IARA County/Local Records Management - Email Retention & Disposition
Indiana Archives and Records Administration sent this bulletin at 11/29/2021 10:00 AM EST
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Good morning County/Local Agencies,
This is Part 2 of a primer on e-mail and records management, Retention and Disposition. For Part 1, Classification and Organization, please see the November 22, 2021 bulletin.
E-mail is one of the more complicated electronic records to manage so we hope the information below will prove helpful. If you ever have questions about e-mail and records management, please reach out to the Electronic Records Program team at erecords@iara.in.gov.
Retention
E-mail records must remain useable, searchable, retrievable, and authentic for the applicable retention period.
Like all electronic records, e-mail retention is based on content rather than format; e-mails must be retained and disposed of according to the same rules as their paper counterparts.
The contents of most e-mail falls under GEN 10-04: General Files, and will therefore only need to be retained for 3 years unless there is further business use. This means the average user does not need to migrate their e-mails to another software format or storage system for long-term preservation.
For e-mail which does have a longer retention, such as messages that fall under GEN 10-03: Policy Files, it may be necessary to work with your IT department or e-mail provider to ensure e-mail is not being caught in any auto deletion policies that have been set up. Arrangements should be made to enable messages to be extracted from the e-mail program and saved in a backed up, secure location.
All staff who use agency e-mail accounts or conduct business on behalf of your office should be trained on their records retention responsibilities related to e-mail. In order to protect against loss, agencies should provide clear instructions on the use of personal accounts and devices. Having an internal e-mail use policy is recommended.
Disposition
Destruction
All e-mail that has reached the end of its scheduled retention period must be disposed of in a manner that ensures protection of any sensitive, proprietary, or confidential information.
Complete disposal means that the content is permanently deleted from the e-mail system and any backups or Cloud storage, not just put into the user’s “deleted items” folder. Destruction of confidential e-mail categories may require intervention by your IT department or e-mail provider.
County/Local e-mails are subject to the same disposition rules as paper records:
- A Notice of Destruction (SF 44905) is required.
- Confidential records must be destroyed completely and securely in a manner that does not expose them to unauthorized viewers and according to any state or federal law(s) that may apply.
If you are confident that you are able to separate GEN 10-04 e-mail from anything that must be retained for a longer period, and you are planning to auto-delete GEN 10-04 e-mails on an on-going, predetermined schedule, IARA has developed a new workflow. If you would like to learn more and see if this workflow meets your needs, please contact Meaghan Fukunaga, Deputy Director for Records Management, mfukunaga@iara.in.gov.
Permanent Records
E-mails falling under record series GEN 10-03 or another permanent record series must be kept permanently. There are several ways to do this, including by using third-party recordkeeping software. Please reach out to the Electronic Records team (erecords@iara.in.gov) if you’d like to discuss options and current best practices.
Third-Party Recordkeeping Software and Backups
If you already use a third-party vendor to help archive your e-mail, we recommend you create policies to help your office support long-term or permanent records management. As a starting point, or a way to evaluate your current system, we have created a handy electronic recordkeeping systems checklist for your reference. We recommend walking through this with any vendors you are currently using or are looking to contract with. If you would like to share a copy of your answers with IARA, or have questions, please e-mail the Electronic Records team, erecords@iara.in.gov.
It is also important to ensure that electronic record backup policies and practices are sufficient, including what backups are needed and how long to maintain them. Backups are not recordkeeping systems but can help restore records in the event of a disaster or technology failure. If computers or mobile devices are not backed up, then e-mail and other records should not be stored on them.
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It's almost December, how did we get here?
AMY CHRISTIANSEN
Records Management Liaison
Indiana Archives and Records Administration
o: 812-929-3882
e: achristiansenjanicki@iara.in.gov |
a: 402 W Washington St, Room W472, Indianapolis, IN 46204