Opportunity for Comment: Capstone Email Bulletin

We are requesting comments on a draft of an upcoming NARA Bulletin that creates a new approach to managing email. NARA bulletins are designed to provide fundamental guidance to Federal agencies who must then determine the most appropriate ways to incorporate the guidance into their work.

This draft Bulletin (available here as .pdf) will provide Federal agencies with guidance about the “Capstone” approach to managing email. It will allow agencies to declare a certain subset of email accounts as permanent and other accounts as temporary. It will allow agencies to manage these accounts instead of managing individual email messages. The Bulletin will identify the considerations for this new approach.

This draft is part of ongoing work that has been underway in our office and across NARA for several years. We talked about the launch of the pilot back in October of 2011. In addition, the draft will meet the requirement in Action A2 of the Managing Government Records Directive.

Please leave your comments and suggestions about the draft Bulletin here by June 21, 2013.

Thank you for your input!

4 thoughts on “Opportunity for Comment: Capstone Email Bulletin

  1. Arian, terrific work to you and your colleagues. This practical, sensible approach actually very closely resembles our institution’s emerging practice, which we hope to codify as official policy soon. Our stakeholders will be emboldened to know that this approach has the NARA imprimatur.

    In particular, I think that the list of potential roles whose email accounts would be “capstoned” is a good start and virtually mirrors the list we’ve created. For what it’s worth, we’re working with the email management group on campus to see if we can automate the retention of such accounts by associating certain retention periods with job classifications embedded our email system’s directory (senior administrators, deans). I’d be interested in comparing notes offline at some point when we cross paths in the future.

    When do you expect to have a final version?

  2. Jordon, thanks for your comment. We hope to be able to issue this Bulletin in final form in a few weeks. Even after the Bulletin is released, we anticipate issuing additional information about the policy as necessary.

  3. First off, my compliments to NARA for their leadership and, on this topic specifically, continuing its investments and guidance for handling this important, yet difficult, problem of email management.

    With investments and costs in mind, I would like to inquire as to the research performed by NARA on this topic specifically as to the costs of implementing Capstone. Could you please provide comment to this?

    Specifically, every decision or policy such as this has an up-front cost and an operational, or long-term cost. The benefits of Capstone for the up-front costs are more readily apparent. It’s an easy policy and technology implementation. The challenges in Capstone will lie in the future. The long-term costs of managing billions of email messages that are of no value, but were over-retained due to the role-based retention, will be staggering.

    We see this every day as we advise clients that made similar ‘easy’ decisions to ‘just keep everything’. Today, organizations that have a small fraction of the employees that the Federal Government has are being overwhelmed with many hundreds of terrabytes of email. ‘Storage is Cheap’ is a common misunderstanding. Just ask any IT manager who routinely has to purchase million dollar storage systems to handle the ever-growing storage footprint in their enterprises. But the cost of storage begins to pale when compared to the manpower and technology costs as old systems are retired and these volumes of email must be migrated – without loss of integrity and with a chain-of-custody – to new hardware and software systems.

    As Barclay Blair asserted in his response to Capstone, “I wonder if NARA is turning away from a content-based approach to record identification and retention too soon” . Yes, a lot of organizations have failed with classification of email based on each individual messages content and value. Today, we are able to stand on the shoulders of those that have preceded us and through a simple and intelligent combination of process, technology, and people we are seeing companies be very successful with content aware classification. It is some more effort up front, but the long-term savings are huge.

    This approach does not require NARA to rewrite Federal Regulation (36 CFR 1236), as suggested by Ron Layel (also on Barclay Blair’s blog and sent directly to NARA). Records are media neutral, and it should matter not if the record occurs in email, paper, or other form.

    To serve the needs of government and business to properly manage records based upon each message’s value, our company developed the solution that does work. The solution lies not at the extremes of 100% auto classification, or 100% user classification, but instead of the logical intersection of various approaches. This hybrid model brings out the best, and mitigates the negatives, of various approaches to email management. The keys are this:
    > Exception based processing (users need only take action on 0% to 2% of their email on average)
    > Auto classification with human oversight
    > Simple, and integrated, User Interface with key capabilities including personalization

    Back to the Capstone recommendation of role-based retention, the long-term costs must be considered. These costs of over retention include the following:
    > Storage
    > Hardware and Software upgrades, and content migrations
    > FOIA requests across the huge volumes of email
    > eDiscovery costs including preservation and review
    > Manpower for management of these large data stores
    > Privacy and Personal Information concerns
    > Reputation and legal risk costs

    Thank you for requesting comments, and thank you for your consideration,

    Scott Burt

  4. The Capstone approach is one I have endorsed for a long time. However the draft guidance from NARA goes too far, violating some of the basic tenants of Records Management.

    Please reference the AIIM blog site (http://www.aiim.org/community/blogs/expert/the-email-pyramid) for a detailed explanation of how email should be approached in a best practice model.

    From the draft: “Following this approach, an agency can schedule all of the email in Capstone accounts as permanent records. “

    This part of the guidance is fine, and should be supported. However, it should not be limited to just email. One of the basic tenants of best practice records schedules is that they should be “media neutral.” Therefore the Capstone guidance should encompass all content regardless of media type. The guidance should be limited to this single approach, and who should be included in this list.

    “The agency could then schedule the remaining email accounts, which are not captured as Capstone, as temporary and preserve all of them for a set period of time based on the agency’s needs.”

    This second piece of guidance is very flawed. It violates everything we all have promoted for the last decade. There are many emails that are permanent but which are not Capstone. Also, many emails need to be stored with business transactions in context for audit purposes for full documentation of a transaction lifecycle. Lumping all non-transitory and non-Capstone email into one “bucket” is a huge mistake.

    This approach invites agencies to implement a fragmented approach to archiving email that creates another records “silo” rather than a unified approach that manages all content. This is exactly what we are trying to avoid.

    NARA has just begun the process of inviting agencies and vendors to present their best practice approaches to RM automation. Before we change the rules in a very flawed way, we should let agencies and vendors present their solutions and examine what is working and how it can be implemented in best practice scenarios.

    For example, the Department of Interior has already implemented a best practice solution, using a cloud-based service, that applies Records Management to all email as part of a unified repository that manages all media types equally. This best practice model is what NARA should support, not fractured silo approaches that violate RM policy.

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