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Mastering Information Governance with the ARMA IGIM 2.1 Framework – Part 3: Operationalizing the Framework

By Kathryn Rattigan & Jim Merrifield on July 10, 2025
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Last week, we outlined the building blocks for a strong IG program. Now that you’ve laid the groundwork, it’s time to bring your IG program to life. The ARMA IGIM framework emphasizes operational execution in three key areas:

  1. Procedural Framework
  2. Capabilities
  3. Information Lifecycle

These domains are where your framework tangibly interacts with AI systems, ensuring tools like machine learning models work with clean, structured data.

1. Procedural Framework

Your Procedural Framework establishes consistent policies, roles, and accountability measures. For AI, having standardized processes ensures that models produce reliable outputs.

Key for AI Adoption:
Without uniform procedures, AI systems can misinterpret data. For example, inconsistent naming conventions in datasets can skew analytics or predictions.

Actionable Tip: Create a policy requiring metadata tagging for all incoming data to improve accessibility for AI models.

2. Capabilities

Capabilities refer to the tools and technologies that power your IG program. AI tools are only as good as the systems they connect with.

Key for AI Adoption:
Role-based access controls prevent sensitive data from being used irresponsibly in AI training, while metadata management enhances the searchability of training datasets.

Example: A retail company equipped its e-commerce platform with AI product recommendations. By integrating IGIM-driven policies on access control and metadata, they ensured only accurate, permissible data informed the algorithms.

3. Information Lifecycle

AI relies on data that evolves through its lifecycle—from creation to disposition. The Information Lifecycle ensures that outdated or incorrect data doesn’t compromise AI tools.

Key for AI Adoption:
By defining retention schedules, organizations ensure AI models are trained on relevant data, reducing errors and increasing trust in outputs.

Next week, we’ll discuss how to sustain your IG program, enabling continuous innovation with AI.

What can you do now? Make sure that your data policies, tools, and lifecycle management strategies are aligned to support your AI-driven initiatives.

Photo of Kathryn Rattigan Kathryn Rattigan

Kathryn Rattigan is a member of the Business Litigation Group and the Data Privacy and Security Team. She concentrates her practice on privacy and security compliance under both state and federal regulations and advising clients on website and mobile app privacy and…

Kathryn Rattigan is a member of the Business Litigation Group and the Data Privacy and Security Team. She concentrates her practice on privacy and security compliance under both state and federal regulations and advising clients on website and mobile app privacy and security compliance. Kathryn helps clients review, revise and implement necessary policies and procedures under the Health Insurance Portability and Accountability Act (HIPAA). She also provides clients with the information needed to effectively and efficiently handle potential and confirmed data breaches while providing insight into federal regulations and requirements for notification and an assessment under state breach notification laws. Prior to joining the firm, Kathryn was an associate at Nixon Peabody. She earned her J.D., cum laude, from Roger Williams University School of Law and her B.A., magna cum laude, from Stonehill College. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.

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Photo of Jim Merrifield Jim Merrifield

Jim Merrifield is Robinson+Cole’s Records & Information Governance Manager, a member of the Data Privacy + Cybersecurity Team, and a non-attorney contributor to the Data Privacy + Security Insider blog. He has spent more than a decade helping organizations of all sizes, including…

Jim Merrifield is Robinson+Cole’s Records & Information Governance Manager, a member of the Data Privacy + Cybersecurity Team, and a non-attorney contributor to the Data Privacy + Security Insider blog. He has spent more than a decade helping organizations of all sizes, including law firms and  Fortune 500 companies, develop and implement practical information governance strategies, policies, and best practices. He has authored numerous publications and frequently speaks on information governance and data privacy issues. Jim holds a bachelor degree in Legal Studies from Quinnipiac University and is a certified information governance professional (IGP).

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  • Posted in:
    Intellectual Property
  • Blog:
    Data Privacy + Cybersecurity Insider
  • Organization:
    Robinson & Cole LLP
  • Article: View Original Source

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