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X1 Enterprise Successfully Passes GDPR-Mandated Data Protection Impact Assessment

By John Patzakis

The European Union (EU) General Data Protection Regulation (GDPR) requires that subject organizations ensure and demonstrate the protection of personal data under their control. GDPR Article 35 mandates that when implementing new data collection technologies or engaging in a major new project involving significant data collection, an organization must perform a Data Protection Impact Assessment (DPIA).

Recently, a Fortune 500 company with global operations successfully implemented X1 Enterprise to address their eDiscovery and information governance requirements throughout the EU region, involving both Microsoft 365 and on-premises data sources. This implementation required the vetting of X1 Enterprise by auditors and the internal Data Protection Officer through an extensive DPIA process, which X1 passed. The effort provides important industry insights into how our Fortune 500 customer leveraged X1’s unique, on-premises index-in-place and targeted search and collection features, as well as other data minimization capabilities, to meet the DPIA requirements.

The EU provides official guidance and a checklist for conducting an Article 35 DPIA. Among the key requirements is the consideration of the “current state of the technology” in the area and that the technology and collection processes have adequate “proportionality measures” in their collection capabilities to “ensure data minimalisation.” If processes and technology engage in overly broad data collection, the guidance suggests considering alternative technologies and methods.

The team at our Fortune 500 customer emphasized the following unique data minimalization capabilities and features of X1 Enterprise in their DPIA:

  1. Index and Search Data In-Place. X1’s proprietary micro indexes enable the searching of data on laptops, file servers and Microsoft in-place so that only the potentially relevant data is collected for eDiscovery and data audits, which fulfills the GDPR’s proportionality requirements. In contrast, tools that require full disc imaging for basic eDiscovery collection are extremely problematic.

    As the court said in In re Ford Motor Company, 345 F.3d 1315: “[E]xamination of a hard drive inevitably results in the production of massive amounts of irrelevant, and perhaps privileged, information…” Even worse, the collected data is then re-duplicated, often multiple times, by the examiner for archival purposes. And then the data is sent downstream for processing, which results in even more data duplication. Load files are created for further transfers, which are also duplicated. Notably, EU guidance for a DPIA analysis requires that organizations consider alternative data collection technologies and methods that have better “proportionality measures” to “ensure data minimalization.”
  2. Blind Searches and User Enabled Review. Using X1 Enterprise, an administrator can run detailed system wide searches and receive a detailed search result report without having access or possession of the target data. Instead, the administrator can direct X1 to first present the search results to the end-user employee to review and apply tags to identify personal, relevant or non-personal data, thereby applying clear and detailed consent to the subsequent collection of any relevant information.
  3. Segmentation of Data Regions vs. Creation of Central Data Lakes. X1 can be deployed behind an organizations’ firewall or their own private cloud instance in the EU. Each custodian/employee is associated with a single micro-index. This allows X1 to target searches to specific EU counties and segments of users. This contrasts to archiving or other eDiscovery tools that require bulk copying and intermingling of all user data to a central location, where additional back-up copies are made, all which directly run afoul of the data minimalization and proportionality requirements of the GDPR.
  4. Delete Data In-Place. GDPR requires the deletion of non-compliant on demand. Purging data on managed archives does not suffice if other copies are on laptops, unmanaged servers and other unstructured sources. X1’s on-premises distributed architecture uniquely enables the systematic deleting of data in place.
  5. Platform to Enforce GDPR and Privacy Policies. In addition to asserting X1 met the requirements and standards under GDPR mandated DPIA, our Fortune 500 customer noted as further justification in their DPIA that they also planned to utilize X1 Enterprise to enforce privacy policies and provisions under the GDPR. X1 Enterprise is an ideal platform to respond to Data Subject Access requests, proactively audit data sources to identify and remediate personal information, as well as systematically purge unneeded data that may contain personal information of EU data subjects.

    Ready to Learn More?
    For companies navigating complex information governance and eDiscovery requirements, including those involving M365, the  X1 Enterprise Platform ensures compliance while protecting privacy. By implementing X1 Enterprise, organizations can not only reduce costs and save valuable time but also gain a strategic advantage in managing their information governance needs. For a demonstration of the X1 Enterprise Platform, contact us at sales@x1.com. For more details on this innovative solution, please visit www.x1.com/solutions/x1-enterprise-platform.

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Filed under Best Practices, Case Study, Cloud Data, compliance, Data Audit, eDiscovery & Compliance, GDPR, Information Governance, Information Management, law firm, m365, Preservation & Collection

Inactive Mailboxes, Unlocked: How X1 Enterprise Transforms M365 Data Discovery and Compliance

By Chas Meier and John Patzakis

In today’s compliance-driven environment, organizations must retain, discover, and manage large volumes of email data—even when the employees who once owned that data have long since departed. In Microsoft 365 (M365), this is managed through the concept of “inactive mailboxes.” An inactive mailbox is a mailbox that remains accessible for legal, regulatory, or compliance reasons, but no longer corresponds to an active user. While these preserved data stores are critical for eDiscovery, compliance, and investigations, they can pose significant challenges when it comes to efficiently locating, searching, and collecting the information they contain.

Fortunately, the latest innovations from X1 Enterprise are transforming how organizations handle these inactive mailboxes, making it easier and more streamlined than ever to discover and collect critical information—no matter where it resides.

What Are Inactive Mailboxes in M365?
Inactive mailboxes are mailboxes retained after a user leaves an organization, even after their license is removed. By placing a mailbox on legal hold or under a retention policy before deprovisioning the user, you can preserve it indefinitely without incurring licensing costs. This ensures the data remains accessible for compliance and eDiscovery. Best practices include applying holds before removing accounts, treating inactive mailboxes as part of ongoing governance efforts, and lifting holds once no longer needed.

The Process of Searching Inactive Mailboxes in Purview
In Microsoft Purview (the compliance and security center for Microsoft 365), users granted the eDiscovery manager role and each provisioned with an E5 license can search across both active and inactive mailboxes to fulfill legal or regulatory requirements. Generally, the process involves:

  1. Identifying the Inactive Mailboxes: Administrators must first know which mailboxes are inactive. Inactive mailboxes do not appear in the standard active user lists and often require additional steps to locate—either through the Purview interface, the Microsoft 365 admin center, or by running PowerShell scripts.
  2. Setting Up Permissions and Scope: The person performing the search needs appropriate eDiscovery roles in Purview. Once permissions are granted, they create a new content search or eDiscovery case and include the specific inactive mailboxes in the scope.
  3. Applying Search Criteria: Administrators can filter the search by date, keywords, sender/recipient, or other criteria. After running the search, Purview indexes the content and returns results for review and export.

Why Users Find It Challenging
Users face significant challenges when searching inactive mailboxes due to limited visibility—these mailboxes do not appear with active ones, requiring extra effort to locate and include them. Additionally, complex eDiscovery and compliance roles can be difficult to manage, particularly in organizations with large teams or complicated approval processes. A lack of a unified interface means working across multiple portals, tools, or scripts, leading to a fragmented and easily mismanaged workflow. Finally, without an intuitive, consolidated process, adding inactive mailboxes into search scopes, running queries, and ensuring data completeness is time-consuming and more prone to errors.

As organizations scale and accumulate thousands of these mailboxes, these difficulties multiply. Managing a vast, growing inventory of inactive mailboxes transforms a cumbersome task into a formidable burden, slowing down investigations, audits, and regulatory responses, and increasing the risk of overlooking critical data.

Many organizations resort to re-hydrating inactive mailboxes by applying an active M365 license to each one (“throwing licensing”), copying all M365 mailboxes of departed employees in a separate non-Microsoft archive (“throwing archiving”), or bringing inactive mailboxes into the litigation workflow (“throwing services”) to address the problem when faced with eDiscovery requests. Each of these approaches is extremely expensive, burdensome, and fraught with risk.

Driving the Transformation of Inactive Mailboxes through New Capabilities
X1 Enterprise has long been a trusted solution for comprehensive and targeted search across M365 data sources, file servers, and endpoints. With the new release of X1 Enterprise version 5.3, X1 is taking an industry-leading step forward in how organizations manage and leverage their inactive mailboxes.

How X1 Enterprise Revolutionizes Inactive Mailbox Management:

  • Unified Discovery Experience: With X1 Enterprise 5.3, legal and compliance professionals can now select inactive mailboxes directly within the platform. Instead of treating inactive mailboxes as separate or isolated repositories, X1 provides a consistent, familiar interface—just like working with active mailboxes.
  • Centralized Indexing and Search: Once selected, inactive mailboxes can be staged, indexed, searched, and collected using the same intuitive workflows. This streamlines eDiscovery, ensures rapid insights, and reduces the administrative burden on IT and compliance teams.
  • Seamless Integration with Microsoft Purview: X1 Enterprise automatically discovers and presents your full list of inactive mailboxes stored in Microsoft Purview (formerly Office 365 Security & Compliance Center) using only a single E5 license. This direct integration ensures that all preserved mailboxes are readily visible and actionable.
  • Consistent Identification and Collection Workflows: By applying the same workflows to both active and inactive mailboxes, X1 Enterprise eliminates confusion and complexity. The result is a more efficient and effective approach to responding to legal requests, regulatory audits, and internal investigations.

Benefits of the New Approach:

  1. Faster Response Times: Legal and compliance teams can rapidly identify and collect relevant information from inactive mailboxes without reinventing the wheel for each scenario.
  2. Improved Efficiency: In-place indexing and targeted searching with X1 Enterprise reduces administrative overhead and streamlines processes without the need to “boil the ocean,” thereby vastly reducing licensing costs with no need for 3rd party services or archiving platforms.
  3. Reduced Risk: Consistent workflows lower the chance of missing critical data or mismanaging preserved mailboxes.
  4. Enhanced Transparency: Having a clear, uniform process for both active and inactive mailboxes bolsters your overall information governance framework.

In Conclusion: Embrace the Future of Inactive Mailbox Management
Inactive mailboxes are here to stay, as legal and regulatory requirements continue to mandate the preservation of key business communications. Instead of viewing these repositories as a burden, forward-thinking organizations can leverage advanced technologies like X1 Enterprise 5.3 to take control of their compliance landscape.

Ready to Learn More?
The X1 Enterprise Platform is available now from X1 and its global channel network in the cloud, on-premises, and with our services available on-demand. For a demonstration of the X1 Enterprise Platform, contact us at sales@x1.com. For more details on this innovative solution, please visit www.x1.com/solutions/x1-enterprise-platform.

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Filed under Best Practices, Cloud Data, Corporations, eDiscovery, eDiscovery & Compliance, Enterprise eDiscovery, ESI, Information Governance, Information Management, m365, Preservation & Collection

Industry Experts Address Information Governance Challenges in Microsoft 365

By John Patzakis

Successful information governance in a Microsoft 365 environment can be extremely challenging. Organizations require ways to operationalize their compliance processes, in order to effectively address their information governance use cases, such as PCI compliance, ROT, Data separation, and GDPR. However, Microsoft’s Purview eDiscovery platform is a very expensive add-on to M365 that does not scale to the data throughput requirements of a typical information governance project.

This is because M365 is a massive data ocean that is not purpose-built for compliance and eDiscovery, and so a new “compliance index” must be created with data carved out of the M365 ocean to initiate an eDiscovery or compliance case in Purview eDiscovery to ensure proper and complete content indexing. As a result of this disjointed two-step process, users are encountering significant problems with low throughput and defensibility. Many customers report to us that Microsoft Purview Premium’s documented inability  to handle anything other than small matters due to their 2GB per hour throughput limit. A matter involving 100 custodians at 10GB of M365 data would take several weeks to complete with Microsoft Purview Premium.

Last week X1 hosted a webinar with industry leaders Randy Kahn and Chas Meier to discuss information governance challenges in an M365 environment. Kahn outlined information governance principles and priorities in general and then emphasized how technical automation is essential to enforce and execute on any implemented information governance policies and procedures.

Kahn’s overview segued into Meier’s discussion and demonstration on how the X1 Enterprise Platform is the best solution available for managing M365 data sources as well as on-premises sources like laptops and file shares. Meier highlighted recent case studies involving large-scale projects where X1 was able to search and analyze terabytes of M365 information very accurately and in a fraction of the time required for other means, including Microsoft Purview.

Meier explained how the X1 Enterprise platform’s unique architecture allows it to index nearly ten times the daily volume compared to Purview or other competitive “connector” technologies. X1’s patented distributed micro-index-in-place architecture, combined with horizontal scaling, makes X1 the only solution capable of handling rapid indexing, identification, searching, and remediation of massive data sets in the terabytes across M365 sources, including modern attachments and inactive mailboxes. Additionally, X1 effectively addresses both cloud and on-premises data sources in a unified manner, including distributed endpoints, network file shares, and multiple M365 services like Mail, OneDrive, Teams, and SharePoint.

A copy of the webinar recording can be accessed HERE.

For companies navigating complex information governance and eDiscovery requirements, including those involving M365, the  X1 Enterprise Platform ensures compliance while protecting privacy. By implementing X1 Enterprise, organizations can not only reduce costs and save valuable time but also gain a strategic advantage in managing their information governance needs. We invite you to explore how X1 can transform your data management processes and help you stay ahead in the ever-evolving digital landscape.

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Filed under Best Practices, Corporations, ECA, eDiscovery, eDiscovery & Compliance, Enterprise eDiscovery, ESI, GDPR, Information Governance, m365, Preservation & Collection

Addressing Critical Information Governance Challenges from Departing Employees

By John Patzakis and Chas Meier

When employees leave an organization, they often leave behind a significant amount of valuable information. This poses major information governance challenges, as companies must decide how to manage litigation holds and retain essential data assets.

A common response to this challenge is to retain departed employees’ laptops, hard drives, or keep their Microsoft 365 or Google Workspace accounts active. However, this approach is both expensive and inefficient. Another often-used method is creating a full disk image of the laptop for archiving. While this preserves data, it is a slow and cumbersome process that can require vast amounts of storage, sometimes reaching petabytes, which becomes both costly and unwieldy. Neither approach offers the ability to gain insights from the data, nor do they allow for intelligent and targeted data extraction, making it difficult to leverage these data assets effectively or comply with legal and regulatory requirements.

To address these challenges, X1 has developed a game-changing workflow utilizing our X1 Enterprise Platform, offering a streamlined and cost-effective solution. With our platform, organizations can process hundreds of laptops and Microsoft 365 accounts in a single day. Leveraging X1’s unique and patented in-place indexing technology, data extraction becomes highly targeted, allowing for efficient responses to litigation holds. This means that each litigation scenario can have a tailored search applied across all relevant data sources simultaneously, enabling precise data extraction.

For example, one company with over two dozen active litigation holds has employed X1’s solution, allowing them to save detailed keyword search routines crafted by their counsel. These searches can be quickly and programmatically applied not only to data on specific laptops but also to archived PSTs and associated Microsoft 365 accounts. Once the targeted data is extracted, the company repurposes the laptops for new employees, resulting in significant cost savings—estimated to be in the millions—and a reduction in storage requirements.

Beyond managing litigation holds, another core benefit of X1’s solution is its ability to extract key data assets from departed employees to retain within the company’s knowledge base. This capability is especially valuable for law firms, consulting firms, and organizations that rely heavily on high-end knowledge professionals. For instance, one law firm uses X1’s workflow to rapidly search large, archived PST files from departed attorneys to identify and separate key data related to ongoing matters. This ensures that crucial information remains accessible to the firm or is appropriately transferred to the attorney’s new firm. Additionally, vital legal and business insights from retained documents and emails are quickly mined and reviewed, enhancing the firm’s overall knowledge management.

Client Example:
Overview: A major pharmaceutical retailer uses X1 within Relativity to perform 50 data collections weekly, covering both Mac and PC environments. The system allows them to repurpose laptops from departed employees within days instead of months, leading to substantial savings.
Integration: The company eliminated the need for traditional eDiscovery tools to remediate laptops, opting instead for X1’s more efficient approach.
Time and Cost Savings: This shift has saved the company millions by:
1. Reducing the reliance on costly traditional eDiscovery tools.
2. Minimizing the risk and cost associated with retaining unnecessary data.
3. Reintroducing millions of dollars’ worth of computer equipment back into circulation.
4. Completing these processes in one-tenth the time it would have traditionally taken, vastly improving operational efficiency.

Conclusion:
In today’s fast-paced and data-driven world, organizations face numerous challenges when it comes to managing and retaining data from departed employees. Traditional methods, such as retaining physical devices or creating full disk images, are not only costly and time-consuming but also fail to provide the flexibility and insight needed to effectively manage information assets. X1’s innovative solutions, particularly its patented in-place indexing technology, offer a modern, scalable, and efficient alternative. By enabling targeted data extraction, streamlining the process for litigation holds, and supporting knowledge retention, X1 empowers organizations to manage data governance with precision and agility.

For companies navigating complex data environments, especially those utilizing BYOD policies, X1 Enterprise Platform ensures compliance while protecting privacy. By implementing X1’s advanced platform, organizations can not only reduce costs and save valuable time but also gain a strategic advantage in managing their information governance needs. We invite you to explore how X1 can transform your data management processes and help you stay ahead in the ever-evolving digital landscape.

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