Section 3: Questions related to Permanent Email Records and other types of Electronic Messages
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1. What is meant by "Cutoff and transfer in accordance with the agency's approved form NA-1005, Verification for Implementing GRS 6.1. This will be between 15 and 30 years, or after declassification review (when applicable), whichever is later." within the disposition instructions for item 010?
Agencies have varying business needs and will adopt unique Capstone implementation plans that may affect when they cutoff (consider the records inactive) email and/or other types of electronic messages. This language allows an agency to define both their cutoff and transfer instructions on the form NA-1005 by selecting the option that meets their business needs.
Cutoff instruction options on the form NA-1005 include:
- Cutoff at the end of the calendar year;
- Cutoff at the end of the fiscal year;
- Cutoff at the end of employee tenure;
- Cutoff at the end of the current administration; or
- Other (discuss with your NARA Appraisal Archivist during review)
Transfer instruction options on the form NA-1005 include:
- Transfer 15 years after cutoff, or after declassification review, whichever is later;
- Transfer 20 years after cutoff, or after declassification review, whichever is later;
- Transfer 25 years after cutoff, or after declassification review, whichever is later;
- Transfer 30 years after cutoff, or after declassification review, whichever is later; or
- The above options, but with 5-year blocking.
This flexibility also allows agencies to block (or batch) the records to reduce the number of transfers to NARA. Agencies that do not wish to transfer annually may find blocking beneficial; specifically, an agency could transfer records in five-year blocks instead. If the first five-year block spans from 2015 through 2020, and the agency was transferring permanent email 15 years after cutoff, then the agency would transfer the email in 2036 (15 years after the cutoff date of the most recent records). They would next transfer email in 2041, which would cover email from 2021 through 2025. And so on.
The transfer date should be determined in conjunction with the cutoff instructions, as the two complete the full transfer instructions. Examples of full instructions include, but are not limited to:
| Cut off... | Transfer... | In this example.. |
|---|---|---|
| At the end of the calendar year | To NARA 15 years after cutoff | Records through the end of calendar year 2015 would be transferred in early 2031 |
| At the end of employee tenure | To NARA 25 years after cutoff | Records from individuals whose tenure ended in 2015 would be transferred in 2041 |
| At the end of the current administration | To NARA 20 years after cutoff | Records from the 2017 to 2020 administration would be transferred in 2041 |
| At the end of calendar year | To NARA in 15 years in 5-year blocks | Records from 2015 through 2020 would be transferred in 2036; records from 2021 through 2025 would be transferred in 2041 |
| At end of employee tenure | To NARA in 5-year blocks 15 years after cutoff | Records from individuals whose tenure ended in 2015 through 2020 would be transferred in 2036; records from individuals whose tenure ended in 2021 through 2025 would be transferred in 2041 |
Specific to classified email and/or other types of electronic messages, the records must be reviewed prior to transfer to NARA (as with any classified permanent records). Classified email is typically reviewed at 25 years based on standing Executive Orders.
2. Does the GRS apply if Capstone officials have more than one email or messaging account or if their email and/or electronic messages are managed by other staff (such as special assistants, confidential assistants, military assistants, or administrative assistants)?
Yes. Capstone officials often have multiple email or messaging accounts, either based on their titles (for example, ArchivistOfTheUnitedStates@nara.gov), or managed by other staff members on their behalf. Agencies must designate all accounts affiliated with a Capstone official role or position as permanent.
3. Are shared or program accounts covered under this GRS and could they be permanent?
Yes. Shared or program accounts for email or electronic messages, often referred to as group accounts, are common within the federal government. They allow multiple people access to a specific account; for example, a single email account assigned to an entire program office, or a messaging account assigned to multiple staff to disseminate message blasts.
If any of these accounts involve a Capstone official or fall under category 10 of GRS 6.1, item 010, they should be managed as permanent and included on the form NA-1005. Otherwise, shared accounts can be temporary, and would be covered under items 011 and/or 012 of GRS 6.1.
To determine whether or not a shared account should be included as a permanent account, consider the following:
| Scenario | Disposition |
|---|---|
|
The shared account relates to an office or function that otherwise produces permanent records outside of email or other electronic messages.
|
Permanent. Include it in category 10. |
|
The shared account relates to, or is checked by, staff that are otherwise Capstone (permanent) officials.
|
Permanent. Include it in the appropriate category. In the example provided, this would be category 8, which already includes the General Counsel. |
|
The shared account relates to an office or function that is administrative. For example, a group email account assigned to a finance office.
|
Temporary. Include in item 011 or 012. |
4. Must agencies maintain a list of Capstone officials and their associated email addresses or messaging identifiers?
Yes. Agencies should maintain an extended version of form NA-1005 that includes this additional information. Doing so will support the requirements in 36 CFR 1235.48, which requires agencies to include proper documentation when transferring permanent electronic records to NARA. The NA-1005 list will help agencies implement Capstone and export and transfer permanent records. Agencies should consider managing and keeping up-to-date a list of Capstone officials and their associated email addresses and/or identifiers for other messages as part of agency policy (one of NARA’s recommended best practices). See also See Section 8: Questions about Permanent Records Transfer related to required documentation at the time of permanent records transfer.