and LiveArchive

• Business Issue
• World Wide Projects implementation to support a
  1B Engineering Business
• IT Challenges
• Upgrade to 11i in a 6 day window.
• Consolidate data from Asian operations in to
  single global instance
• 20-50 increase data post 11i upgrade
• Traditional Options
• Tuning
• OuterBay Solution
• LiveArchive
• Benefits
• 35 increase in production database space.
• 42 decrease in 11i outage window (12 to 6 days)

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About OuterBay
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Application Data Management

• Problem Unmanaged data growth
• Solution Proactive Application Data Management
• Identify active/inactive data
• Relocate to live archive
• Retain application transparency
• Benefits
• Deliver high application performance and
  stability
• Reduce infrastructure costs
• Free resources to focus on strategic initiatives
• Application Data Management Suite
• Application Resource Manager (ARM)
• LiveArchive
• Instance Generator
• Developers Edition

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OuterBay Customer Factoids

• 43 of customer base are Fortune 500 companies
• 26 of customer base are Global 500 companies
• Over 50 of customers have archived due to
  performance issues
• Customers revenues range from 126 Million to 60
  Billion
• Top 3 Largest Oracle Application Sites
• Alcoa Largest of users
• Sun Largest consolidated database
• POSCO Largest implementation

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Market Leader

• Crossroads A-List Award 2003
• Ranked 3 of the Top 10 Private Companies 2002
• Top Ten Start-ups 2002
• The Only Oracle Certified Archiving Solution
• AMR Names OuterBay one of Top Five High-Value
  Infrastructure Projects for 2002

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THANK YOU QUESTIONS
All Data is Not Created Equal
Kevin OMalley komalley_at_outerbay.com www.outerba
y.com