In their February 2009 email blog for Travis County, Texas, written by Steven Broberg and Shawn Malone, as government records managers for Travis County, they were debating how best to create an email policy which would support over 4000 end users without adding more confusion about state directives and standards on records retention policies. They proposed three general directions for their email retention policy and asked readers for their feedback.

As I have seen in many enterprises, and as the authors have also noted in their blog, there is always resistance to change that will be encountered anytime new ideas are proposed especially in large enterprises where business processes that are not broken will be defended as not needing to change.

One of their options, “Maintaining the Status Quo”, offered the least resistance by end users to accept as a general direction for records management. And it was also, of course, the least costly. If end users are at the front end of this direction – and also the endorsers – then the back end opponents included: security specialists, lawyers, vendors, NARA, TSLAC, etc.

With option one it is very unlikely that the company could maintain that mode as sooner or later there would be a need for email records that would be the subject of electronic discovery procedures and legal litigation. “Maintaining the Status Quo”, in my opinion, is not a viable option but merely one to list as a possible, though not probable, general email retention direction.

Their second option was to allow every employee using email to be their own records keeper. This direction would include publishing a records management set of rules and guidelines that all email users would have to adhere to. And to assist the employees in staying within the guidelines of a company’s record management policy the IT department would provide tools and training.

From my perspective this is how most companies operate today. When it comes down to who is responsible and who will have to produce email records it will be the IT department that hands over the retained emails to the company attorneys for use in court. It is usually not simply an employee of a company that is the subject of litigation but an entire company that is most often either the plaintiff or the defendant in a court of law. In my opinion the ultimate responsibility for records management lies with the IT department.

The third general direction for records management which Travis County considered was that of retaining “all” email. As they noted it is this third option which provides the most protection from electronic discovery requests as no emails are lost and all have been retained. Although this option involves the expenses of storage and administration those costs can be balanced against the costs of having to analyze each electronic record when deciding which email records to keep and for how long.

In their blog post, http://traviscountyemailretention.blogspot.com/
, on February 11, 2009, Steven Broberg and Shawn Malone responded to a comment from one of their readers, Patricia Kay Galloway, Associate Professor, Archival Enterprise and Digital Asset Management, School of Information, University of Texas at Austin, in which she wrote:

“We would like to think of mindful record keepers gracefully dealing with their records … [A]utomation is promising, but if I were the public and you proposed to me that you would do automatic classification using a proprietary method of some kind that even you don’t know, I would be very disturbed (and I say to my IR colleagues, it’s all very well for you to use these fancy algorithms, but you can always go back to the corpus of records to test whether you are right — once it’s gone, we can’t) … keep it all is my favorite, especially for government records — we’re all supposed to be transparent, right? …. If you don’t get pushback from elected officials and can somehow manage to deal with privacy and confidentiality statutes by either time-based restriction or redaction, then why not? It’s almost to the point that you can get a terabyte of storage for $100. But the snag is not the email texts; it’s the attachments in zillions of formats, and what to do with them?”

In her comment, Professor Galloway raises the question of confidentiality that can be a cause for concern during the decision making retention analysis phase. She also points out that any automatic classification of documents will have to deal with the many different formats that exist out there. Her comment highlights the additional costs of an automated classification system as compared to the potentially lower cost of just keep everything. This is where an efficient archival system can save money for a company over the long run.

If readers wish to follow-up on the progress of Travis County and their records management policy then readers can review their blog at: http://aiimcertified.com/default.aspx which begins their topic, “Travis County Email Retention”, with their cordial request of “Records Managers, your advice is sought!”