April 13, 2020

Why Email Archiving is Not Records Management

20 minute read
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How we communicate with one another evolves as technology changes and we become a more mobile workforce. Mobile apps like WhatsApp, text messaging and collaboration tools like Microsoft Teams and Slack are all part of our corporate communications landscape these days. But email hasn’t gone away, in fact the volume of email is increasing annually.  

Have you considered the role email should play in your records management program? 

The Challenge of Email 

One of the biggest challenges with email is the sheer volume we have to deal with. Analyst reports state that over 300 billion emails will be sent this year and the number will continue to grow every year. We all know that person who has an inbox with 1200 unread emails in it and a deleted items folder that has never been emptied. Let’s not even think about their spam folder! 

Then there is the infamous ‘reply to all’ feature. I send you and three colleagues an email, each colleague hits reply to all with their feedback, we then all hit reply to all with our feedback to their feedback, and the email chain goes on and on. Like a game of Telephone, the original context of the email gets lost in the string of replies, not to mention the attachment on the original email. Plus, we now have multiple copies of the emailall containing overlapping information that could be subject to a discovery request.  

You can argue that email is a collaboration tool, a messaging tool or bothI won’t try to answer that here or convince you one way or another. I’ll just leave these two definitions for you and let you make up your own mind. I have my own opinion. 

  • CollaborationThe action of working with someone to produce or create something. 
  • ReplySay something in response to something someone has said  

How Do We Manage the Challenge? 

We’ve identified the challenges with email, so how do we manage it? Most users simply create massive folder structures to capture and store the emails they feel are relevant to their job. They’ll create folders for departments, clients, products, etc. and then nest folders underneath those folders. Emails get filed away and occasionally retrieved for reference. It’s like your own personal document management system but they never get deleted, do they? When was the last time you spent a few hours going through your email folders cleaning up old emails that weren’t relevant any longer?  

Your IT organization may have implemented an email archiving and retention policy to help address this issue. When Exchange servers were managed on-premise, the cost of storage for those servers was an issue and older emails would be moved to lower cost storage systems and deleted after a defined period. With platforms like Office 365 and Exchange online, storage isn’t the issue it used to be. Everyone says storage is cheap (but it’s still not free!). You still need to destroy emails that have aged beyond their useful life and are residing on your email serverWith the millions and millions of emails an organization deals with annually, this may be automated and done rather broadly (delete all emails over 12 months old for example) instead of relying on the end users. 

Email as a Record 

There are cases where email should be considered a record and managed accordingly. By itself, email is not a record series or category. It’s simply a format and/or a delivery mechanism. Retention or disposition of email messages should be done based on the information they contain and what purpose they serve. The content is what makes it a record. 

Email containing subject matter such as policies and directives, final reports, and meeting minutes are usually identified as record emails. If it is used in the conduct of business, it’s a record. With a little searching, I found a couple of good, real-world definitions of what makes an email a recordOne is from a University, the other is from a Government department: 

  1. Whenever email messages are sent or received in the conduct of University business, they become official records of the University. As records under both The Freedom of Information and Protection of Privacy Act and The Personal Health Information Act, they must be managed to the same degree that paper records are managed and may need to be disclosed under access to information legislation. 
  2. An e-mail message is a record if it documents the Department’s mission or provides evidence of a business transaction and if you or anyone else would need to retrieve the message to find out what had been done or to use it in other official actionsEmail that are classified as official records are subject to the individual department’s records retention schedules and must be retained for the same period of time as the record retention line item/records series that most closely matches the subject matter contained within the email. 

So, now we know what makes email a record. What type of email is not a record?  

  1. Transitory and personal emails that do not provide insight into business. An email regarding a lunch meeting time should be deleted after it is no longer needed. 
  2. Messages that are created primarily for the communication of informal information as opposed to the perpetuation or formalization of knowledge. Destroy transitory email when it has served its purpose. 

Email Archiving and Records Management 

If you determine that email, the attachment, or both are records then they need to be classified and retained the same as your other electronic and paper records. That means you should move them off a transitory location like your email server or local email folder. Move them into a more persistent repository like SharePoint Online or Box and capture the email header information as metadata. There are a number of good software tools that allow you drag and drop emails into your content management system, automatically capturing the metadata during the process. It makes it easy on end users to capture and save their emails. Ask us, we’d be happy to make a recommendation.  

Why should you move your emails out of your email system? There are a variety of reasons: 

  • Your IT staff may automatically delete emails and attachments that reach a certain age without any warning. 
  • Retention on records may range anywhere from 30 days to 30 years or even have permanent retention. An email server isn’t a long-term retention solution. 
  • Email should be classified with other records of the same subject or that serves the same purpose and is retained the same way. 
  • Retention, legal holds and disposition need to be case based, affecting all related records on a topic as a group. 
  • Your compliance team needs a complete view of all the records being managed for reporting and planning. 

IT tools for email archival and retention are designed for just that purposeThey are designed for IT organizations with user interfaces and features to match. They don’t provide the usability or granular retention and classification functionality required of a records management solution. When emails are deleted, you don’t have the reporting, visibility and audit-ability around the disposition of records.  

If you have determined an email and/or attachment is truly a record, move it somewhere secure! 

Conclusions 

Email archiving and records management are not at odds with one another. They are both provide a set of services that an organization needs but they solve different problems. By understanding the problem that each solves, you can apply the technology in the proper way and reduce the risk to your organization. 

Train your organization to follow your policies. Email, like any other record you may have stashed away in OneDrive, your C:\ drive, a USB stick or a file sharing site should be moved to a location where it is properly classified, retained according to policy and managed throughout its lifecycle. Transitory information may be deleted at the user’s discretion or by automated policies set by your IT organization. 

If you do both effectively, you’ll reduce the risk and liability to your organization.  

 

For more information on email archiving verses email records management, check out this video.  

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