WORM storage, or "write once, read many" (WORM) compliant storage, is a regulatory necessity in industries like finance, healthcare, and government.

In these industries, failing to keep WORM-compliant archives of your organization’s records can lead to serious penalties. Just ask the 12 firms, including Wells Fargo and RBC Capital, that were fined for a total of $14.4 million by FINRA in 2016 for not properly preserving broker-dealer and customer records in WORM format. 

With regulatory bodies like FINRA and the SEC ramping up enforcement, organizations in regulated industries need to ensure their data is unalterable and secure in WORM compliant storage. In this article, we’ll break down what WORM storage is, why it matters, and how you can use it to avoid fines, protect your data, and boost consumer trust by using WORM compliant solutions.

What is WORM Storage?

WORM stands for “write once, read many.” 

It describes a method of managing data storage that’s often required for compliance with industry regulations. WORM storage ensures that data, once written, can't be altered or deleted, ensuring its authenticity and security throughout its retention period. 

To properly store or archive WORM-compliant data, companies need a system that prevents any data from being altered or erased while still making it easily accessible. WORM storage technology helps protect organizations from accidental data deletion or modification and ensures compliance with regulatory recordkeeping requirements.

Key Features of WORM storage

WORM storage has key features that make it indispensable for regulated industries. These features ensure that data remains secure, unalterable, and compliant with industry regulations.

1. Immutability

The core feature of WORM storage is immutability—once data is stored, it can't be changed or deleted. This ensures that records are preserved exactly as they were, maintaining data integrity over time.

2. Tamper-proof

By design, WORM storage is tamper-proof. This means that even malicious actors or internal errors can’t alter the stored data, giving organizations peace of mind that their records remain untouched and authentic.

How does WORM Storage Work?

As we’ve discussed, WORM storage operates on the principle of "write once, read many." Once data is written to a WORM-compliant system, it is locked, and the system marks this data as immutable, meaning it cannot be altered, deleted, or overwritten. This guarantees that records stay in their original, unmodified state.

WORM storage is not a new thing, it actually predates CD-R and DVD-R technology. The earliest iteration of WORM storage was achieved by writing data onto a layer that physically couldn’t be rewritten. Today, modern systems achieve the same immutability through software.

WORM storage solutions typically use specialized file systems or storage architectures that prevent changes after the data is written. Whether cloud-based or physical, these systems ensure that each piece of data is treated as unchangeable once recorded.

In cloud-based WORM storage, immutability can be enforced through software controls like "object locking" (e.g., AWS S3 Object Lock). Any attempt to modify or overwrite the data triggers an error, and the system blocks the action.

Modern day WORM compliant storage has benefitted from the evolution of cloud-based technology, enabling a higher level of protection and practicality. Instead of relying on physical media, WORM cloud storage offers complete data protection, preservation, and accessibility. Once stored, data is fully immutable—readable as often as needed, but never overwritable or erasable.

Can cloud storage be WORM compliant?

Yes, modern cloud storage solutions can be WORM compliant. Cloud storage providers offer WORM compliant storage options that replicate the same level of immutability traditionally found in on-premises solutions. In fact, many organizations are turning to WORM storage in the cloud due to its flexibility, scalability, and ease of use, all while maintaining full compliance with industry regulations.

How does WORM storage work in cloud environments?

In cloud environments, WORM storage ensures that once data is uploaded, it is locked and unchangeable. Cloud providers like AWS offer WORM compliant features such as the AWS S3 Object Lock used in AWS Glacier. Often cloud-based WORM storage providers add extra layers of protection like encryption, authentication, and audit logs, which work alongside immutability features to safeguard the stored data.

While the amount of data organizations produce and have to retain and protect grows exponentially, cloud-based WORM compliant storage provides a scalable, tamper-proof solution.

What is the difference between a backup and WORM storage?

The key difference between a backup and WORM storage lies in the purpose and functionality. 

A backup is typically designed for disaster recovery—it's a copy of your data that can be restored if needed, but it's often overwritten or updated on a regular basis. 

In contrast, WORM storage ensures that once data is written, it cannot be altered or deleted. 

While backups can be changed or rotated, WORM compliant storage preserves data in its original form, making it ideal for meeting strict regulatory requirements.

The Benefits of WORM Compliant Storage

Archiving data with a WORM-compliant storage solution protects companies from issues like data corruption and loss. Here are the main benefits of using WORM data archives:

1. Data Integrity & Governance

WORM storage supports strong data governance practices across your organization. It also helps you follow the Electronic Discovery Reference Model (EDRM), a model that outlines the stages of the eDiscovery process during an investigation.

2. Regulatory Compliance

For industries bound by strict regulations like SEC Rule 17a-4 and FINRA mandates, WORM-compliant storage ensures that companies are complying with recordkeeping regulations. Failure to comply can be costly. In 2023 alone, FINRA issued $85.5 million in fines, with an increase in supersized fines of $1 million or more.

3. Risk Mitigation & Data Loss Prevention

By ensuring that data cannot be overwritten, deleted, or modified, WORM archiving helps businesses mitigate risks associated with data loss or corruption. This is critical in industries where the loss of records could have serious legal or financial consequences.

4. Enhanced Information Security

With the rise in cyber threats, protecting data from tampering and unauthorized access is more important than ever. WORM storage providers often include features like encryption and tamper-proof security to keep sensitive information secure and unchangeable throughout its retention period.

5. Increased Efficiency

Modern, cloud-based WORM compliant storage solutions usually come with easy search and retrieval capabilities. Since the data is indexed and stored in a structured format, auditors can quickly find what they need without combing through messy records. Audit logs provide transparency into data usage, making it easier to track changes and prove compliance. This efficiency is key in regulated industries, where timely and accurate data retrieval is often required to demonstrate compliance during audits.

Common WORM Compliance Challenges

While WORM compliant storage is essential for maintaining data integrity and regulatory compliance, organizations may face several challenges when implementing these solutions.

1. Technical Complexity

One major challenge of implementing WORM compliant storage is the technical complexity involved. WORM storage requires specialized systems that guarantee immutability while still providing secure access and scalability. Setting up and managing these systems often requires expertise in both storage technology and regulatory standards, leading to a steep learning curve for IT teams.

In such cases, it’s essential to look for WORM compliant storage solutions that provide support, training, and a user-friendly interface. 

2. Legacy Systems

Integrating WORM storage with older, legacy systems can be difficult. Many organizations still rely on outdated technology that may not easily support modern WORM compliant solutions. Upgrading or retrofitting these systems to work with WORM-compliant storage can be both time-consuming and expensive, especially for companies with complex, outdated infrastructures.

To avoid issues, it’s important to work with a provider that has experience with migrating data from legacy systems and has the technical expertise to scope the project accurately from the start so you don’t get stuck with runaway costs and billing surprises.

3. Cost of Implementation

The initial cost of implementing WORM compliant storage systems can be high, as it often involves investing in new hardware, software, or cloud storage. However, these costs are usually outweighed by the long-term benefits, including reduced regulatory risk, enhanced data security, and more efficient audits. The cost of compliance may seem steep initially, but it’s undoubtedly far less than the penalties for non-compliance.

When vetting potential vendors, make sure to ask what’s included in the cost of implementation upfront – is onboarding and data migration an additional cost? 

4. Maintaining compliance across multiple jurisdictions

For multinational organizations, maintaining WORM compliance can be challenging due to different regulations across regions. Each country and industry has unique compliance mandates, and organizations must ensure their WORM storage solutions meet all applicable requirements. Navigating these complex regulatory landscapes takes careful planning and may require working with compliance experts to avoid costly mistakes.

What Industries Require WORM Compliant Storage?

For organizations in regulated industries, maintaining WORM-compliant storage is not just a best practice—it's a critical requirement for avoiding fines, ensuring legal compliance, and protecting sensitive data from tampering. The consequences of non-compliance can be severe, as evidenced by several high-profile cases.

WORM-compliant storage is essential for a range of industries, including:

1. Financial Services

The financial sector must store business-related electronic records in a "write once, read many" format to prevent alteration. This includes everything from emails to transaction records to comply with Securities and Exchange Commission (SEC) Rule 17a-4. 

Companies that accept credit card payments also need WORM storage to meet  PCI-DSS compliance requirements, which protect personal and financial information from tampering. 

Meeting the financial services industry’s requirements can seem daunting, but solutions like Pagefreezer provide automated recordkeeping solutions that comply with all financial industry rules and regulations. 

2. Healthcare

Healthcare providers must meet HIPAA requirements to securely store patient records. WORM storage ensures these records are tamper-proof and retained for the required time periods, helping maintain patient confidentiality and legal compliance.

3. Government Agencies

Government sectors use WORM archiving for official documents, records, and communications. The immutability of these records helps government agencies build trust and increase transparency, particularly when responding to open records requests.

4. Law Firms

Law firms often rely on WORM-compliant systems to archive case-related communications and documents, protecting them from tampering and ensuring proper chain of custody.

5. Insurance providers

For insurers, maintaining tamper-proof records of policies, claims, and customer communications is critical for legal compliance and customer trust.

What Regulations Mandate the Use of WORM Compliant Storage?

SEC Rule 17a-4

As the SEC’s interpretive document on 17a-4(f) simply states,“the WORM requirement is designed to ensure that electronic records are capable of being accurately reproduced for later reference by maintaining the records in an unalterable form.” 

SEC Rule 17a-4 includes specific requirements for verification, serialization, indexing, and duplication of records, including:

• Quality verification of both the recording process itself, and post-recording processes
• Serialization of the original, duplication of units of storage media, and time-date stamps making records easier to locate
• Capacity to download indexes and records to any medium as required
• Storing duplicate copies of records separately from the original
• Organizing and indexing of both original and duplicates
• Duplicating indexes and storing them separately from the original copy of each index
• Storing both originals and duplicates (indexes and records) for specified retention periods
• Having in place an audit system to provide accountability

👉 Learn More About SEC Rule 17a-4 & FINRA Records Retention 

FINRA

While the SEC oversees the broader securities market, The Financial Industry Regulatory Authority (FINRA) specifically regulates brokerage firms and registered securities representatives, enforcing rules to ensure they operate fairly and honestly. FINRA requires records to be stored in WORM format, as alterations or destruction of records would violate compliance standards set out by the SEC that are designed to protect investors.

HIPAA

Healthcare organizations must use WORM compliant storage to secure patient data and ensure that it is not altered, meeting federal requirements for data integrity and privacy under The Health Insurance Portability and Accountability Act (HIPAA).

MiFID II and FCA

In the European Union, financial firms must comply with Markets in Financial Instruments Directive 2014 (MiFID II) regulations, which require WORM storage for archiving communications. 

The UK's Financial Conduct Authority (FCA) has similar mandates, requiring firms to preserve communications in an unalterable format for compliance and audit purposes.

How Long Should Records Be Archived in WORM Format?

The required retention period for records stored in WORM format varies depending on the industry and specific regulatory requirements. Though we cannot provide required retention periods in all industries and regions, generally, these are some retention periods worth noting:

• Financial Services: Under SEC Rule 17a-4, financial institutions must retain records in WORM compliant storage for at least six years, with immediate access required for the first two years.
  
  
• Healthcare: HIPAA mandates that healthcare providers retain patient records for a minimum of six years to ensure compliance with privacy and security regulations.
  
  
• Government Agencies: Retention periods can range from several years to decades, depending on the nature of the records and which state, local, or federal laws apply.

Again, this is far from an exhaustive list so please check with the government, regional, and enforcement agencies that regulate your specific industry to find out exactly how long your organization needs to retain records in WORM compliant storage. 

The WORM Storage Compliance Checklist

Meeting WORM compliance standards is crucial for maintaining data integrity and adhering to regulations. To achieve this, you need to choose a WORM-compliant storage solution that fits your organization’s needs. A reliable WORM storage solution should provide the necessary features to help your organization remain compliant while ensuring long-term security and accessibility of your data. 

Here are key factors to consider when selecting a WORM-compliant storage system:

✅ Regulatory Compliance

Make sure the storage solution meets all applicable regulations—whether it’s SEC Rule 17a-4, FINRA, HIPAA, or mandates specific to your industry. The system must guarantee that records remain unaltered throughout the required retention period.

✅  Scalability

As your organization grows, so does your data. Choose a WORM-compliant storage solution that can scale with your needs, allowing you to expand storage capacity without compromising compliance.

✅  Cost

Compliance is non-negotiable, but WORM storage solutions can vary significantly in cost. Look at the total cost of ownership—including hardware, software, onboarding, and ongoing fees. Find a solution that balances cost-effectiveness with comprehensive compliance features.

✅  Security

Your WORM storage system should have advanced security features like encryption, tamper-proofing, and access controls to keep data safe from unauthorized access or tampering while ensuring records remain immutable.

✅  Accessibility

The solution should make it easy to access archived data for audits, legal requests, or internal needs. Make sure it offers seamless search and retrieval so you can quickly find what you need while staying compliant.

Ensure WORM Compliance With Pagefreezer

Pagefreezer provides powerful WORM-compliant storage solutions that help regulated industries meet strict data retention and security standards. With advanced features for ensuring data integrity and easy access, Pagefreezer offers a reliable way to archive electronic records in full compliance with industry regulations like SEC Rule 17a-4 and FINRA guidelines.

Key Features of Pagefreezer’s WORM-Compliant Storage:

✅ Immutable Data Storage

Pagefreezer’s WORM-compliant system guarantees that once data is stored, it cannot be altered or deleted, preserving the original state of your records. For the WORM tape backup, Pagefreezer uses VEEAM software to write data to WORM tape storage. VEEAM performs data integrity checks during the export process, ensuring a perfect match between the data, metadata, and file descriptors before committing the write.

✅ Retention Management

Regulated industries often have specific requirements for how long records need to be retained. Pagefreezer allows you to set and enforce retention periods to comply with regulations like SEC Rule 17a-4(f). Data is stored exactly as required for the specified duration, which typically ranges from two to ten years, depending on industry needs. When in doubt, we recommend storing data for at least three years.

✅ Replication and Backup

To enhance data security, Pagefreezer uses a private Ceph data storage cluster to replicate data across two separate storage nodes. A third snapshot is also kept offsite on WORM tape storage for added security, with all versions indexed as required. This ensures records are WORM-compliant and securely backed up in a tamper-proof manner.

✅ Encryption and security

Pagefreezer uses advanced encryption to protect data from unauthorized access. This includes AES-256 encryption for data at rest and SSL encryption for data in transit. VEEAM adds additional security features, such as secure shell, integrated firewalls, RBAC/IAM access controls, and AES-256 server-side encryption. This combination ensures sensitive information is protected while meeting compliance standards.

✅ Verification and Serialization

Pagefreezer ensures data integrity and authenticity by hashing each data object and adding a digital signature to verify authenticity. Every record is serialized and timestamped, making it easy to locate and retrieve during audits or legal requests.

✅ Audit Trail and Accessibility

Pagefreezer provides a complete audit trail, allowing organizations to track activities related to their archived data. All associated metadata is captured, and records are indexed during the archiving process. 

The Pagefreezer dashboard offers continuous access to data, where administrators can view detailed audit logs that include what actions were taken, who took them, and when. Data files in cloud storage and WORM tape are also indexed for easy search and retrieval using disk-like directory tree structures.

Pagefreezer also simplifies compliance by automatically archiving websites, social media, mobile text messages, and enterprise collaboration platforms—streamlining the audit process and keeping all your bases covered.

✅ Scalability

Pagefreezer is built to grow with your organization. Its highly scalable solution lets you expand storage capacity without sacrificing compliance or performance, making it easier to manage large volumes of data over time while maintaining WORM compliance.

WORM Storage Compliance Simplified

Meeting the WORM storage compliance requirements can seem daunting, but companies like Pagefreezer can provide an automated recordkeeping solution that complies with all rules and regulations.