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With the 2012 President’s Managing Government Records Directive (MGRD), federal agencies were required to finally make the transition to electronic record keeping and address the challenge of managing email for both records management and e-discovery purposes. 

Email represents perhaps the highest volume and greatest risk to agencies in the event of litigation, Freedom of Information Act requests and investigations — and the volume is growing to where many agencies are creating well over 1 million email messages daily.   

NARA’s Guidance on a New Approach to Managing Email Records, addresses this requirement with a role-based approach to email records management. The Capstone approach allows agencies to designate certain email accounts as permanent records by job position or role.  All other email accounts are designated as temporary for a set time.  

The Capstone approach also requires agencies to evaluate their policies, disposition schedules and technology options. Records managers and IT will need to evaluate current systems to determine whether they meet their email records management, search and e-discovery needs.

Agencies should consider commercial-off-the-shelf email archival alternatives that support both records management and e-discovery requirements:

The sheer volume of email that must be preserved requires a highly scalable solution with the ability to capture and process millions of email messages within short time frames.

Email archival solutions must have the ability to capture email metadata and apply retention policies based on user role, metadata or the content of the email.

The solution must be able to support e-discovery requirements and apply legal holds on email.

Permanent email must be transferred to NARA in appropriate formats, and temporary email must be destroyed based on retention schedules.

Agencies should evaluate technologies, including auto-categorization, that automate the categorization, de-duplication and removal of transient and personal email.

Compliance challenges

The presidential directive presents significant challenges to agency records managers who must determine how electronic information, in a variety of formats and systems, will be governed according to established policies. 

The reality for many agencies is that electronic records, including email, social media and office documents, exist in various disconnected and incompatible systems. Records managers must evaluate whether a centralized enterprise records repository is feasible or whether the agency’s information governance and retention policies must applied in a consistent manner to multiple systems and repositories. 

Perhaps the greatest technology challenge surrounding the MGRD is the need for agencies to continuously respond to the rapidly increasing demands for new information technology including collaboration services, mobile devices, social media and cloud-based solutions that challenge traditional records management policies and processes.  

In addition, agencies must evaluate digitization of records, including an assessment of whether certain paper document collections, based on their subject and value, should be scanned and made electronically accessible for e-discovery, FOIA and other requests. Scanning and optical character recognition technologies are mature and are well-integrated with most information management applications. 

Agencies should take a disciplined approach to the MGRD, and they must develop plans for how they will achieve each of its milestones. When addressing the requirements for a transition to an electronic record keeping solution, the following approach is recommended:

Define and gain consensus on the agency’s functional and compliance requirements for electronic records management.

Identify gaps between the requirements and agency’s current technology, and determine whether gaps can be addressed by adapting current systems or new technology acquisition.

Evaluate proven technology to provide efficiencies including auto-categorization, search and digitization technologies.

Analyze viable alternatives and make recommendations on the best solution to meet the agency’s needs.

The MGRD presents a huge opportunity and challenge for agencies, as they determine how to implement record keeping policies and practices in an ever-changing environment fueled by the accelerated pace of new technology adoption.