The EDRM 2.0 model, released in September, introduces four key changes, including integrating the Information Governance Reference Model (IGRM) as a foundational layer and adding Disposition as a distinct phase. If you're responsible for legal hold, retention schedules, or eDiscovery workflows, you need to audit your program against this update. Here's how to do it systematically.
Why This Matters
Your RFPs, vendor contracts, and training materials reference a framework that just changed. The EDRM has organized eDiscovery vocabulary for two decades, and when it shifts, procurement documents and service catalogs eventually follow. This isn't a compliance mandate, but a consensus reference developed by about 150 contributors over two years. If your team uses EDRM terminology in statements of work or matter management protocols, you're working with outdated language until you reconcile your documentation.
The practical impact hits three areas. First, EDRM 2.0 defines Disposition as "a systematic, defensible process to retain, delete, transfer, or return data after use." This provides a reference point for updating retention schedules or defensible deletion protocols. Second, the model groups Identification, Preservation, Collection, and Processing under a Data Acquisition framework, reflecting how modern tools work, which may differ from your contract descriptions. Third, the IGRM now underpins the entire lifecycle, altering how you present governance in internal discussions.
What You Need Before Starting
Gather your current documentation:
- RFPs or vendor contracts referencing EDRM phases
- Internal training materials using the EDRM diagram
- Records Control Schedule entries referencing eDiscovery workflows
- Legal hold protocols citing specific EDRM stages
- Statement-of-work templates used with outside counsel
You'll also need the published EDRM 2.0 diagram and the public comment response document from EDRM's project page. The reasoning behind changes is crucial for your audit.
Step-by-Step Implementation
Phase 1: Audit Your Vendor Documentation
Review active eDiscovery vendor contracts for terms like "Processing," "Collection," "Identification," and "Preservation." If these are priced or serviced separately, flag them. EDRM 2.0 groups them under Data Acquisition, so your next RFP should reflect that vendors increasingly offer integrated capabilities.
Check if contracts reference the EDRM diagram by version number or include it as an exhibit. Decide whether to amend existing agreements or update templates for future procurements. Most organizations will choose the latter.
Phase 2: Reconcile Disposition with Your Records Control Schedule
The addition of Disposition as a formal phase provides a framework for defensible deletion. Review your Records Control Schedule for series where disposition authority reads "delete after litigation hold release" or similar language.
Compare this against EDRM's Disposition definition. If your schedule lacks systematic criteria for deletion, transfer, or return, you're exposed. Use the EDRM reference to justify adding those criteria. For example, revise "delete when no longer needed" to specify the event triggering disposition and the verification method.
Document this reconciliation in a memo to your legal team, framing it as aligning with an updated industry reference model.
Phase 3: Update Training Materials
Update internal training decks with the EDRM 2.0 diagram. Add a slide explaining what changed and why it matters to your team.
Focus on two points: First, the IGRM foundation means governance isn't separate from eDiscovery readiness. Second, the Analysis band now runs continuously across all phases, reflecting reality where relevance decisions happen at collection, not just review.
Rewrite any speaker notes that describe EDRM as a workflow. Emphasize that it's "a reference model, not a prescriptive workflow."
Phase 4: Revise Legal Hold Protocols
Review your Records Freeze procedures for references to specific EDRM phases. Update language to reflect that Preservation is part of Data Acquisition and that Analysis spans the entire lifecycle.
This isn't just semantics. If your protocol assumes Preservation is a discrete stage ending before Review, you're not accounting for iterative collection or rolling productions. Revise the language to reflect continuous custodian identification and preservation decisions.
Phase 5: Pressure-Test Your RFP Templates
If you issue RFPs for eDiscovery services, update templates to reference Data Acquisition for early-stage work and add a question about Disposition capabilities.
Ask vendors: "Describe your systematic process for data disposition after matter closure, including deletion verification, transfer protocols, and return-to-custodian workflows." This forces vendors to document their capabilities.
Validation: How to Verify It Works
Run a spot check three months after implementation. Review a recent matter to see how your team described each phase in status reports or invoices. If pre-2.0 terminology persists, your training didn't stick.
Check if outside counsel or vendors use EDRM 2.0 language in their deliverables. If not, send them the updated diagram with a note that your organization has adopted it as a reference. This maintains a common vocabulary.
Review your Records Control Schedule for new series added since the update. Verify that disposition authorities include systematic criteria as defined by EDRM. If new entries still use vague language like "delete when appropriate," your reconciliation process failed.
Ongoing Tasks
Set a reminder for Q1 each year to review any EDRM clarifications or supplemental guidance. Include EDRM 2.0 in new staff training. Check vendor contracts for alignment with EDRM 2.0 terminology. If your organization uses the EDRM diagram in external communications, update those materials now. Perception matters, and the diagram signals your program's alignment with current frameworks.
