Capstone Approach to Email Management NATO Archives Committee Meetings May 22, 2019 Lisa Haralampus Director Records Management Policy and Outreach Office of the Chief Records Officer for the U.S. Government National Archives and Records Administration

Who We Are Independent Federal Agency 3,000 Employees, 40 Locations $380 Million Budget Office of Chief Records Officer 100 Employees Training Oversight Policy and Outreach Operations (Scheduling & Appraisal)

Transformational Targets By 2016, agencies manage all email in an accessible, electronic format By 2019, agencies manage all permanent electronic records in electronic formats By 2022, NARA will no longer accept transfers of temporary or permanent records in non-electronic form

An Email Policy Story Nov 2011 Presidential Memorandum -- Managing Government Records Aug 2012 Managing Government Records Directive (OMB/NARA Memo M-12-18) Aug 2013 Guidance on a New Approach to Managing Email Records (NARA Bulletin 2013-05) Jan 2014 Format Guidance for the Transfer of Permanent Electronic Records (NARA Bulletin 2014-02) Sep 2014 Guidance on Managing Email (OMB/NARA Memo M-14-16) Sep 2014 Guidance on Managing Email (NARA Bulletin 2014-04) Nov 2014 Updated Federal Records Act (Public Law 113-187, Title 44 of USC, Chapters 21, 29, 31, 33) July 2015 Guidance on Managing Electronic Messages (NARA Bulletin 2015-02) Apr 2016 Criteria for Managing Email Records July 2016 Managing Information as a Strategic Resource (OMB Circular No. A-130) Aug 2016 Electronic Messages White Paper Sept 2016 Email Managed under a Capstone Approach (General Records Schedule 6.1) Aug 2017 FAQ about GRS 6.1 Aug 2017 Universal Electronic Records Management Requirements contains requirements for e-messages May 2018 Draft Use Cases for Email Management

Capstone Theory - Policy

Capstone Reality - Schedules 7-year and 3-year dispositions Apply to use, NA 1005 form Public listing of agencies’ Capstone positions

Agency Capstone Implementation, Based on Online Data 191 Agencies Using Capstone 73 Agencies Not Submitted 23 Agencies Pending 2 Agencies Withdrawn

Capstone Lessons Learned Email systems inventories – do agencies know how many email tools they use, especially larger organizations Capture the first step and accomplished goal Keeping track of Capstone officials and tagging/identifying email collections is resource intensive Culling non-record can be automated (binary question – personal or professional) Culling temporary versus permanent, identifying collections within collections. Encryption issues for long-term access and retrieval (PIV card, attachments, 365 encryption) Constant development of new tools for preserving chats, texts, emessaging other than email Determining whether to expand Capstone approach to other electronic records? Scalability is a concern, how many emails per year will NARA be preserving?

NARA Records Management webpage Contacts for More Information Records Express – Official Blog http://blogs.archives.gov/records-express/ NARA Records Management webpage http://www.archives.gov/records-mgmt/ Lisa Haralampus lisa.haralampus@nara.gov

Supplemental Slides

Implementation and Ongoing Responsibilities When using the Capstone approach, agencies must continue to: Schedule records Prevent the unauthorized destruction of records Ensure records are retrievable and usable Consider whether email should be filed with related records Capture and maintain metadata

Agency Capstone Implementation, Based on Oversight Data

Top 5 Reasons NA 1005 Forms Were Rejected (year 1 of implementation) Not using the most recent form. The NA-1005 form has been updated a few times Not submitting one form per Record Group. NA-1005 forms should be submitted by Record Group (RG) number – one form per RG. Providing incomplete information. Make sure that all fields are filled out completely and all checkboxes are checked on the form. Missing signatures. Both your agency Records Officer and your Senior Agency Official for Records Management (SAORM) must sign the form. Providing a URL to an intranet version of organizational charts. Organization charts are required for the review process.

Definition of a Federal Record (44 U.S.C. Chapter 33) § 3301. Definition of records (a) RECORDS DEFINED.— IN GENERAL.—As used in this chapter, the term “records”— (A) includes all recorded information, regardless of form or characteristics, made or received by a Federal agency under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the United States Government or because of the informational value of data in them; and (B) does not include — (i) library and museum material made or acquired and preserved solely for reference or exhibition purposes; or (ii) duplicate copies of records preserved only for convenience. (2) RECORDED INFORMATION DEFINED.— For purposes of paragraph (1), the term ´recorded´ information includes all traditional forms of records, regardless of physical form or characteristics, including information created, manipulated, communicated, or stored in digital or electronic form. (b) DETERMINATION OF DEFINITION.—The Archivist’s determination whether recorded information, regardless of whether it exists in physical, digital, or electronic form, is a record as defined in subsection (a) shall be binding on all Federal agencies.

Use of Personal Accounts Definition of Emessages (44 U.S.C. Chapter 29) § 2911. Disclosure requirement for official business conducted using non-official electronic messaging accounts (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 an 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. (b) ADVERSE ACTIONS.—The intentional violation of subsection (a) (including any rules, regulations, or other implementing guidelines), as determined by the appropriate supervisor, shall be a basis for disciplinary action in accordance with subchapter I, II, or V of chapter 75 of title 5, as the case may be. (c) DEFINITIONS.—In this section: (1) ELECTRONIC MESSAGES.—The term ‘electronic messages’ means electronic mail and other electronic messaging systems that are used for purposes of communicating between individuals. (2) ELECTRONIC MESSAGING ACCOUNT.—The term ‘electronic messaging account’ means any account that sends electronic messages. (3) EXECUTIVE AGENCY.—The term ‘executive agency’ has the meaning given that term in section 105 of title 5.

Criteria for Managing Email Records CRITERIA COMPONENTS Foreword from the Archivist Success Criteria – Policies, Systems, Access Disposition Appendix A: Questions for Discussion Appendix B: Spreadsheet of Requirements Successful email management is defined as having policies and systems in place to ensure that email records can be used, accessed, and have the appropriate disposition applied.

Managing Information as a Strategic Resource (OMB Circular No. A-130) OMB Circular No A-130 Relevant Text for Email Management h. Records Management Agencies shall: 1) Designate a senior agency official for records management (SAORM) who has overall agency-wide responsibility for records management; 2) Institute records management programs that provide documentation of agency activities; 3) Manage electronic records in accordance with Government-wide requirements. This includes: a) Managing all permanent electronic records electronically to the fullest extent possible for eventual transfer and accessioning by NARA in an electronic format; and b) Managing all email records electronically and retaining them in an appropriate electronic system that supports records management and litigation requirements, including the capability to identify, retrieve, and retain the records for as long as they are needed; 4) Ensure the ability to access, retrieve, and manage records throughout their life cycle regardless of form or medium; 5) Ensure agency records managed by the SAORM are treated as information resources and follow the requirements in this Circular; 6) Establish and obtain the approval of the Archivist of the United States for retention schedules for Federal records in a timely fashion; 7) Ensure the proper and timely disposition of Federal records in accordance with a retention schedule approved by the Archivist of the United States; and 8) Provide training and guidance, as appropriate, to all agency employees and contractors regarding their Federal records management responsibilities.

Electronic Messages White Paper Contents NARA Research NARA Analysis Current Practices Agency Next Steps Appendix A: Other Government and Federal Agency Policies Appendix B: Tools Available for Capture of Electronic Messages

Electronic Messages Use Cases

FERMI Use Cases Document the standard workflows. Identify the roles and actions for actors. Can be used to evaluate and demonstrate a solution’s functionality.

FERMI