Section 6: Questions about Legacy Records

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1. How are legacy records defined for GRS 6.1?

In the context of this GRS, legacy records are records that still exist in an electronic format, whether part of a temporary or a permanent account, at the time of Capstone implementation. These records may be stored in an email archiving application, a document management system, in individual files (such as *.PST files) on local computers or drives, within current live email applications/systems, and/or stored in other ways. 

2. Does the Capstone GRS apply to both retroactive (legacy/existing) and day-forward records?

Yes.  NARA expects an agency using this GRS to apply the items the agency uses to all legacy (existing) records. Agencies should summarize the extent of their legacy records within the “Legacy Scope” field on their form NA-1005. For example, an agency might state that no legacy records exist for the agency before a certain date, as the agency used traditional records management with a print-and-file policy prior to adopting Capstone. NARA acknowledges that legacy records may be incomplete, or that position titles may have changed over time. In cases of title changes, the agency should apply GRS items to equivalent positions. 

3. Does legacy email include backup or recovery tapes with email stored on them?

No. These tapes were not created for records management purposes, and are outside the scope of GRS 6.1. Backup/recovery tapes are covered under GRS 3.2, item 050, “Backup files identical to permanent records scheduled for transfer to the National Archives,” or GRS 3.2, item 051, “Backup files identical to temporary records authorized for destruction by a NARA-approved records schedule.” 

4. Can other disposition authorities be used to dispose of email and other types of electronic messages prior to using the authorities within GRS 6.1?

Yes. Whether or not to allow the application of other disposition authorities to email and other electronic messages is an agency decision. Agencies should address the application of other disposition authorities in agency records management policy. See Section 5, Questions about Implementation, for additional information. 

For example, an agency may apply: 

• GRS 5.1, item 020, which authorizes deletion of electronic records once filed in an official recordkeeping system (such as with a related case file, or within another records management application) prior to use of the appropriate item from GRS 6.1;
• GRS 5.2, item 010, which authorizes the deletion of transitory records; and/or
• Other NARA approved, media neutral, agency specific disposition authorities. See Section 7: Questions about Culling, for additional information. 

This strategy is essentially applying a certain level of traditional records management before applying the disposition authorities provided in GRS 6.1 

5. What do we mean by ‘readable email’?

Readable email is email that is retrievable and usable for as long as needed to conduct agency business, to meet disposition requirements, and to ensure the transfer of permanent records to the legal custody of NARA. This aligns with the requirements of 36 CFR 1236.12(b), related to records management and preservation considerations that must be incorporated into the design, development, and implementation of electronic information systems. Email that is not retrievable and usable is, therefore, not readable. 

6. What do I do if I have legacy records that are not readable?

Currently NARA is requiring agencies to submit a schedule for legacy email and other types of electronic messages that are not readable. Please contact the GRS Team at GRS_Team@nara.gova> to discuss your situation further.

7. What if the status of legacy email and other types of electronic messages is unknown?

Agencies may still submit, and receive approval of, the form NA-1005. NARA understands that agencies may not be able to fully articulate their legacy records scope, and how legacy email and other types of electronic messages will be addressed, at the time of form submission. This may be due to the complex nature of older technology, access issues, or an agency needing time to inventory legacy records.

In these cases, agencies should notate as much information as possible on the form NA-1005. Examples of responses may be “Agency is still determining the full scope of our legacy records. We believe it dates back to approximately 2003. We will report our full findings to NARA within 6 months.” or “We have determined the scope of our email, which extends back to 2000, but we are still determining our access issues and will report our full findings to NARA in 6 months.”

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