December 22, 2010
TO: Heads of Federal agencies
SUBJECT: Guidance Concerning the use of E-mail Archiving Applications to Store E-mail
EXPIRATION DATE: Expires when revoked or superseded
1. What is the purpose of this bulletin?
This bulletin is a re-issuance of NARA Bulletin 2008-5, Guidance concerning the use of e-mail archiving applications to store e-mail. The guidance issued in 2008-05 remains unchanged with the exception of minor editorial changes, changes to the expiration date, and references to the Code of Federal Regulations (CFR) found in the bulletin. The bulletin provides guidance to Federal agencies on using e-mail archiving applications and similar technologies for managing e-mail records. It advises agencies that:
- Although e-mail archiving applications may provide business benefits to an agency, e-mail archiving applications can be limited in their capabilities to keep and organize records according to records management laws, regulations, and policies; and,
- If an agency decides to use e-mail archiving applications to manage Federal records the agency is responsible for addressing those areas where the applications do not meet the requirements of the Federal Records Act and applicable NARA regulations.
2. What is e-mail archiving?
E-mail archiving generally refers to applications that remove e-mail from the mail server and manage it in a central location also known as an archive. Information technology professionals use the term "archiving" to mean the copying or transfer of files for storage. In general, these applications collect in a central repository the e-mail (which may include attachments, calendars, task lists, etc.) of some or all agency users. E-mail archiving applications typically require little to no action on the part of the user to store or manage the e-mail records. Once messages are stored, authorized users are able to search the repository.
3. What is the status of e-mail messages as Federal records?
E-mail messages are records when their content (including attachments) meets the definition of a record under the Federal Records Act. See also 36 CFR 1236, and specifically 36 CFR 1236.22, which provides additional requirements for electronic mail.
4. What are the requirements for managing e-mail messages as Federal records?
Recordkeeping systems that include electronic mail messages must:
- Provide for the grouping of related records into classifications according to the nature of the business purposes the records serve;
- Permit easy and timely retrieval of both individual records and files or other groupings of related records;
- Retain the records in a usable format for their required retention period as specified by a NARA-approved records schedule;
- Be accessible by individuals who have a business need for information in the system;
- Preserve the transmission and receipt data specified in agency instructions; and
- Permit transfer of permanent records to the National Archives and Records Administration (see 36 CFR 1235.44 - 1235.50 and 36 CFR 1236.20).
5. Generally how do e-mail archiving applications work?
E-mail may be removed from the mail server either manually by the user or automatically after a predetermined period of time. Automatic transfer to the e-mail archive server may be based on a characteristic or combination of characteristics explicitly found in the e-mail such as the identity of the sender or recipient, date, or keywords found in the subject line or text of the message. The archive server then indexes the e-mail and associated files for future search and retrieval. Individual e-mail systems continue to provide access to archived e-mail through pointers or shortcuts. In most situations, only one copy of the e-mail gets archived.
6. What are the benefits of e-mail archiving applications?
Depending on the agency and its business purposes, e-mail archiving applications may provide the following benefits. Each application has different features and different strengths, so this list is not exhaustive:
- More efficient storage of e-mail because it is moved from a distributed network of servers, desktop applications, and other places to be managed in one place;
- Enhanced electronic search capability for content that may be germane to a subpoena, Freedom of Information Act request, e-discovery request, or similar purpose;
- Assists in back-up and disaster recovery.
7. What are the recordkeeping issues associated with e-mail archiving applications?
E-mail archiving is a relatively new technology and is still developing. While these applications offer business benefits, e-mail archiving technologies do not necessarily meet all of the requirements of 36 CFR 1236.22. Unless the agency appropriately configures and implements the application, it can weaken a records management program. For instance:
- Current e-mail archiving applications may not be capable of grouping related records in accordance with recordkeeping requirements or maintaining the records in a usable format for their full required retention periods;
- It may make it difficult to identify permanent records and temporary records and carry out proper disposition at the end of their retention periods, be that transfer to the National Archives for permanent records or destruction of temporary records;
- An agency that adopts e-mail archiving while continuing a print and file policy for official e-mail records could unintentionally undermine records management compliance as users may assume that the e-mail application has replaced the e-mail print and file policy; therefore, an agency should provide clear guidance that print and file should be done in addition to e-mail archiving.
8. If an e-mail archiving application is adopted as the only means of storing Federal records, what should an agency do to ensure proper recordkeeping?
Under such circumstances, agencies must use e-mail archiving technologies in conjunction with additional controls such as records management policies and procedures, business rules, and other conditions necessary to ensure compliance with records management requirements. Any agency that adopts e-mail archiving applications as its means of official recordkeeping must create policies and provide adequate user training and take steps to identify and manage the limitations in current e-mail archiving applications in order to ensure that records are kept according to 36 CFR 1236.22.
9. What else is NARA doing in regards to e-mail archiving applications?
NARA is monitoring Federal agencies deploying or considering deploying e-mail archiving applications in order to evaluate what steps agencies may take to ameliorate recordkeeping issues posed by this emerging technology. We continue to study e-mail archiving and recognize that software developments may eventually bring these technologies in closer accordance with good recordkeeping practices.
10. Where do I go for more information?
If you need general information about the contents of this bulletin, please contact ERM@nara.gov.
DAVID S. FERRIERO
Archivist of the United States