Case Study

Strengthening Records and Information Management for a Global Bank

In facing challenges with Electronic Records Retention and regulatory compliance, a global bank partnered with Arrayo for expertise in records management and audit validation. This case study explores how the collaborative effort helped to enhance the bank’s data management practices, ensuring adherence to regulatory standards and reinforcing its information management framework for better resilience.


Our client, a prominent global bank, faced regulatory concerns related to Electronic Data Management, specifically Electronic Records Retention. To address these challenges, the bank opted for a co-sourced validation approach and engaged Arrayo to support its Internal Audit (IA).
The bank’s Internal Audit sought a third-party vendor with expertise in records retention and audit experience to validate the remediation actions taken. Our role was to provide guidance, oversight, and subject matter expertise to perform validations of all remediation actions.


Our team, comprised of electronic records management experts with decades of experience, collaborated with the bank’s IA to ensure compliance with regulatory requirements. Led by an industry leader and SME, our responsibilities were extensive and spanned the entire project lifecycle.
In the initial phase of the project, our team focused on conducting interim validations and drafting essential MRA Validation Deliverables such as work programs, work papers, and checklists. We meticulously reviewed the bank’s data disposal processes, offering insights into gap analyses. Additionally, our experts provided valuable feedback on the bank’s Record Retention policies and procedures. Throughout this phase, we collaborated closely with the bank’s Internal Audit to ensure a unified approach to addressing identified gaps and observations.
Moving into the Data Catalog and Reporting phase, our team actively engaged in reviewing the Draft Data Catalog of Unstructured Electronic Records, suggesting revisions to enhance accuracy and completeness. The scrutiny extended to the final risk-based catalog, validating User Acceptance Testing report results, and assessing the efficacy of training materials. Comprehensive sample testing of reports and disposal results formed a crucial part of our approach. We also ensured the accuracy and consistency of exception and exemption lists, evaluating the bank’s BAU record retention electronic data disposal process before its final implementation. Throughout, our collaboration with IA remained pivotal, with joint efforts directed at addressing gaps and optimizing the project’s outcomes.
Lastly, our team conducted an end-to-end review to verify the thoroughness of remediation actions in addressing the initial concerns outlined in the MRA. This rigorous process involved preparing a final validation report, offering a comprehensive overview of the remediation efforts. We reviewed IA’s report and provided recommendations to finalize revisions. This conclusive phase marked the successful completion of the project, empowering the bank to confidently close the action plan and fortify its Records Retention practices in alignment with regulatory requirements.

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