Section 7: Questions about Culling

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1. What is culling?

Culling, in the context of Capstone implementation, is the act of removing or deleting material prior to disposition. This may include deleting non-record email and other electronic messages [e.g., email blasts (such as agency-wide communications), spam, and personal email and other types of electronic messages (records belonging to an individual and not related to agency business)], and transitory records (records of short-term interest or that have minimal documentary or evidentiary value). Please refer to GRS 5.2, item 010, and FAQs about Transitory Records in Electronic Messages for additional information on what constitutes a transitory record. 

2. Are agencies expected to cull Capstone (permanent) accounts?

Yes, in order to minimize the amount of non-record and personal records agencies transfer into the National Archives. Since agencies are most familiar with the content of their records, we expect agencies to cull permanent accounts to the greatest extent possible. Culling may be manual, automated, or a hybrid of both. We do not expect agencies to cull temporary accounts, but you may do so in accordance with your agency’s policy as appropriate. 

For temporary records, agencies may choose the amount of culling it will allow, based on agency business needs and concerns (such as size of the email repository, cost of maintenance, and risk associated with the possible destruction of records that may be needed for agency business, including litigation). 

3. What if an agency can’t cull records?

An agency should review its policies and technology to determine and verify its culling capabilities. Some technologies may not allow culling as described in question 2 above.  Agencies may still implement Capstone for permanent accounts without culling, but this will result in the agency transferring to NARA material that does not meet the definition of a federal record, which NARA might then permanently preserve. 

NARA screens and, when warranted, withholds access to accessioned records in accordance with the general restrictions set out in 36 CFR 1256.40-1256.62. NARA decides on the access permitted to accessioned records containing personal privacy information as outlined in 36 CFR 1256.56 without consulting the originating agency. As part of our mission to provide public access to federal government records, we disclose records whenever legally permissible. As a result, we could release personal information in non-records that an agency or user did not cull prior to transfer. 

4. Will NARA cull Capstone records after they are legally transferred?

Yes, NARA has this authority. In accordance with 44 U.S.C. § 2108, the Archivist of the United States assumes custody of these records when they are transferred. NARA administers accessioned records in accordance with 44 U.S.C. Chapter 21, 36 CFR Part 1256, and other rules we promulgate to dispose of non-record materials we find in any transfer. However, we cannot guarantee that we will find or cull non-records.

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