With mobile executives storing information on their notebook hard drives, any given piece of data might be on a notebook flying to Milwaukee, in an Access database across the hall, or scattered across dozens of different tables built for end-of-year financial statements.

The solution is to create the data map before you need it. Because there is no business software currently available that can automatically seek out all your data sources and dump them into a document of some kind, IT and legal must come together, not only to map what the data sources are but to record which business processes they touch.

Of course, if you already have a good records-retention policy in place, it will dictate what data your company is going to keep and where it is located. Obviously, the "where" is the link to the data sources.

Companies must identify the departments and employees with custody of the data, and they must create a stewardship that includes a container expert (data source), content expert, or business unit that owns the data -- and a policy owner for retention, privacy, and security, Paknad advises.

4. Rule 34 (b): Form of production