Transition Post 3: Managing Official Email and Social Media Accounts

The next post in our Federal Government transition series highlights the need to manage official email and social media accounts of senior officials as they enter and exit Federal Service. It is very important for these officials to keep personal materials separate from official accounts or systems. This avoids the laborious and difficult task of reviewing voluminous materials when leaving the agency.

Agency officials should use their official email and electronic messaging accounts when conducting agency business (see NARA Bulletin 2015-02: Guidance on Managing Electronic Messages for more information). Personal accounts should only be used in exceptional circumstances. When officials conduct agency business using personal electronic messaging accounts or devices, Federal records are created. If personal accounts are used, individuals must capture electronic messages created or received in those accounts to meet the requirements of the Federal Records Act.

The Federal Records Act (44 U.S.C. 2911 as amended by Pub. L. 113-187) states:

(a) IN GENERAL.—An officer or employee of an executive agency may not create or send a record using a non-official electronic messaging account unless such officer or employee— (1) copies and official electronic messaging account of the officer or employee in the original creation or transmission of the record; or (2) forwards a complete copy of the record to an official electronic messaging account of the officer or employee not later than 20 days after the original creation or transmission of the record.

Electronic messages created or received in a personal account meeting the definition of a Federal record must be forwarded to an official electronic messaging account within 20 days. The statutory definition of electronic messages includes email.

Social media accounts created or used for official agency business must stay under the control of the agency. When an employee uses a personal social media account to communicate with the public on behalf of the agency, they may be creating Federal records that must be brought under records management control and managed. It may be necessary for the account to become the property of the agency.

It is best practice for employees and senior officials to create unique agency-administered accounts when they begin using social media for official purposes or when they enter Federal service so that the public can clearly see the accounts are used for official agency business. 

When an employee starts or stops speaking on behalf of the agency, they should indicate their change of status on the social media platform. This allows for a clear delineation between when an employee is acting in an official or personal capacity. For example, a government employee’s username could be their position title, acronym, or role instead of their personal name. Upon leaving government service, an employee who wishes to continue using the same social media platforms for personal reasons will need to create new social media accounts.

As a reminder, the Federal Records Act does not apply to Presidential records created under the Presidential Records Act.. Presidential records are managed separately from Federal records. Questions related to determining whether or not documentary materials are Presidential records should be referred to the White House Counsel.

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