1. SAA-COSA Annual Meeting Session 301: Capstone Officials & Public Records
Arian D. Ravanbakhsh
Office of the Chief Records Officer for the U.S. Government
National Archives and Records Administration
Disclaimer: This presentation contains my opinions and may not represent official policies of the National Archives.

2. ERM Policy Overview Nov 2011 Presidential Memo
Aug 2012 OMB/NARA Directive
Aug 2013 Capstone Bulletin
Jan Format Bulletin
Sep 2014 OMB/NARA Memo and Bulletin
Nov 2014 New FRA Law
July 2015 Electronic Messaging Bulletin
Sep 2015 Minimum Metadata Bulletin
Apr Success Criteria
*Sept 2015 Capstone GRS

3. Managing Government Records Directive

4. Milestones in the Directive
By 2019, agencies manage all permanent electronic records in electronic formats
By 2016, agencies manage permanent and temporary in accessible, electronic format

5. OMB M-14-16 Sept 15, 2014 Offers guidance on email
Reinforces the Managing Government Records Directive goals.
Focuses on training
Requires all agency employees review the attached guidance (NARA Bulletin )

6. Capstone Accounts

7. Benefits Reduces reliance on user-dependent policies
Optimizes access for information requests
Preserves permanent records
Approach for managing legacy accounts
Eases the burden on end-user
Simplifies disposition
Reduces unauthorized destruction
Leverages existing technologies

8. Capstone General Records Schedule
Divides accounts into three categories:
Permanent
7- year temporary
Largest category, most employees
3-year temporary
Employees responsible for routine, administrative tasks
Capstone official
Contain permanent records by default
User may label as non-record
Non-Capstone official
Contain 7-year temporary records by default
User may label as permanent record
Group account
Group owner is responsible for records management

9. Capstone and Open Government
“The National Archives and Records Administration will release a public dataset of positions of government officials whose will come to the National Archives for permanent preservation under the Capstone approach. This dataset will increase transparency and accountability in the recordkeeping process, while facilitating public participation in the ongoing dialogue over records that document key actions, policies, and decisions of the Federal government.”

10. GitHub

11. NARA’s Capstone Accounts
Permanent records
Temporary records
Transitory records
Non-records
48 staff members were identified as “Capstone”
Agency Head & Deputy
“C” Level Officials
Executives
Directors of major programs
Presidential Library Directors
Typically expect “Capstone” to include 1 to 2 percent of accounts

12. NARA’s Capture Approach
NARA allows individuals to cull
by deleting or labeling s
by deleting from live system (90 days) or archive system (180 days)
NARA has some system rules on capture, such as don’t capture “notices to all staff”
NARA allows non-Capstone users to identify permanent

13. 4 categories of criteria:
Policy
Systems
Access
Disposition

14. Email Management Success Criteria
Three Parts:
Forward/Introduction -- describes purpose, criteria categories, provides links to resources
Appendix A -- questions to discuss
Appendix B -- specific requirements mapped to laws, authorities, guidance

15. Presidential Records Act and Federal Records Act Amendments of 2014

16. New Definition of Federal records
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

17. New Definition of Federal records
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.
Does not include:
library and museum material made or acquired and preserved solely for reference or exhibition purposes
duplicate copies of records preserved only for convenience

18. New Definition of Electronic Messaging
§ DISCLOSURE REQUIREMENT FOR OFFICIAL BUSINESS CONDUCTED USING NON-OFFICIAL ELECTRONIC MESSAGING ACCOUNTS
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—
copies an official electronic messaging account of the officer or employee in the original creation or transmission of the record; or
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:
Electronic messages.—The term “electronic messages” means electronic mail and other electronic messaging systems that are used for purposes of communicating between individuals.
Electronic messaging account.—The term “electronic messaging account” means any account that sends electronic messages.

20. Can electronic messages be Federal records?
Electronic messages created or received in the course of agency business are Federal records.
These records must be captured and managed in compliance with Federal records management laws, regulations, and policies.

21. Electronic messages created in personal accounts
Personal accounts should only be used in exceptional circumstances
Agencies must provide instructions to all employees on their responsibility to capture electronic messages created or received in personal accounts

22. Electronic Messaging Accounts
Federal employees using non-official electronic messaging accounts must forward or copy their messages to an official account.
Intentional violation shall be a basis for disciplinary actions.

23. Email Management in Agencies Reporting Results

24. Capstone Plans in Agencies (from RMSA 2015)

26. NARA Records Management webpage
More Information
Records Express blog
NARA Records Management webpage