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For those of us that have reviewed NARA’s draft bulletin “Guidance on a New Approach to Managing Email Records” (available at NARA Capstone Draft), we’ve seen a glimpse of what may be the future of email records management, for large agencies anyway — and it may not involve email users declaring and classifying their own individual email records.   

One of the biggest concerns of agencies today is how to effectively preserve and classify email records.  Email represents perhaps the highest volume and greatest risk in the event of discovery, FOIA requests, and agency reputation — and the volume is growing to where many agencies are creating well over one million email messages daily.   

NARA’s proposed Capstone approach is intended to be a simplified approach that 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.  Capstone is an option for agencies, but all must determine how to manage email properly by December 31, 2016, per the Managing Government Records Directive. 

Capstone is an attempt to address the greater email records concern, and it may be the beginning of the end of many agencies’ attempts at asking email users to declare and classify individual emails as records within Outlook.   Indeed, NARA’s bulletin states that this approach “was developed in recognition of the difficulty in practicing traditional records management on the overwhelming volume of email that Federal agencies produce” and Capstone “Cuts down reliance on print-and-file, click-and-file drag and drop, or other user dependent Policies”.

 I have conducted several analyses on behalf of agencies on adoption issues and short-fallings of record management solutions.  I’ve found often that a major obstacle to the adoption of the ‘user driven’ email records approach, no matter how well-integrated the solution, has been the cultural hurdle for users at any level to (time allowing throughout their work day) independently decide that an email qualifies as a record, and to then perform the extra work to properly classify an email record against the agency’s records schedule.  Adoption of these solutions has suffered because these actions take time, require training, and interfere with staff’s normal work responsibilities.  One of the drivers for NARA’s Capstone approach is to significantly reduce or remove the email user’s involvement in this process, while ensuring that all email records are captured with scheduled. 

The Capstone approach leaves many questions unanswered for agencies, and requires them to evaluate their policy, disposition schedule and technology requirements--- but it may be a practical basis for scheduling the millions of email, particularly within large agencies, in order to reduce the risk of unauthorized destruction of email records.   Agencies will have to give serious thought as to who the Capstone accounts will be within their organization; assessing which accounts have the highest likelihood of creating permanent records.  Records Managers and IT will need to evaluate current systems including email backup systems, email archives and records repositories to determine whether these meet their email records requirements from compliance, records management, security and capacity perspectives.  

An immediate concern is that agencies will be capturing and preserving all emails within the Capstone accounts – not just those deemed to be records.  I believe that NARA’s proposal leaves the door open (once emails are captured) to automating metadata capture, deduplication, and removal of personal and other transitory email as proven technology such as auto-categorization becomes available. 

If done right, preserving all relevant email records in a searchable repository will improve support for discovery, holds and FOIA requests – but we must consider the functionality required to support these activities, and the consequence of capturing all emails.

Should be very interesting to see how agencies react to NARA’s Capstone approach over the coming months, and how NARA responds in turn.   There are a lot of lenses with which to look at NARA’s Capstone approach, so I’m looking forward to everyone’s opinions and insights.