Agencies using GRS 6.1, Email Managed Under a Capstone Approach, are expected to apply items the agency uses to all existing email, including legacy email. Legacy email is defined as email that still exists in an electronic format, at the time of Capstone implementation (see GRS 6.1 FAQ #19). When submitting an NA-1005 form, agencies must summarize the state of their legacy email. For example, “no legacy email exists for this agency, as traditional records management with a print-and-file policy was enforced prior to Capstone adoption” or “agency will be including legacy email for all items being used, dating back to approximately 2010.”
If agencies do not know the status of their legacy email–for example, they are not certain if they can access or read an older format–they may still submit an NA-1005 form, but must note what action is being taken to determine if the email is readable or unreadable. For example, “agency has legacy email dating back to 2005 and will notify NARA within [30, 60, 90 days] if email is readable or unreadable.” Readable email is email that is retrievable and usable for as long as needed to conduct agency business and to transfer permanent email records into the National Archives. Agencies must submit an agency-specific schedule for email that is not retrievable and usable, i.e. unreadable.