Data Maps

Data Maps are always referred to in guides to electronic discovery, but the definitions are somewhat nebulous and examples are rarely provided. ACEDS defines a Data Map as "periodic survey of an organization's digital landscape" . This survey must describe the following on a network

1. The ESI formats in use.

2. Data stores that have been archived.

3. The process for backing up data.

4. Data purging schedules and policies.

5. Network access controls.

6. Reporting capabilities of storage systems.

7. Audit trail capabilities of the system

8. Security features for the network

9. Server types

10. Offline data stores

11. Paper / hard copy records

The EDRM glossary states that, "Data mapping finds or suggests associations between files within a large body of data, which may not be apparent using other techniques.

Perhaps even more importantly, the Courts have begun to define data maps.

In, HydroChem, LLC v. Duplessis, 14-264 (M.D. La. May 28, 2015) federal judge Richard Bourgeois in an order giving an ESI protocol, which aside from setting the date range of electronic discovery, fixing keyword search terms, and identifying custodians for data collection, also instructed the parties to produce data maps within 15 days. The Middle District of Louisiana instructed the parties to "exchange information regarding the location and existence of electronic data sources that may contain discoverable ESI (the 'Data Map') including information regarding the parties' policies and/or procedures regarding data retention; their computer servers and back-up and archival sources that store ESI; all computers, phones, tablets, and other storage devices issued to the Custodians or used by the Custodians for business purposes; all email accounts and cloud-storage/file-sharing service accounts used by the Custodians for business purposes; and any data source that the party identifies as not reasonably accessible pursuant to Fed. R. Civ. P. 26(b)(2)."

On his blog, Craig Ball says, "I use 'data mapping' to encompass methods used to memorialize the identification of ESI–an essential prerequisite to everything in the EDRM east of Information Management." He notes that there are rarely graphical representations of digital landscapes that the word 'map' suggests but instead spreadsheets are often used.

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