12 Steps to Meeting Email Mandates

Follow these tips to fulfill your electronic recordkeeping requirements.

Email is a major pain point for federal agencies. The Presidential Directive on Managing Government Records identifies it as one of two electronic-recordkeeping priorities. The directive requires agencies to manage both permanent and temporary email records in an accessible electronic format by 2016.

Since email is one of the focal points of the directive, a common response is to start looking at software. Although an email management application is often a component of a solution, it is only one piece. Outdated polices, schedules and file plans for the disposition of paper-based records and user resistance are major barriers and must be addressed before rolling out software. Procuring a records-management application (RMA) or even an email archiving package often takes several years, so agencies must start immediately in order to meet the 2016 deadline.

Here is a 12-step program for complying with the directive while improving agency effectiveness:

Management

1. Pull together a coalition of major stakeholders — the CIO, general counsel, records-management leaders, email system managers and selected program executives — to steer the implementation and establish a leader to manage the initiative.

Analysis and Selection

2. Assess how the agency uses email, and determine what emails the agency actually needs to preserve. The National Archives and Records Administration (NARA) divides email records into three major categories: permanent — records to be transferred to NARA at some point; temporary — meeting the definition of a federal record but not transferred to NARA; and transitory — eligible for deletion within 180 days.

I would further divide temporary records into two categories: official records needed to document agency activities; and working files used to perform agency activities but not needed as “evidence of the organization, functions, policies, decisions, procedures, operations or other activities of the Government or because of the informational value of the data in them,” as federal law describes. In most agencies, the vast majority of email will be either transitory or working files.

3. Identify classes of email not needed as part of the official record. For example, e-mailemails setting up meetings, exchanging drafts, discussing options or providing day-to-day direction would qualify as records but would not be necessary to document most business processes and should therefore be considered working files.

4. Identify individuals responsible for collecting and managing records (including email) for major business processes, such as budget, personnel and statutory responsibilities. Those individuals (process recordkeepers) are responsible for identifying the records necessary to document their specific areas of responsibility. Emails held by others would be working files in all but exceptional cases.

5. Employees should be trained in using three simple options for email not needed for the official record of their business process:

  • Include in the official record: If employees think an email should be part of the official record, they should send a copy to the person responsible for the official record to decide whether the email needs to be retained.

  • Transitory email: Email that is not work related or that meets the NARA definition of transitory email should be deleted in 180 days or less, based on the retention schedule.

  • Working files: Agencies should set a standard retention period for work-related email not needed as part of the official record. Most published research recommends a maximum of two to three years. Such email should be moved to employee-managed folders for the retention period. Employees should be authorized to delete working files that are no longer needed and should be responsible for locating and providing files if requested.

Use Existing Technology

6. Email systems organize messages by date, sender, recipient and subject and allow employees to manage their email by using folders. Use these capabilities to provide basic management for email, at least as an interim solution.

7. Identify individuals within the agency whose records are generally permanent. Establish a business rule so that all of their email, except that designated as transitory, is copied automatically to an archival mailbox, from which the email cannot be deleted. Set rules for other employees to regulate retention of working files.

8. Provide an email box that can be used to archive “official records.”

9. Identify opportunities to simplify retention and disposition instructions. For permanent records, review records-disposition schedules and the current business process to determine whether the permanent designation is still accurate. Older paper recordkeeping systems may have been replaced by automated systems, making the hard copy and related email documentation disposable. Conduct a similar review for temporary records to determine whether the retention period is still appropriate. If possible, move to fewer common retentions to simplify automated disposition.

Final steps

10. Review NARA regulations concerning email and records management on shared drives for additional tips.

11. Establish a process for systematic review of retained email so disposition is implemented properly on a regular basis.

12. Develop a long-term solution, including the technology platform for it. Minimally, deduplication software will be extremely useful, but agencies may want an email archiving system or records-management application. These steps will help prepare an agency for that implementation.

This solution offers a route to meet the Presidential Directive’s goal and manage email within NARA’s guidelines.

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Feb 20 2013