Feds Get Serious About Email Preservation

In a paperless society, office file cabinets may become an endangered species. However, the need to store documents — albeit in electronic form — will remain. The U.S. government, like many private sector companies, is struggling to develop efficient means to retain billions of electronic messages.

The National Archives and Records Administration is playing a central role in the government-wide effort to retain and manage electronic documents. As one of the initial steps in meeting records management mandates issued by President Obama in November 2011, NARA has just developed a simplified approach to managing federal agency email messages. The NARA initiative, called “Capstone,” is designed to permanently preserve valuable email as well as to provide a way to dispose of other email messages.

“Capstone allows agencies to manage email without having to use print-and-file or click-and-drag methods for each email message,” said Arian Ravanbakhsh, a records management policy analyst at NARA.

Agencies Create Retention Accounts

The program works by utilizing a system for the transfer of designated emails from an agency to a NARA archive. To meet federal requirements, agencies will designate individual employees whose jobs are at a level such that all of their email is assumed to be important enough for permanent archiving. That approach allows for the capture of records that should be permanently preserved from the accounts of officials at or near the top of an agency or an organizational subcomponent, according to NARA.

“Capstone is not a software application that agencies use. It is an approach to managing email that is software-agnostic. Capstone focuses on leveraging existing technology for email and discovery that may already be installed at federal agencies,” Paul Wester, chief records officer at NARA, told the E-Commerce Times.

“Each agency will designate their Capstone email accounts as they implement the approach. NARA will, through the records scheduling process, review those designations,” he said.

Agencies should use the Plum Book, a federal directory of high-level positions, as a starting point for designating employees for the archive process, NARA suggested.

NARA developed Capstone to meet an August 2012 Office of Management and Budget directive that charged the agency with coming up with an email archiving system for high-level federal personnel by December 2013. Agencies have been directed to implement such a retention system by December 2016. Remaining email accounts can be managed as temporary records and preserved for as long as the agency needs for business operations, NARA said.

Federal agencies may be relieved to have the Capstone system available, but the advantages of the program should be balanced against the disadvantages.

Benefits and Drawbacks

“This approach offers the advantages of expediency and simplicity. The process of submitting records to an archive system can be easily automated. It ensures that all record emails are captured. It eases the burden of email management on end-users where no automated solutions are in place,” said B. John Masters, subject matter expert at IMC.

“Within the context that it was offered, agencies with current records management policies, and email and records systems that are compatible with Capstone may find the approach helpful in meeting their records retention requirements, specifically for the permanent email records of their senior executives and important agency functions,” Cheryl Smith, vice president of information management at NetSmith, told the E-Commerce Times.

“It affords an alternative solution to print-and-file or other user-dependent policies that can be quickly implemented using available tools to meet the challenge of capturing and preserving permanent emails,” she said.

While Capstone presents a giant receptacle for the storage of emails, its use is somewhat limited. The major drawback is that the system does not discriminate as to which emails are truly significant based on their content, and simply sweeps up all messages within a designated person’s files.

“It is IMC’s experience — in working with a number of federal agencies — that officials likely to be designated for Capstone accounts still receive significantly more non-record emails than official record emails,” Masters told the E-Commerce Times.

Even for qualified Capstone accounts, more than 90 percent of the email content is of a transient nature and would be over-retained, based on studies IMC cited.

“It is unlikely that agencies will transfer the entire email file to NARA. This means that the agency will have to absorb the cost of having staff cleanse the email file so that only record emails are submitted for permanent storage,” Masters said.

While Capstone has the benefit of simplicity and does not require agency investment in new technology, the program really does not measure up to best-practices data management, he observed. “We do believe it will result in higher operating costs to agencies though, as the email files will likely be purged by staff regardless of Capstone recommendations. This will require additional time.”

IMC also noted other deficiencies:

• The total size of the collections will be larger.
• Larger files will mean that staff time required to find and review messages in response to Freedom of Information and legal discovery requests will be significantly higher.
• Capstone does not relieve the agencies of their requirement to properly manage the email messages of lower-ranking officials and employees, so agencies will likely have to make investments in other email management solutions.

“Capstone is not — and was not designed to be — a comprehensive solution to the management of all email records,” said Smith. While the system offers a significant advantage for agencies over conventional retention methods, the ability to organize and access emails would be more dependent upon the tool being used and how it is configured than upon NARA’s guidance itself, she noted.

The Capstone system is only one component of a comprehensive federal effort to improve records management, NARA conceded.

“Agencies implementing a Capstone approach for their email are not absolved of the requirement to manage records. Specific functions, such as categorization, depend on the underlying software that is already installed by an agency to manage their email. Certainly, as technology improves, those capabilities will also improve,” NARA’s Wester said.

An Emerging Market for Vendors

Federal agencies will not be required to use Capstone to meet email retention mandates, but NARA’s initiative provides an option for meeting archive goals. Current technologies, such as IBM’s Content Collector for Email and its auto-categorization solutions, make it possible to add the desired simplicity to email management, improve compliance with laws and regulations, and adhere to best practices for records management, IMC pointed out. IMC is a partner and reseller of IBM offerings.

To date, email system providers have not been active in the RM field, according to IMC.

“We are not seeing the major email platform providers paying any significant attention to email management requirements for either federal or commercial users. They are merely providing storage capacity, and expecting end-users and IT organizations to plan for any email management functions,” Masters said.

With email message retention just one of many federal records management goals, agencies will likely need a significant amount of assistance when it comes to the full range of future RM requirements. There will likely be significant growth opportunities in the federal RM market, said Smith.

“We provide services that directly assist agencies to meet the various records management objectives outlined by the Managing Government Records Directive,” she said. Thus, for her firm and others in the field, records management services “will become increasingly valuable and in demand as federal records management becomes more electronic.” END