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Minding the Gap: Are We Missing Label Varieties in M365?

Microsoft Purview offers various labeling options to help organizations manage their content effectively. These labels—Retention, Records, and Regulatory Records—each serve distinct purposes and come with their own sets of features and limitations.


I believe that some gaps in their design could lead to compliance risks and operational challenges. This post aims to highlight these gaps, focusing on the shortcomings in Records Labels regarding metadata immutability and the restrictive nature of Regulatory Record Labels.


I previously posted a blog entry regarding the issues with Regulatory Records that could lead to potential non-compliance and how treacherous they could become in organizations that do not invest in governance or Information Architecture design. This is precisely the reason why Regulatory Record Labels, while providing the desired immutability for both content and metadata, are not being considered as the perfect solution.


Gaps in Microsoft Purview Label Options


Existing

Existing

Existing

Proposed

Feature

Retention Label

Record Label

Regulatory Record Label

Record Label with Immutable Metadata and Content

Purpose

Manage lifecycle of working documents, internal use, business value assets, and those not subject to regulatory requirements

Declare content as records; manage some business value assets with Locked/Unlocked functionality

Ensure compliance with strict regulations

Ensure metadata and content immutability while allowing label or duration changes

Content Immutability

Not enforced

Not enforced when Unlocked; Enforced when Locked

Enforced

Enforced

MetadataImmutability

Not enforced

Not enforced

Enforced

Enforced

Compliance Assurance

Basic lifecycle management, not for records

Moderate compliance

High compliance

High compliance

Use Case

Document stage of lifecycle, Business Value assets

Records management with some flexibility; suitable for some business value assets with Locked/Unlocked functionality

Strict records management

Strict records management with flexibility in label and duration management

Gap 1

Not suitable for regulatory record keeping

Allows changes to metadata

Fully compliant but rigid

None - Suitable for regulatory record keeping with flexible administration

Gap 2

Basic compliance features

Metadata changes undermine record integrity

Lack of flexibility for evolving needs

None - No metadata changes, maintaining record integrity

Gap 3

Limited to basic retention functionality for working documents and business value assets (and in some cases, DLP-like functionality for working documents)

Limited audit capabilities for metadata changes

May be overly restrictive for some scenarios

None - Comprehensive audit capabilities for both content and metadata

The key gap in Microsoft Purview’s Record Labels is their allowance for metadata changes, which contradicts the fundamental concept of records management. Ensuring metadata consistency and integrity is crucial for maintaining the authenticity of records, which is a regulatory requirement for many organizations.


On the other hand, Retention Labels serve well for managing the lifecycle of working documents, internal use, and Business Value assets but fall short for serious record-keeping.


While Microsoft does offer Regulatory Record Labels, their highly restrictive nature makes them less suitable for setups that are not strictly governed or well-designed. The irreversibility of actions taken under Regulatory Record Labels can be a significant risk if not managed correctly.


Therefore, recommending Record Labels can be a more practical approach. With strict governance in the Purview Center, Record Labels can become effectively immutable in practice when locked. However, since metadata can still be changed, they do not fully meet the requirements for ensuring the integrity and authenticity of records in compliance-heavy environments.


Proposed Solution


Introducing a new type of label: Record Labels with Immutable Metadata and Content.


This label would combine the flexibility of Record Labels with the assurance that both content and metadata cannot be altered, while still allowing administrators to change the label applied to the document or the duration. There should be no locking/unlocking of the records with this label type. Both Record Content and Metadata should always be locked.


Why It's Worth Considering


Based on experience, here are some key points:

  1. Regulatory Compliance: Many organizations must adhere to strict regulatory requirements. This proposal addresses these needs more comprehensively, helping organizations avoid compliance risks.

  2. Practical Flexibility: While Regulatory Record Labels are very rigid, this suggested label offers a balance by providing immutability for content and metadata while allowing necessary administrative flexibility.

  3. Improving the Product: Constructive feedback is vital for product improvement. Highlighting these gaps can help Microsoft enhance their product, ultimately benefiting all users.

  4. User Advocacy: Advocating for the needs of users and organizations is always valuable. If these gaps are causing challenges, it’s important for Microsoft to be aware so they can address them.




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