Immutability in Exchange

re: Immutability in Exchange

Ankur Kothari MSFT — Wed, 22 Aug 2012 17:11:03 GMT

@Carl

PST Capture is limited to 1000 users today only for Exchange Online, not for on-premises. We will take the feedback for Online though - thank you.

Ankur

re: Immutability in Exchange

Carl — Wed, 22 Aug 2012 07:54:44 GMT

Hi Perry, PST capture is not overly helpful given its got a 1000 limit cap! Does pose some challenges to large orgs. Any thoughts on this?

re: Immutability in Exchange

Ankur Kothari MSFT — Tue, 24 Apr 2012 21:10:57 GMT

The statement at the end of the paragraph you quoted is the part I would like to hold onto. Exchange does not create a fingerprint to notify you that the data was there.

Using a fingerprint/finger analogy:

If the item is "deleted" by a user, the finger (not fingerprint) is retained without modifying the integrity of the message.

If the item is changed, the original finger is retained, and a second finger is created with the new modified data. (What we call copy-on-write).

At the same time, we also provide the finger print for all access (auditing).

there is another portion where it states that "do not prevent the a record from being changed or deleted" - Exchange nevers alter the item.

Ankur

re: Immutability in Exchange

Paul — Tue, 24 Apr 2012 17:43:07 GMT

Hello Ankur and Perry,

Just checking in again to see if you agree that Microsoft does or does not comply with SEC 17a-4 as listed in the SEC interpretation above?

Thanks,

Paul

re: Immutability in Exchange

Paul — Fri, 13 Apr 2012 14:32:54 GMT

Thank you Ankur! I appreciate the follow up. Sorry to continue pressing the point but there is the potential for significant architecture simplification if Microsoft guarantees compliance to the SEC rulings.

The SEC has an article titled the "Interpretation of Electronic Storage of Broker-Dealer Records" at the following link.

www.sec.gov/.../34-47806.htm

Your comments are in line with what broker-dealers and vendors have asked for but the Commission's interpretation towards the middle of the 3rd page makes me uneasy:

"The Commission's interpretation does not include storage systems that only mitigate the risk a record will be overwritten or erased. Such systems - which may use software applications to protect electronic records, such as authentication and approval policies, passwords or other extrinsic security controls - do not maintain the records in a manner that is non-rewriteable and non-erasable. The external measures used by these other systems do not prevent a record from being changed or deleted. For example, they might limit access to records through the use of passwords. Additionally, they might create a "finger print" of the record based on its content. If the record is changed, the fingerprint will indicate that it was altered (but the original record would not be preserved). The ability to overwrite or erase records stored on these systems makes them non-compliant with Rule 17a-4(f)."

I go back and forth on what this means and how it applies to Exchange 2010.

re: Immutability in Exchange

Ankur Kothari MSFT — Thu, 12 Apr 2012 23:01:42 GMT

err - the above was for Paul, not Perry.

re: Immutability in Exchange

Ankur Kothari MSFT — Thu, 12 Apr 2012 23:01:18 GMT

Perry,

Section iii states the following: "Broker-dealers and vendors of electronic record storage systems have asked whether broker-dealers may use, consistent with Rule 17a-4(f), systems they describe as storing records in a manner that prevents the records from being overwritten, erased or otherwise altered without relying solely on the system's hardware features. Specifically, these systems use integrated hardware and

software codes that are intrinsic to the system to prevent the overwriting, erasure or alteration of the records. Thus, while the hardware storage medium used by these systems (e.g., magnetic disk) is inherently rewriteable, the integrated codes intrinsic to the system prevent anyone from overwriting the records."

By using legal hold or rolling hold, you are using such software based codes.

re: Immutability in Exchange

Paul — Thu, 12 Apr 2012 13:59:13 GMT

To be clear. Are you saying that Microsoft Exchange 2010 meets industry regulations, specifically SEC 17a-4(f)(2)(ii)(A) that states that the electronic storage media must preserve records exclusively in a non-re-writeable, non-erasable format?

re: Immutability in Exchange

Ask Perry — Fri, 24 Feb 2012 18:39:23 GMT

Thanks for your interest in the topic @Charles

@Michael -- Yes, we have the same features available in Exchange Online.

re: Immutability in Exchange

Michael — Thu, 23 Feb 2012 07:05:36 GMT

Can I achieve the same using Exchange Online?