WHITE PAPER. Overview of RSD GLASS. Comprehensive Information Governance Solution. RSD, Page 1

Transcription

1 WHITE PAPER Overview of RSD GLASS Comprehensive Information Governance Solution RSD, Page 1

2 TABLE OF CONTENTS Executive Summary... 3 The Information Governance Challenge... 4 Business Drivers for Information Governance... 7 RSD GLASS Delivers Unique Capabilities... 9 Recognizable and Measurable Benefits of RSD GLASS In Conclusion About RSD RSD, Page 2

3 EXECUTIVE SUMMARY Information is essential to managing a business since it drives decision making, customer support programs, back office operations, collaboration between business functions, and product innovation. However, with information comes risk. The risk relates to compliance, security, and privacy of the information. Organizations are cognizant of their ongoing legal and regulatory obligations since non compliance leads to substantial fines, serious revenue loss, significant reputational damage, and possibly jail sentences for C level executives. Information governance enforces desirable behavior in the creation, use, archiving, and deletion of corporate information. It includes the various global and local regulations and contains corporate standards for managing information. An information governance program includes the business processes and information lifecycle practices which entail more than just retention/disposal. It incorporates data privacy attributes, ediscovery requirements, storage optimization, and metadata management. Figure 1. Information governance helps organizations leverage their information assets to drive business performance, help comply with rules and regulations, and control the lifecycle and use of information RSD GLASS helps organizations manage corporate risk and improve operational efficiency as they work to achieve compliance with regulations and laws governing enterprise information and records management. Current records management and enterprise information management solutions address the information governance challenge from the bottom up by hard wiring their policy and enforcement capabilities to proprietary repositories. RSD GLASS takes a top down approach: central policy management, federated enforcement, and repository agnosticism. This represents a fundamentally new design center for information governance, and offers organizations far greater flexibility to implement truly enterprise wide solutions. This document reviews the information governance challenge and summarizes RSD s information governance solution; called RSD GLASS. RSD, Page 3

4 THE INFORMATION GOVERNANCE CHALLENGE The information governance challenge: greater than the sum of the document management, records management, document archive and retrieval, and content management challenges combined VOLUMES OF CONTENT In recent years, there is an explosive growth in the creation and collection of documents and other rich content by both applications and individuals. Large corporations have massive amounts of content (hundreds and sometimes thousands of terabytes, example Fortune 100) which is often times scattered across different jurisdictions. According to a May 2010 IDC study 1, the digital universe grew by 62% to nearly 800,000 petabytes in 2009 and will grow to 35 trillion gigabytes by And by 2020, 50% of this information will require a level of IT based security and management. BREADTH OF CONTENT In addition to the significant volumes of content, there are practically thousands of different types of information within the enterprise print streams, images, ERP/CRM reports, Office documents, databases, e mail, Website content, instant messages and rich media such as audio and video files. Each content type has different formats each with its own unique requirements (and limitations). PLETHORA OF APPLICATIONS, BUSINESS PROCESSES, CONTENT MANAGEMENT SYSTEMS Business processes are the lifeblood of many organizations across various applications claims systems, loan processing, employee appraisals, inventory management, customer support just to name a few. A business process starts with a customer s need and ends with a customer s need fulfillment which then becomes a legal record or transaction which is often stored in a content management system. To complicate matters, content management systems are being increasingly deployed across the enterprise, with the objective not only of improving productivity and efficiency, but also of improving control over the growing volume of business content being created and collected in these systems. A survey from a few years back from an IDC survey found that, on average, there are 24 repositories in a company. Large companies average more than 42 repositories including multiple content management systems. COMPLEX AND EVER CHANGING RULES AND REGULATIONS Organizations are inundated by demands for compliance with regulations and laws. These requirements come from diverse industry and government sources. For global organizations, compliance requirements also come from faraway lands where local governments want to apply their own regulations and laws to businesses that operate within their jurisdictions. Securities Exchange Commission (SEC) 17A, Sarbanes Oxley Act (SOX), Health Insurance Portability and Accountability Act (HIPAA), Financial Industry Regulatory Authority (FINRA), and the updated Federal Rules of Civil Procedure (FRCP), are just a few requirements demanding stringent governance. 1 RSD, Page 4

5 Executives are looking to bridge operational gaps between legal staff, compliance teams, business units and IT CONTROL ONGOING LITIGATION COSTS Almost every company is occupied with managing (or perhaps mismanaging) numerous ediscovery requests. For a single ediscovery request, industry statistics on costs and time requirements are frightening if not unbelievable. According to the 2008 Socha Gelbmann Survey 2, commercial expenditures on electronic data discovery topped $2.7 billion in 2007, up 43 percent from According to the Gartner Group, every gigabyte of data (approximately 75,000 printed pages) sent to outside counsel for an attorney/client privilege review costs about $18, Many times, an organization is forced to settle a legal matter simply to avoid excessive legal expenses necessary to adequately comply with current laws, regulations, and the increasingly strict requirements from courts. LACK OF TRANSPARENT ACCESS Content without simple access is useless. Business users are demanding simple and rapid access to information in all corporate repositories regardless of source, format, platform or storage media. Thanks to popular search engines, users expect this search to be done securely from a simple Web interface or within a line of business (LOB) application. According to a recent AIIM survey on findability 4, 49% of respondents indicated that finding the information they need to do their job is difficult and time consuming. DISCONNECT BETWEEN LEGAL, BUSINESS, RECORDS MANAGEMENT, AND INFORMATION TECHNOLOGY When it comes to managing information, each corporate function has its unique requirements, goals, and perspectives. In most cases, there is no alignment across the various groups particularly with the legal department, business units, records management, and the technology group. Legal doesn t understand the technology but they need to satisfy the courts, the CIO has a tight budget with overlapping technologies, and business managers need to respond to customers and ongoing competitive threats. VALIDATING, ENFORCING AND MAINTAINING A RETENTION SCHEDULE A retention schedule lists the different types of corporate records along with their agreed retention periods and disposition methods. Records Retention Schedule is a policy document that is typically created using Excel spreadsheets and rarely validated by legal or IT. Companies are struggling to take the retention schedule to the next level and technically enforce the rules across jurisdictions and business applications. The retention schedule should be reviewed periodically (typically, once each year) to update or add new rules and regulations and to verify that current retention decisions should remain in effect. This process should be automated as much as possible to gain efficiencies Gartner, E Discovery: Project Planning and Budgeting, , February Watch/Findability RSD, Page 5

6 Current solutions address the information governance challenge from the bottom up by hard wiring their policy and enforcement capabilities to proprietary repositories INCREASE IN COSTS ASSOCIATED WITH DATA BREACHES Organizations have a responsibility to protect the privacy of customers and employees. This covers medical privacy (example: patient medical history), citizen privacy (example: race and age), and financial privacy (example: credit card numbers). According to a recent study from Ponemon Institute 5, there has been a significant spike in legal defense associated with data breaches costing U.S. companies $204 per compromised customer record in According to the study, companies are spending more on legal defense costs which are attributed to increasing fears of successful class actions resulting from customer, consumer or employee data loss. RESTRICTED BUDGET WITH LIMITED RESOURCES Does do more with less sound familiar? CIOs are being asked to deploy and manage more applications and projects with either zero percent or a decrease in their budget. IT management needs to better leverage their existing infrastructure, applications, and storage platforms with a reduced IT staff. LIMITATIONS OF CURRENT OFFERINGS In the early to mid 2000s, the conventional wisdom was to use a records management fortified ECM technology as the basis of the solution. However, executives discovered this approach is extremely limited in terms of scalability, ability to handle structured as well as unstructured content, and ability to adapt with all facets of the record lifecycle rules and not simply the retention and disposition. Current systems on the market have a dedicated and isolated policy engine or focus on administration and control. There are no solutions that seamlessly go from policy management to control and administration of corporate records to enforcement of information governance policy all independent of the repository /23 RSD, Page 6

7 BUSINESS DRIVERS FOR INFORMATION GOVERNANCE EDISCOVERY READINESS ediscovery requirements are forcing companies to consider new methods for managing information. Most litigation focuses on e mail, but the changes driven by the Federal Rules of Civil Procedure (FRCP) do not focus on e mail alone. All electronic stored information (ESI) is now admissible. Legal discovery is beyond e mails and involves a variety of information formats ranging from paper documents, images, correspondence, text messages, data warehouses, voice mails, statements, MS Office documents, etc. Legal departments are looking for ways of disposing unnecessary information and ensuring the organization is compliant to the approved retention schedule. There is a very well known case study by DuPont detailing the costs when companies do not have a proactive lifecycle management process 6. The case study concluded over 39 million documents were reviewed during litigation that were past their retention period which cost $12 million. Bottom Line: Litigation is inevitable. Information governance gives organizations a mechanism to policy manage information and to align it to the correct levels of accessibility, protection, and retention to reduce risks and costs of future ediscovery requests. INFORMATION RISK MANAGEMENT Widely reported cases such as Zubulake Warburg ($29.2 million initial judgment for Zubulake which was subsequently settled) and Coleman v. Morgan Stanley ($1.5b fine assessed to Morgan Stanley by SEC) have shed light on the issues surrounding improper management of information in the enterprise today. Beyond e mail, companies must gain control over many forms structured as well as unstructured of content in its many formats, in order to avoid such exposure. Within the enterprise, there are two very different views to address the concerns of information risk management. The Chief Compliance Officer (CCO) is responsible for the entire organization and typically reports directly to the CEO and Board of Directors. The CCO must enforce compliance with regulations through business processes and information flows which span business units, applications, and geographic locations/jurisdictions. The CCO endorses and supports enterprise level, centralized policy definition. On the other hand, the Chief Information Officer (CIO) must achieve compliance across complex network infrastructure, must address heterogeneity of platforms, applications, and content repositories and must embrace principles of federated control and enforcement. Only a properly architected solution can address the concerns of both the CCO and CIO. Bottom Line: Corporate information comes with risk. Information governance delivers strict retention management to minimize the risk of inappropriately destroying records that could cause irreparable damage. 6 RSD, Page 7

8 What if you could retrieve corporate records securely from your line of business application within seconds? BUSINESS INFORMATION LIFECYCLE MANAGEMENT The lifecycle of a corporate record can be measured in days, weeks, months, years, decades or centuries. There are many different milestones and actions throughout the life of the record including rules on when to delete or add new business descriptors, move the information from one storage device to another, and anonymize and declassify the record. An information governance solution should help manage these processes and enforce these activities. Some of these activities are automated (7 years after record declaration) while other times they are triggered from a business event (employee leaving or customer closing account). Identifying information is typically done using business descriptors and metadata. Example of business metadata terms include: Sarbanes Oxley Promise to deliver, contingency sale, executive loan, commitment, SPV accounts, off the book, revenue recognition, proposal, etc. BASEL II Account, account management, fiduciary, rate of return, risk, put, call, long, short, churn (turnover), etc. HIPAA Patient, episode of care, provider, payment, coverage, carryover coverage, treatment, outcome, diagnosis, disease, etc. The importance of proper management of metadata is becoming clearer, whether that metadata is abstracted from existing paper and digital documents, added when authored, tied to a formal taxonomy, or tagged informally by users. The more descriptors a content object has, the more likely it is to deliver greater value in a variety of contexts over a longer lifecycle. Bottom Line: Information fuels business growth. The goal of an information governance program is to ensure records support business growth efficiently as well as to ensure correct preservation obligations regardless if they come from external regulations, corporate standards, or business terms defined in contracts. RSD, Page 8

9 RSD GLASS DELIVERS UNIQUE CAPABILITIES RSD GLASS (Governance Layer for Archive ServiceS) is a solution to manage corporate risk and pain related to the compliance of corporate information with requirements mandated by applicable laws and regulations. The solution enables proactive and central information management with a systematic process across business functions, jurisdictions, and isolated silos of information. RSD GLASS simultaneously provides authorized users and applications with simple and rapid access to information in all corporate repositories while offering internal transparency by weaving information governance capabilities into the fabric of the content infrastructure. RSD GLASS is unique and creative by incorporating components that transcend the typical boundaries and limitations of current generation solutions: RSD GLASS promotes the federation of content and simultaneously provides centralized information governance policy definition, maintenance and enforcement capabilities RSD GLASS is agnostic of the repositories, content sources, and business applications Policies in RSD GLASS transcend the retention in scope and cover data privacy and ongoing ediscovery requirements RSD GLASS is modular based service oriented architecture using industry standards and is optimized for very high access rates Figure 2. RSD GLASS is an integrated solution which decouples the information governance functionality of information such as policy management, control and enforcement into highly modular independent services based layers RSD, Page 9

10 CENTRALIZED POLICY MANAGEMENT As mentioned earlier, large enterprises typically have multiple repositories containing massive amounts of content. The repositories are typically spread across jurisdictions, business units, and platform technologies. It is difficult to deploy corporate retention policies in a stove piped manner and it s also not feasible to migrate all content into a single content repository. Each repository needs to have dedicated policy administration and controls to ensure content is archived to corporate defined rules. Not only is this is an administrative headache, but it also creates a huge risk for the entire organization. As a result, retention policies must be centralized and the content should remain federated. Information governance requirements go beyond retention and disposition and must include electronic discovery and holds, data privacy protection, information lifecycle management, audit trail management, distributed archiving services, and a comprehensive approach to information risk management. RSD GLASS satisfies all of these requirements while most record management applications are solely focused on retention and disposition. Figure 3. RSD GLASS centralizes the creation and management of information governance policies which include more than retention and disposition RSD GLASS Mosaic provides a centralized facility for the simple creation and management of policies governing information and their configuration across the enterprise. RSD GLASS Mosaic drives the transition for companies who rely on paper based process and repositoryspecific retention and disposition policies. An information governance program incorporates the requirements across all corporate functions business, legal, risk management, compliance, IT, privacy, and executive management. RSD GLASS aligns the needs from all stakeholders by including all the necessary requirements for governing corporate information: RSD, Page 10

11 Policies in RSD GLASS are centrally defined to show they are enforceable and auditable Retention and disposition Assign retention and disposition rules to the record classes. Rules are time or event based which depending on your needs can be very simple (i.e. delete after 7 years of record declaration) or advanced (i.e. after the contract is terminated, send for approval to be deleted). Records managers have advanced records lifecycle control and administration functionality including screening and scheduling as well as much more granular controls over the elements and lifecycle of the record. Companies who already have this in another format (such as Excel spreadsheet) have the option to easily import their retention schedule into RSD GLASS. Laws and regulations List the rules and regulations that apply to the record class and include documentation, comments, and external hyperlinks. When a rule changes, compliance officers can search for all the record classes which are impacted by the change. Discovery and litigation attributes Specify a legal hold on one or more records (or have multiple holds on one record) and include additional information such as reason of hold, case number, legal team, plaintiff, etc. These retention rules and metadata are stored in the information governance policy. Legal teams are able to search using this information. Data privacy rules Define various rules to content to hide private information such as social security number, date of birth, and other sensitive data. Chief privacy officer can determine when the rules go into effect and how they are applied. Metadata management Add groups of metadata to the record class to help drive the enterprise classification and taxonomy. IT has the ability to manage the lifecycle of the metadata to optimize storage, application performance, and new business requirements. Storage optimization Migrate information across storage tiers automatically based on a set of defined rules. IT data storage managers can better utilize, control, and predict storage costs while making the storage platform transparent to the user and business application. Comprehensive auditing facilities Document all the detailed changes made to the information governance policy. Auditors can easily get a complete overview of the information governance program including the change history of the enterprise policies. Security integration Link information governance policies to existing security protocols and technologies. Data security officers can easily link records to corporate standards for authentication and authorization including LDAP. RSD, Page 11

12 Figure 4. RSD GLASS Mosaic manages the entire lifecycle of corporate information from a simple user interface Once the policy rules are defined, RSD GLASS Mosaic has a workflow engine to validate the policies. The workflow steps are either basic or advanced and all activities and outcomes are tracked in the audit trail. This encourages collaboration between the various business functions and promotes accountability. Once policies are validated, the retention schedule is then published in electronic and human readable formats (such as PDF). Making the policies available in electronic formats enables the enterprise architecture group to enforce the policies across the IT infrastructure. RSD, Page 12

13 RSD GLASS is a repository of all the information governance policies mapped to your jurisdictions and applications INFORMATION LIFECYCLE MANAGEMENT AND ENFORCEMENT Companies who have successfully published an enterprise wide retention schedule are struggling with implementing and enforcing the rules to the underlying corporate infrastructure. Most of the data within the organization is decentralized stored in databases, content repositories, file shares, desktops, back up tapes, and paper. Executive management needs the assurance the information governance policies are being implemented properly and timely in the field. This is the only way to entirely mitigate risk and exposure to non compliance with regulations in force. The swivel chair and word of mouth enforcement simply does not work. RSD GLASS Periscope enables the enterprise architecture team to enforce the corporate policies across geographies and jurisdictions, platforms and applications, repositories and data warehouses. RSD GLASS delivers enterprise policy enforcement directly into the infrastructure with the following capabilities: Breaking the silos RSD GLASS enforces policies across data center boundaries; across jurisdictions; and across storage tiers. Executing defined actions RSD GLASS transmits instructions and commands to the content repositories and applications such as hold records or set of records or clean out records which are beyond the approved retention periods, migrate these records to a slower storage level, or declassify these set of records. RSD GLASS Periscope generates a list of required actions to be executed and manages the entire approval process for driving the lifecycle process. Supporting the standards RSD GLASS Prism supports applications that have adapted the Content Management Interoperability Services 7 (CMIS) specifications developed by OASIS working group. Connecting to proprietary and custom systems For applications that do not support standards, a connector can be configured within RSD GLASS Prism. The connector translates the rules from the policy to the customer application. Alerting and notifying exceptions RSD GLASS automatically alerts the compliance team if a repository or jurisdiction is out of compliance. For example, if a repository didn t properly dispose a set of defined records, a message will be sent to the compliance officer (and perhaps IT manager) to investigate. Auditing policy enforcement RSD GLASS has a comprehensive audit trail for compliance and business metrics. Audit reports are archived and distributed as required by your compliance team. Enforcing information governance policies automatically across the potentially hundreds of enterprise applications on day one is somewhat (almost) impossible so RSD GLASS supports the phased enforcement capabilities. Enforcement needs to be assessed on a case bycase basis and is typically subject to business cases, funding and resource availability a.html RSD, Page 13

14 CONTENT FEDERATION FOR ARCHIVING AND TRANSPARENT ACCESS Information is an asset. An important driver for information governance is to help drive better value for customer service, product innovation, investment decisions, inventory control, and resource allocation. Users demand high speed secure access to information typically from a Google like interface and from their line of business application (i.e. claims, mortgage, HR, customer service, legal case management). Information also needs to be correct and current. FEDERATED ARCHIVING SERVICES With minimal clicks, RSD GLASS Periscope creates an information governance file plan that includes the entire information governance hierarchy, along with its security and templates. Corporate records are grouped according to their file plan, so file plans are implemented as easy to navigate folders. The file plan also carries with it a set of rules for evaluating new records that must be properly governed. As new information is being created, the information governance rules are applied which guarantees compliance at content creation time. The design and architecture of RSD GLASS is based on the principles of the OAIS archiving framework model (ISO 14721:2003). Content creation applications within the organization that create content includes (but not limited to): Line of business applications ERP systems such as SAP and Oracle Content authoring applications such as MS Office and Adobe E mail applications such as MS Exchange and Lotus Domino Collaboration platforms such as Alfresco, SharePoint, and Quickr RSD Enterprise Output Solution (EOS) Others (social media sites) Figure 5. RSD GLASS Periscope comes with a simple dashboard to see all the events triggered and enable ongoing policy maintenance RSD, Page 14

15 The content creation in these applications may be manual (with end user involvement) or fully automated. For example, with content authoring applications such as MS Office, the user is provided with an interface for quick classification and filing of the document. In all cases, the content is classified using the rules defined RSD GLASS and appropriately archived and stored. TRANSPARENT ROLE BASED ACCESS RSD GLASS Crystal provides authorized users with transparent role based access to information regardless of location across the potentially decades long lifecycle. A single query goes across all the sources with automatic consolidation and categorization of results. RSD GLASS has the search features users are accustomed to including phrase, wildcard and proximity queries. The search is executed from the out of the box graphical user interface and/or from a line of business application. INFORMATION GOVERNANCE FUNCTIONS ACROSS THE COMPANY RSD GLASS enables employees to manage information as an asset and improve their daily corporate duties. The table below shows a small sample of the roles within the organization and the governance functionality available in RSD GLASS. Role RSD GLASS End User Functionality Benefits Executive Management Legal Customer service Records manager Business unit managers Access compliance reports and performance metrics Restore content across the enterprise, issue litigation hold to prevent spoliation, apply additional metadata specific to the legal case, export documents to third party applications Search for customer related content, export information for analysis, change metadata (i.e. customer name), trigger lifecycle event (i.e. close bank account to trigger a change in the lifecycle) Maintain Master Classification, create file plan, change taxonomy, enforce administration processes and procedures Integrate information lifecycle with business process (i.e. loan approval process), search for business related content (i.e. employee, product, etc), provide compliance reports for auditors Ensures compliance of corporate information with requirements mandated by applicable laws and regulations Delivers governed content to any ediscovery request Improves customer service and helps identify cross selling opportunities Eliminates redundant and uncoordinated records management activity through centralization of all information governance policies Enhances productivity in high volume driven processes due to RSD product performance and scalability Figure 6. Sample of corporate roles and the features within RSD GLASS to support their job function RSD, Page 15

16 RECOGNIZABLE AND MEASURABLE BENEFITS OF RSD GLASS RSD GLASS delivers a scalable solution to address information governance needs for all organizations with the following short and long term benefits. MINIMIZES RISK ACROSS THE COMPANY RSD GLASS mitigates risk in a number of areas related to litigation, audit, and data protection. RSD GLASS delivers persistent compliance by protecting information from the threat of unauthorized access, loss or destruction. RSD helps the largest companies in the world make better business decisions while ensuring compliance with requirements mandated by applicable laws and regulations ENSURES PROACTIVE AND CONSISTENT POLICY ENFORCEMENT RSD GLASS enables the management (creation, publishing, reviewing) of the Master Classification and all related elements. RSD GLASS integrates all information governance policies and deploys them seamlessly directly into the infrastructure. IMPROVES EMPLOYEE PRODUCTIVITY RSD GLASS allows authorized users to perform a single query from their line of business application across unlimited amount of sources with an automatic consolidation and categorization of results. LEVERAGES EXISTING TECHNOLOGY INVESTMENTS RSD GLASS works within the existing network infrastructure and the existing repositories such as enterprise content management (ECM), records management (RM), web content management (WCM), collaboration platforms, and e mail. Furthermore, RSD GLASS allows the IT department to improve service to the business units by optimizing storage media and enterprise archiving solutions. FACILITATES COMPLIANCE EFFORTS RSD GLASS enforces corporate best practices and helps organizations comply with government regulations using state of the art retention management, detailed audit trails, and flexible reporting capabilities. SIMPLIFIES MANAGEMENT OF BUSINESS INFORMATION RSD GLASS gives organizations a powerful mechanism to policy manage information and to align it to the correct levels of accessibility, protection, and retention. This includes structured and unstructured content stored in disparate silos (i.e. ECM repositories, SharePoint, data warehouses, databases). ALIGNS IT, LEGAL, BUSINESS AND ADMINISTRATION RSD GLASS facilitates compliance with a plethora of technical, regulatory, legislative and corporate requirements. RSD GLASS promotes collaboration between all stakeholders while developing transparency and creating accountability. REDUCES OVERALL COSTS RSD GLASS lowers costs with automatic classification of content based on business rules and legal requirements. The solution eliminates manual tasks by automatically managing information throughout its lifecycle across disparate silos of repositories. RSD, Page 16

17 IN CONCLUSION The information governance challenge has created the urgency at the executive level responding to the explosive growth in content creation and rapid expansion in laws and plethora of regulations. Unlike current enterprise information management and bolted on records management solutions, RSD GLASS enables central management of retention policy and metadata, while supporting enforcement of information governance policy across business functions, locations, and information silos. RSD GLASS solves the compliance challenge with laws and regulations regarding the retention and disposition of business records. RSD GLASS cuts costs with managing information and employs a proven framework to stimulate business growth while improving business processes and supply chains. For 35 years, RSD has a proven track record for delivering enterprise class solutions for content management, records management and high volume archiving and distribution. ABOUT RSD Founded in 1973 in Geneva, with affiliates in New York, London and Madrid, RSD helps companies meet the growing challenge of information governance by providing marketleading products for business information delivery, content and records management, and document archiving and retrieval. RSD solutions are used in more than 1,200 installations worldwide, including a majority of the Fortune 500. Today RSD supports over 2 million users, and offers its innovative products and services in more than 26 countries around the globe both directly and through strategic business partners. Copyright RSD, All rights reserved. All brand and product names quoted in this publication are trademarks or registered trademarks of their respective holders. info@rsd.com RSD, Page 17