Federal Records Management

Bulletin 2013-02

August 29, 2013

TO: Heads of Federal Agencies

SUBJECT: Guidance on a New Approach to Managing Email Records

EXPIRATION DATE: Expires when revoked or superseded

1. What is the purpose of this Bulletin?
This Bulletin provides agencies with a new records management approach, known as “Capstone,” for managing their Federal record emails electronically.  This Bulletin discusses the considerations that agencies should review if they choose to implement the Capstone approach to manage their email records.

NARA developed the Capstone approach as part of  NARA's continuing efforts to evaluate how agencies have used various email repositories to manage email records (see NARA Bulletin 2011-03, “Guidance Concerning the use of E-mail Archiving Applications to Store E-mail,”).  This approach was developed in recognition of the difficulty in practicing traditional records management on the overwhelming volume of email that Federal agencies produce.  Capstone will provide agencies with  feasible solutions to email records management challenges, especially as they consider cloud-based solutions. Moreover, the Capstone approach supports the Presidential Memorandum on Managing Government Records and allows agencies to comply with the requirement in OMB/NARA M-12-18 Managing Government Records Directive to “manage both permanent and temporary email records in an accessible electronic format” by December 31, 2016.

NARA bulletins provide fundamental guidance to Federal agency staff, who must then determine the most appropriate ways to incorporate recordkeeping requirements into their business processes and identify the specific means by which their agencies will fulfill their responsibilities under the Federal Records Act.

2. What is the Capstone approach?
Capstone offers agencies the option of using a more simplified and automated approach to managing email, as opposed to using either print and file systems or records management applications that require staff to file email records individually.  Using this approach, an agency can categorize and schedule email based on the work and/or position of the email account owner. The Capstone approach allows for the capture of records that should be preserved as permanent from the accounts of officials at or near the top of an agency or an organizational subcomponent.   An agency may designate email accounts of additional employees as Capstone when they are in positions that are likely to create or receive permanent email records.  Following this approach, an agency can schedule all of the email in Capstone accounts as permanent records.  The agency could then schedule the remaining email accounts in the agency or organizational unit, which are not captured as permanent, as temporary and preserve all of them for a set period of time based on the agency’s needs. Alternatively, approved existing or new disposition authorities may be used for assigning disposition to email not captured as permanent.

While this approach has significant benefits, there are also risks that the agency must consider, including choosing the appropriate Capstone accounts, the possible need to meet other records management responsibilities, and the possibility of incidentally collecting personal and other non-record email.  Agencies must determine whether end users may delete non-record, transitory, or personal email from their accounts.  This will depend on agency technology and policy requirements.

3. What are the advantages of the Capstone approach?
The Capstone approach simplifies electronic management of email records for agencies and may provide the following advantages:

a. Cuts down reliance on print-and-file, click-and-file  drag and drop, or other user-dependent policies;

b. Optimizes access to records responsive to discovery or FOIA requests;

c. Preserves permanent email records for eventual transfer to NARA;

d. Provides a practical approach to managing legacy email accounts;

e. Eases the burden of email management on the end-user;

f. Represents a simplified approach to the disposition of temporary and permanent email records;

g. Reduces the risk of unauthorized destruction of email records; and

 h. Leverages technologies that exist at many agencies for other purposes – e.g., email archives/e-vaults used for e-discovery, including in cloud-based platforms. 

4. What should an agency consider before deciding to use the Capstone approach?
Before implementing Capstone, an agency must determine its suitability for individual agency programs.  This determination is made in consultation with appropriate stakeholders from the Office of the Chief Information Officer, Office of the General Counsel, and other agency decision makers. 

Within an agency, the appropriate organizational level to implement Capstone may vary.  An agency may have multiple implementations of Capstone depending on the business functions of their programs.  Considerations when using Capstone include:

a. Is the Capstone approach compatible with an agency's current email and other records management/archiving systems?

b. Does the current email repository capture metadata required in 36 CFR 1236.22, or can it be configured to do so?

c. Do all permanent email records contain required metadata at the time of transfer to NARA?

d. Are records accessible to authorized staff for business purposes?

e. Does the agency’s repository have appropriate security controls to prevent unauthorized access, modification, or deletion of email records?

f. Can the technology be configured to allow Capstone officials to remove or delete personal and non-record emails from permanent capture? 

g. Depending on agency technology and implementation, is the tradeoff of potentially capturing personal and non-record messages in Capstone accounts acceptable?

h. Will new agency policies addressing FOIA, discovery, IT security, and other issues need to be developed to implement Capstone?

i. What specific training will be required to implement Capstone?

j. Will records be retained too long or too short a time in terms of agency needs when implementing the Capstone approach?

k. Will Capstone records be duplicated in separate filing systems?

l. Do some Capstone records have legal requirements to be destroyed after a specific time?

After considering the above questions, an agency will be able to determine if Capstone will enhance its records management program. If an agency decides to use the approach, the agency must identify their Capstone accounts and determine if they will apply the Capstone approach to legacy email accounts. Once these decisions are made, agencies will need to apply an appropriate disposition authority.  Agencies are encouraged to consult with their NARA Appraisal Archivists to determine the appropriate strategy for managing email records created in their agency.

5. Does Capstone change agencies' recordkeeping responsibilities for email?
Capstone can reduce the burden on individual end-users by encouraging the greater use of automated methods for managing email accounts.  Agencies are responsible for managing their records in accordance with NARA regulations and to fulfill the requirements of the Managing Government Records Directive. When using the Capstone approach for capturing and managing email, agencies must continue to:

a. Ensure email records are scheduled.
Agencies should work with their NARA Appraisal Archivist to ensure email records are covered by an approved disposition authority.  This may include creating new schedules, using existing schedules, or using an applicable General Records Schedule.

b. Prevent the unauthorized access, modification, or deletion of declared records.
Agencies must ensure the email repository has appropriate security measures in place to prevent unauthorized access and/or destruction of records. Records must retain authenticity, reliability, and trustworthiness throughout capture, maintenance, and transfer.

c. Ensure all records in the repository are retrievable and usable.
Email records maintained in a repository must be accessible to appropriate staff for as long as needed to conduct agency business. Agencies should also consider retrievability and usability when migrating from one repository to another.

d. Consider whether email records and attachments can or should be associated with related records under agency guidance.
As a supplement to the Capstone approach, an agency may want or need to associate certain email records that relate to other records, such as case files or project files, with the related records.  This consideration depends on an agency’s needs and how it chooses to implement its Capstone approach. This may be accomplished by:

  1. Using electronic pointers (such as metadata tags) to establish linkages, or
  2. In select cases, filing with associated paper or electronic case or project files.

e. Capture and maintain required metadata.
An agency is responsible for ensuring that email metadata listed in 36 CFR 1236.22, Parts (1) and (3) are preserved. Required metadata elements include the date of the email and the names and email addresses of all senders and recipients particularly if the system uses nicknames, distribution lists, or a blind copy feature. The agency may wish to retain and preserve additional metadata for legal and business purposes. Regardless of the repository, agencies must examine email upon transfer to another repository or to NARA to ensure that names and addresses are appropriately associated with each email. Agencies are responsible for working with vendors and their information technology departments to confirm that their repository is capturing and can export the required metadata elements.

6. How do agencies identify Capstone email accounts?
When adopting the Capstone approach, agencies must identify those email accounts most likely to contain records that should be preserved as permanent. Agencies will determine Capstone accounts based on their business needs.  They should identify the accounts of individuals who, by virtue of their work, office, or position, are likely to create or receive permanently valuable Federal records.  NARA’s Appraisal Archivists can assist agencies in helping to determine Capstone accounts. For example, these accounts may include

[H]eads of departments and independent agencies; their deputies and assistants; the heads of program offices and staff offices including assistant secretaries, administrators, and commissioners; directors of offices, bureaus, or equivalent; principal regional officials; staff assistants to those aforementioned officials, such as special assistants, confidential assistants, and administrative assistants; and career Federal employees, political appointees, and officers of the Armed Forces serving in equivalent or comparable positions. (GRS 23, Item 5)

Agencies may wish to use the U.S. Government Manual or the United States Government Policy and Supporting Positions (Plum Book) as a starting point to identify potential Capstone accounts. The goal is to capture the email accounts of high level policy/decision makers-- including any secondary or alias accounts-- and the accounts of those authorized to communicate on their behalf in the development of agency policy or important decision-making.  There may be other accounts containing permanent records not covered by these suggestions that relate to the mission of the agency and would meet the criteria for a Capstone account.

7. Must agencies use a specific technology to implement Capstone?
No, Capstone implementation is not dependent on a specific technology or software. This approach is designed to utilize technologies that already exist at many agencies.  Agencies may use native email systems, email archiving applications (which many agencies are already utilizing for other purposes), or other repositories to implement Capstone.  Evolving technologies, such as auto-categorization and advanced search capabilities, may enable agencies to cull out transitory, non-record, and personal email. In the absence of a technological solution, agencies must rely on policy, procedures, and training to fully implement Capstone.

8. How does NARA’s Pre-accessioning policy apply to Capstone?
Pre-accessioning is an option for agencies when implementing the Capstone approach.  Pre-accessioning is when NARA receives and fully processes a copy of permanently valuable electronic records before those records are scheduled to legally become part of the National Archives of the United States.  In other words, pre-accessioning means that NARA assumes physical custody of a copy of the records, usually well before it is time to assume legal custody. The transferring agency retains a complete and fully functional copy of the transferred records even after a pre-accessioning transfer, and that copy must be maintained until NARA assumes legal custody at a future date.  Pre-accessioning allows NARA to preserve permanently valuable electronic records early in their lifecycle while the agency retains its authority and responsibility for providing access. This is done in part to mitigate risk over time, since electronic records are subject to potential obsolescence between the time they are created and the time that they are ready for NARA to assume legal custody, which may be many years in the future. It also gives NARA a means to provide agencies with off-site, no-cost security copies of the pre-accessioned records. For more information about Pre-accessioning, refer to NARA Bulletin 2009-03: Pre-accessioning permanent electronic records and Pre-accessioning: A Strategy for Preserving Electronic Records.

9. What other NARA resources are available?
NARA has the following additional resources that may be useful:

Guidance on Managing Records in Cloud Computing Environments:  A NARA bulletin addressing records management considerations in cloud computing environments. 
Toolkit for Managing Electronic Records: A resource for agencies to share and access records management guidance and best practices. Examples include tools that address the creation of business rules for managing email and related issues.
Records Express: The official blog of the Office of the Chief Records Officer at NARA highlights guidance and upcoming events. It also discusses how we are working with our agency partners to improve records management in the Federal government.
Frequently Asked Questions about Records Management: Provides a list of FAQs on noteworthy records management topics.

10. Whom should I contact for more information?
If additional information is needed, or if you have any questions, please contact your agency Records Officer or the NARA Appraisal Archivist or records management contact with whom you regularly work. Please refer to the List of NARA Contacts for Your Agency, available at /records-mgmt/appraisal/.