Travis County Email Retention

Email in the news

2011-03-03T08:22:00.003-06:00

For those Austin ARMA members who heard our presentation on Feb. 22nd, this article will resonate. A local government that wants to avoid the problem described in today's newspaper could do so by adopting our preliminary recommendation.

We pointed out that some email programs allow a forced categorization element. Before you can start typing an email, you have to select a category that will be used to automatically assign retention. But any such technology makes the email program harder to use (and it doesn't allow the fine-grained detail that would be necessary to comply with our state-mandated retention requirements).

When the work-provided email becomes harder to use, it drives users to alternatives like Gmail or Yahoo or other web-based email systems that don't demand this pre-categorization. This moves records that belong in the work-provided email system to other systems that don't allow access to search. While this is not the issue that put the Austin City Council's email on the front page, it does have a connection to our analysis, which can be reviewed at aiimcertified.com.

We'll post more about our talk on this blog soon, and submit an article to the Austin ARMA newsletter for those who missed it.

Speech at Austin ARMA next week

2011-02-15T17:14:00.002-06:00

Our ongoing efforts to achieve final resolution of email retention issues continue... At the Austin chapter of the Association of Records Managers and Administrators meeting next week, we will once again engage our peers in the field. If you're a first-time guest, admission is free.

Tuesday, Feb. 22, 2011
11:30 AM
Location: Goodwill Community Center
1015 Norwood Park Blvd.
Austin, TX 78753

Upcoming Webinar

2010-11-05T09:14:00.004-05:00

Coming up on Tuesday, Shawn will deliver a webinar for Government Educator on retention of email, texts, and social media.

Here's a link to a description of the webinar: Click here.

Steven and Shawn get schooled

2009-02-11T16:33:00.006-06:00

Today's post begins with excerpts from an email we received from Patricia Kay Galloway, Associate Professor, Archival Enterprise and Digital Asset Management, School of Information, University of Texas at Austin. She wrote:

"We would like to think of mindful recordkeepers gracefully dealing with their records ... [A]utomation is promising, but if I were the public and you proposed to me that you would do automatic classification using a proprietary method of some kind that even you don't know, I would be very disturbed (and I say to my IR colleagues, it's all very well for you to use these fancy algorithms, but you can always go back to the corpus of records to test whether you are right -- once it's gone, we can't) ... keep it all is my favorite, especially for government records -- we're all supposed to be transparent, right? .... If you don't get pushback from elected officials and can somehow manage to deal with privacy and confidentiality statutes by either time-based restriction or redaction, then why not? It's almost to the point that you can get a terabyte of storage for $100. But the snag is not the email texts, it's the attachments in zillions of formats, and what to do with them?"

Many thanks for Professor Galloway for her feedback! We are still soliciting comments and advice from the records management community and other stakeholders, and continuing our conversations ...

Specifics on our retention schedule

2009-02-11T14:22:00.005-06:00

It's been suggested to Steven Broberg and me that we should describe the retention schedules that we apply to email more thoroughly. Section 441.158 of the Texas Government Code says that the Texas State Library and Archives Commission shall adopt record retention schedules for counties in Texas. These schedules apply to all of our electronic records, including email.

Consider, for example, this description for a certain records series:

Correspondence and Internal Memoranda (includes incoming and copies of outgoing correspondence and internal correspondence and memoranda).

Retention Note: The minimum retention period for correspondence or internal memoranda in categories (a) and (b) directly linked to another record series or group listed in this or other commission schedules is that assigned to the other group or series. For example, a letter from an external auditor regarding an audit of a local government's financial records should be retained for the retention period given under item number 1025-01(e); a letter concerning a workers compensation claim should be retained for the period given under item number 1050-32, etc. The retention periods that follow are for correspondence and internal memoranda that do not readily fall within other record groups.

a) Policy and program development - Correspondence and internal memoranda pertaining to the formulation, planning, implementation, modification, or redefinition of the policies, programs, services, or projects of a local government. RETENTION: 5 years.

Retention Note: Review before disposal; some correspondence of this type may merit permanent retention for historical reasons.

b) Administrative - Correspondence and internal memoranda pertaining to or arising from the routine administration or operation of the policies, programs, services, and projects of a local government. RETENTION: 2 years.
c) Routine - Correspondence and internal memoranda such as letters of transmittal, requests for publications, internal meeting notices, and similar routine matters. RETENTION: AV. (Exempt from destruction request requirement)

So, the retention on an email categorized in this series might be zero (AV, or Administrative Value), 2 years, 5 years, or permanent, depending on the content. This is one of more than 1,500 series in the twelve schedules that apply to Travis County government records. The application of these schedules to email records is discussed in today's video:

The Joy of Paper

2009-02-06T15:48:00.000-06:00

John James O'Brien, CRM, gave us a lot to think about:

Greetings Steven and Shawn,

First off, I’ll add my commendation to Steve Bailey’s. It is great to see this approach to calling a community of practice to the challenges faced by Travis County (and so many other organizations). You have articulated the challenges well.

Brief introduction: I am former Director, Government Records Service and Principal Archivist, Hong Kong SAR Government with a career-long involvement in RIM, ERM, archives, privacy & ethics, and KM, more recently Intellectual Capital Management, including public, private and non-profit engagements and a role as past President, Institute of Certified Records Managers, a co-founder of the Information Records Management Association of Victoria, BC. Currently active internationally.

I fully appreciate the challenges associated with compliance but am not a fan of short cuts. The records manager operates at multiple levels, one with an enterprise-wide sensibility to the overall RIM needs; another with a pragmatic understanding of organizational culture and context, still others include the diplomat and the cop. The first enables integrity in the role. The second guides navigation that must, surely, maintain that integrity. The next two facilitate the first two.

Can everything be retained? Not if the law says no (as in Steve’s cited privacy related legislation which is the norm in most of the world, today, but possibly not the US. Nonetheless, citizen expectations in this regard can carry a political cost, regardless of the law). That takes care of one option. That leaves you with "do nothing" or "make RIM work" in the reality of your context.

I suggest renaming your option 2. You are not really seeking to make every employee a records analyst — even though that title might sell better than file clerk.

A records analyst is expected to have a far more nuanced understanding of the issues in the RIM domain. In my shop, the RA has also been expected to have a horizontal and vertical understanding of how meaning, retained in multi-media information resources, plays into a range of considerations from transparency and good governance to learning and capacity building, to risk, litigation and compliance management. All of these need to be factored into your solution—but not at the desktop by people who are pressured to do a job that fits within only one or two of myriad considerations.

It is not unreasonable to expect that a worker knows what they are doing. If you have a function-based classification scheme, then it has categories that are directly relevant to your workforce — or needs reworking so that it does.

It is possible to frame each user profile against the core job description mapped to applicable records series, and to similarly map ad hoc and development projects such that the user is presented with a limited, transparently relevant set of choices – so easy as to make selection easier than the periodic call to clear out space when IT servers fill up. Yes, it takes development of new habits…change. Yes, it may be a lot of work to put this in place, but it is central work that reaches throughout the organization to achieve the RIM function, ongoing.

A red herring, perhaps, is the idea that paper files were designed for access, not management in terms of today’s liabilities. If you have not had the dubious pleasure of experiencing paper file systems that don’t work for access, you have been very lucky indeed!

The joy of paper, however, lies in its tangible presence. If you have information overload and mismanagement in paper, it’s hard to miss. The same is not true of electronic records — email and otherwise. If access were enough, then a folksonomy would work in place of a taxonomy. But it is fundamentally impossible to manage
records in accord with legal limits and value to business without a taxonomy that is linked to media type, relevant series and a retention plan. No less importantly, this content needs defined relationship to records in other media. Email is a container, and medium is NOT the message.

The degree to which you opt to engage users in this level of detail is an entirely different matter more related to change and program management than it is to RIM.

As for the elected officials, your functional scheme should recognize quite different needs for that group that are, as you say, accountable to the people. Lengthy retention that ensures accountability is the game — and they may object to that far more than to your advice that they can select from a drop down box to ensure appropriate destruction. That’s how I’d sell it — and the climate is right to do so.

All the best in your work — don’t hesitate to link up if inclined.

Regards,
John James O’Brien

Many thanks, Mr. O'Brien, for your thoughtful comments.

Steven and I are no fans of short cuts either, and if we decided that the right approach for Travis County's email retention was to retain everything, we'd do so mindful of the legal requirements to purge certain records (these are rare in our environment).

Any change to the current practice -- including a change to a "retain-everything" approach --would require a complex effort coordinated among IT, legal, audit, and other Travis County offices.

We're noticing that some of the experts responding to our plea for assistance seem to be suggesting that what we are calling Option Two, Make Every Email User a Records Analyst, is more workable that we realize.

Because this suggestion has been made more than once, we are rethinking how we decided to describe Option 2 and will post an addendum here soon.

Until then ...

Listen Carefully to this video featuring Travis County Records Management Officer Steven Broberg:

A refinement to our approach is suggested

2009-02-02T14:03:00.003-06:00

My predecessor, Teresa Howard, the former Travis County Records Manager, weighs in:

An easier solution to option 2 (Making Records Analysts out of all employees) would be to provide two electronic file cabinets for every user: One for official county documents and another for convenience documents only. Then you only need to establish and publish the definition of Official and Convenience documents with an understanding that, when in doubt, file the document under Official.

You would keep the official documents indefinitely and the convenience copies for 5 years. I think any issue that would arise causing a need to search convenience copies would occur within 5 years. Remember that most emails are correspondence and the longest retention for non-historical correspondence is only 5 years. Using the word 'indefinite' rather than 'permanent' is probably more accurate and may not require Travis County to jump through all the electronic records hoops required for permanent records. We always understood that indefinitely retained records were subject to future reviews and analysis. Permanent records are not.

What about the big bucket approach?

2009-01-30T16:01:00.003-06:00

David Gaynon, CRM has been active in ARMA since 1981. He writes:

Hi Shawn,

I must stress that the following represents my own personal views and not that of my employer.

What if you use a big bucket approach for the management of email. For non managerial employees you provide the option of: (a) immediate purge for information of limited importance; and a defined retention period --say 6 months or 2 years for working papers. For managerial employees they would be provided with the same categories plus a third of 5 or 10 years for business planning. It may be that management will tell you that they will need additional categories such as external communication. This of course drives how you are using email in support of your governance model. This I think will wash out through deployment.

It is useful to consider that correspondence about a business function should not have the same retention as the function itself. For example I believe that all correspondence about the general ledger does not need to be kept as long as the general ledger itself. One may consider that such correspondence is really backup -- a form of drafts which would normally be disposed of once the final version is issued. This of course is difficult to manage at the user level. That is why I have come to believe that the simplified version of email retention that I lay out above is the way to go.

I think sometimes that records managers make a mistake when they seek the perfect solution that eliminates all risk of error. This is most likely not possible and attempting this could prove most expensive. The goal of risk management is not to eliminate risk but to manage it consistent with an organization's tolerance for risk.

I hope this helps. Good luck in your efforts.

David B. Gaynon, CRM
Records Retention Manager/General Affairs
Yamaha Motor Corporation, USA

One vendor's view

2009-01-30T14:41:00.005-06:00

As responses to our report are received, they are incorporated into this blog. This post is based on feedback received from Davin Cooke of GWAVA, who offered the following:

"I think you nailed the main reason to hold all email approach - Fancy algorithms and artificial intelligence exist but the criteria for retention is always a moving target, making management of the rules or maintaining a dictionary of terms by category difficult. By keeping all email, and ensuring that there is no rogue archiving on desktops or elsewhere, you can set a global policy and never be caught 3.5 years from now when you discover you should have kept something thanks to a misinterpretation of a message.

"Organizations reap tangible benefits by having retaining all email well beyond compliance. Three additional reasons are:

"1. Intellectual Property Reasons - For both Public and Private sectors, email forms a large percentage of the intellectual property, and its contents reflect the culture of their organizations and once indexed is an excellent resource for decisions. [It] is often paramount in settling internal HR and legal issues.

"2. Email Portability - As well keeping the email in a portable format outside of the messaging system will be very important should you decide to switch platforms or acquire newer technology to leverage its contents.

"3. Less Cost and Waste - Another valuable benefit is the ability to store email in cheaper storage and with less space. Systems like Exchange and GroupWise do not de duplicate as effectively as an archiving solution as messages are stored per PostOffice or MTA Message store. In a multi-post office environment you'd get substantial savings over just keeping it all in the email system."

Our thanks to Mr. Cooke for providing his review of our report.

Records Managers, your assistance is sought

2009-01-22T08:53:00.000-06:00

Begin at aiimcertified.com then return to this blog to help Travis County Records Management perfect a recommendation regarding retention of electronic mail records.

Your comments will be incorporated into future blog posts here.

Thanks for your participation!