eDiscovery is subject to trends, like fashion or the latest iPhone application. The newest trend climbing the charts is project management, so I thought it was timely to write about project planning before all the cool kids go sit at another table.
Now, I've had some experience with project planning in my time, and what I've learned is that no plan survives contact with (fill in the blank). Some have even used this as an excuse NOT to plan, since the estimates will always be off, targets will be missed and you'll spend all your time explaining why. However, this misses the point, since the object of the exercise is to figure out what you know, and more importantly, what you don't know.
If this is beginning to sound like the gibberish you'd get in Wonderland, pause for a moment and reflect on this: if you know what you don't know, you can build in extra time and resources as a contingency. If you know what you don't know, you can make it a priority to go looking for information to fill in the blank and firm up your estimates.
Some things to consider in drafting the plan:
- Scope of the information to be collected, processed, reviewed and produced, and any decisions about staging production
- Structure of the project team for each of the main activities (collection, processing…), including description of skills required
- Resourcing – internal resources combined with external contracts, and their availability
- Budget for external resources, services and tools
- Roles and responsibilities of the members of the team
- Governance – who makes decisions about scope, budget, resources and timeframes
- Assumptions (e.g. volumes expected from sources, rates of collection, processing and review, availability of internal resources, time required for tool acquisition, among others)
- Risks (e.g. new allegations or defences added to pleadings, unexpected problems with degraded or encrypted media or files) that could threaten delivery of the project within budget and schedule, and mitigation strategies
- Documentation to be developed – such as coding and processing manuals, instructions for review for relevance and privilege, etc.
- Work breakdown structure of the tasks, their dependencies, who is assigned to each and the schedule
- Quality control – processes used to ensure integrity and completeness, and conformance with scope for collection and processing, and compliance with instructions for review.
- Communications, including progress reporting, exception reporting, and problem tracking and resolution.