Section 5: Questions related to Temporary Email and other types of Electronic Messages
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1. Does this GRS apply to classified email and messaging accounts?
Yes. This GRS applies to all records regardless of classification level. Agencies must include accounts on classified networks or systems within the relevant item on the GRS. For example, a Capstone official (permanent) with both classified and unclassified email accounts would have both included under item 010 of this GRS.
This requirement applies whether or not the agency submitting the form owns the classified network or system that hosts the classified account. For example, if your agency has an agreement to utilize and / or access accounts on the Secret Internet Protocol Router Network (SIPR) or the Joint Worldwide Intelligence Community System (JWICS), but your agency does not own those networks, the management of the email within those accounts is still the responsibility of your agency. Those accounts must be represented on the form.
It is advised that agencies, in these scenarios, establish formal memoranda of understanding (MOUs) with the host(s) to account for ownership, access, and eventual final disposition of the records.
The transfer instructions within item 010 allow agencies to transfer permanent classified email in alignment with declassification review. Agencies often don’t review classified records until just prior to the automatic declassification date, which occurs when they are 25 years old. If an agency completes its review earlier than 25 years but after 15 years, the agency should consult with NARA about when to transfer the records.
2. Does this GRS include calendars, appointments and tasks?
Some agencies may not be able to separate email records from other affiliated records, such as calendars, appointments and tasks. In these cases, the agency can include the other records under the Capstone GRS. Inclusion of these records with email or other types of messages should be noted on the NA-1005 in the scope field. However, when the agency manages these other records separately from email or other types of electronic messages, the agency must have a NARA-approved disposition authority for those records (GRS 5.1, item 010, only covers calendars of non-Capstone officials).
3. How does this GRS affect NARA or agency requirements to file email or other types of messages with other related federal records?
When using the Capstone approach for capturing and managing email and other types of electronic messages, agencies must consider whether email and other types of electronic messages (and attachments) should be associated with related records under agency guidance. As a supplement to the Capstone approach, an agency may need to associate certain email and other types of electronic messages that relate to other records, such as case files or project files. This consideration depends on an agency’s needs and how it chooses to implement its Capstone approach. This may be accomplished by (1) using electronic pointers (such as metadata tags) to establish linkages, or (2) in select cases, filing with associated paper or electronic case or project files.
4. Why do we only include acting Capstone officials in item 010 if they are acting for longer than 60 days?
The requirement to designate email belonging to acting Capstone officials as permanent only after they have served more than 60 days is in line with other government regulations and policies, such as the Office of Government Ethics requirements for filing financial disclosure forms. The presumption is that individuals acting in a position for more than 60 days are carrying out the duties of the position, while individuals acting for less than 60 days are serving primarily in an administrative role.
5. Are there any exceptions to the requirement to designate any acting official as a Capstone official after 60 days or more?
If an individual is on leave for 60 days and will be returning to their position, agencies may require the acting official to copy the Capstone official on emails and may choose not to formally designate the acting individual as a Capstone official. This approach ensures the emails created by individuals acting for more than 60 days are captured in accordance with the GRS requirement. In many situations the individuals in an acting capacity may already be a Capstone official themselves. This effectively means their emails are already captured and managed by the agency, negating the need for additional action by the records officer.
A position may become vacant and acting individuals may fill the position on a rotating basis for less than 60 days. If those acting individuals are performing the full scope of duties of the position, their emails should be captured as Capstone records under item 010.
6. What are additional considerations when implementing the requirement for capturing acting Capstone officials’ emails?
Each agency should issue additional policies on how to handle the designation and capture of emails of officials in acting positions. Agencies also need to ensure that emails of acting Capstone officials are captured for their full tenure as acting, not just beginning on the 61st day.
7. How can an agency incorporate this GRS into its implementation tools and policies?
Best practices include the use of internal implementation tools, such as manuals, handbooks, and/or file plans, for records management execution. As with any GRS, the items should be incorporated into these tools and expanded to include agency-specific information and policies. Agencies should also implement policy around their Capstone approach, to incorporate additional agency specific email and messaging guidance that does not require NARA approval. For example, this could include:
- Clearly defining the retention period for temporary email and other types of electronic messages in policy and agency manuals, since the GRS authorizes banding;
- Developing and implementing policy related to cross-filing requirements; for example, a policy that may require that certain email be cross-filed within permanent case files;
- Developing and implementing policy related to instances where temporary email or other types of electronic messages may need to be retained for a longer period than prescribed by the GRS and supporting agency policy;
- Developing and Implementing policy on the use of Government accounts for personal purposes;
- Defining the Capstone (permanent) accounts/addresses for the agency with more specificity than included in item 010, Email and Other Electronic Messages of Capstone Officials, (for example, those positions and officials specific to your agency). NA-1005 is a tool for this;
- Providing additional policy on how to handle email and messages of officials in an acting position;
- Providing policy on managing non-record email and other types of electronic messages;
- Developing policy on when other disposition authorities related to email and other types of electronic messages are appropriate for use, such as the GRS item for transitory records;
- Developing policy related to culling and other opportunities to apply records management to email and other types of electronic messages (See section 861.5 of NARA’s sample Directive posted on our Email Management webpage);
- Implementing procedures for initiating record freezes and litigation holds; and
- Implementing procedures for conducting document searches for purposes of FOIA, Congressional, and other access requests.