And Records Management Best Practices An IMC and … · And Records Management Best Practices An...

The Capstone Emai l Approach And Records Management Best Pract ices

An IMC and Integro White Paper Prepared by

Information Management Consultants, Inc.

11480 Commerce Park Drive

Reston, VA 20191

Phone: (703) 871-8700

Integro, Inc.

88 Inverness Circle East N 106 Englewood CO 80112

Phone (303) 575-9300


The Good, The Bad, and The Ugly of Email Management

The Office of the President has placed an increasing emphasis on the

management of electronic records in an effort to save costs and increase

efficiency. This is based upon the belief that documents "born digital" are

more effec vely managed and processed if they remain in a digital format.

However, the ease with which organiza ons can create and process

informa on in digital formats merely increases the volumes of informa on

to be managed, which in turn creates its own set of challenges.

Email is a significant concern. Its sheer volume is cause for special a en on.

A recent survey by the GigaOM Group found that email use by workers has

increased by 78% over the past five years. Eighty‐three percent of those

workers surveyed indicate they use email as a primary business

communica ons tool. A 2011 study by the Radica Group predicts that a 7%

growth rate will result in 4.1 billion email accounts by the end of 2015.

The Radica Group also says the typical corporate email user sends and

receives approximately 105 email messages per day. While the rate of

growth for email messages is slowing somewhat, the amount of total

communica ons con nues to increase –it is just moving to other channels,

e.g., instant messaging

and social networks. Is it

any wonder that 57% of

the respondents in the

GigaOM survey describe

feeling overwhelmed and

50% blame email for

workplace tensions? This

is the classic "love‐hate”

rela onship.

“GAO Report 08-742 says that email systems must not be used to store record-keeping copies of email messages identified as records. Email must be stored in

an appropriate record-keeping system.”


The US Government Accountability

Office (GAO) issued a report, GAO‐

08‐742, which states that email

systems must not be used to store

record‐keeping copies of email

messages iden fied as records, and

that email must be stored in an

appropriate record‐keeping system.

The report also noted that email

transmission data and distribu on

lists must be maintained.

The Good

So why do we love our email? Email

can offer organiza ons and

individuals tremendous benefits as

a communica ons tool. The cost is

rela vely low when compared to

exchanging paper documents or

even telephone calls. Most systems

allow for simultaneous distribu on

to mul ple recipients with ease,

and the transmission is nearly real

me. It is easy to understand and

use, enhancing user adop on.

Especially for large and

geographically dispersed

organiza ons and working groups,

email solves two basic problems of

communica on – synchroniza on

and logis cs, the problems of

"any me/anywhere."

Synchroniza on. For mee ngs and

phone calls, par cipants must be

synchronized – they have to meet

on the same schedule and spend

the same amount of me in the

mee ng or call. Using email as the

communica on tool, users do not

need to operate on the same

schedule, be in the same place at

the same me, or spend the same

amount of me processing the

informa on. Email allows for

asynchrony – it solves the challenge

of "any me."

Logis cs: This is the challenge of

"anywhere." In today's world,

people are more mobile and

organiza ons are increasingly

distributed. Federal government

agencies especially face this

challenge. People are no longer

physically in the same building,

area, or even country. Thus se ng

up and a ending an in‐person

mee ng, telephone call, or

conference call can be

inconvenient, me‐consuming, and

costly. Again, with email,

par cipants in a business process

do not need to be in the same

place at the same me. And with

mobile devices growing in

prevalence, place becomes even

“Email use by workers

has increased 78% over

the past five years”—

GigaOM Group Survey


less of a concern. Workers no

longer need to be in an office.

The Bad

Then what do we hate about

email? Es mates indicate that

knowledge workers spend nearly a

third of their day working day on

email – reading it, ordering it,

sor ng it, and wri ng it.

Along with the increasing volume

of email, there are several

problems that can be specific to

email communica ons, including:

Lack of context. Because of the

ease of distribu on to large groups

of people, users are o en copied

on emails for which they have no

context. Time is then spent by the

recipients determining context,

which can lead to unintended effort

expended by the recipients in an

a empt to process or respond to

emailed informa on.

Informa on overload. Email is a

push technology – the sender

controls who receives the

informa on. Convenient availability

of mailing lists and use of "copy all"

can lead to people receiving

unwanted or irrelevant informa on

of no use to them. Who among us

hasn’t received unintended and

unnecessary communica ons from

senders availing themselves of the

"reply all" func on in most email

systems?

Inconsistency. Email can duplicate

informa on. This can be a problem,

for example, when a large team is

working on a document. If they are

not in constant contact with the

other members of their team, they

can create shadow files and

mul ple versions resul ng in

addi onal storage costs and legal

risk to the organiza on.

The Ugly

The prolifera on of electronic

communica ons, par cularly email,

means that everything we do and

communicate ends up documented

and stored in mul ple loca ons.

What used to be an informal water

cooler conversa on may now

become a business record email

maintained in mul ple repositories

across several organiza ons.

This makes email a par cularly rich

target for li ga on discovery and

freedom of informa on act (FOIA)

requests. Good email management

is more important than ever. Email

which rises to the level of a

"government record" must be


properly maintained, whereas non‐

record email must be deleted in a

mely fashion in order to avoid the

costs of storing and managing

valueless data; the poten al legal

risk and reputa onal

embarrassment; as well as the legal

and IT costs in the event of legal

discovery or FOIA requests.

People are prone to dash off

informal comments in an email in a

manner they never would with a

formal le er. Less care is given to

grammar and context. A signature

is generally omi ed, so

authen ca ng an email presents

issues not associated with a

tradi onal le er with its formal

le erhead, paragraph structure

and signature block.

A big challenge with the use of

email as evidence is that email is

arguably more suscep ble to

altera on a er‐the‐fact. Most

email systems allow a person

forwarding an email to edit the

message being forwarded. This kind

of altera on would not generally

be discernible to recipients. Emails

are also more prone to a kind of

hearsay‐within‐hearsay problem:

an "email stream" or “email within

email” is created when an email

includes every email that came

before it in a discussion. It may not

be sufficient to get the most‐recent

email into evidence if that email

a aches a stream of previous

emails. All the prior a ached emails

may need to be separately

authen cated before it can be held

to be admissible.

While there are a number of

challenges to using email as

evidence, authen ca on is

arguably of most concern. The bar

set for establishing authen city is

not high under the Federal Rule of

Evidence 901. According to the 3rd

U.S. Circuit Court of Appeals, a

court need only be able to

legi mately infer that a document

is genuine to find it to be

"authen c." In the 2006 court case

of the United States v. Safavian, the

court held that detailed

authen ca on was not required

when faced with a large volume of

email.

The Capstone Answer

Confronted with these challenges

of volume, regulatory and legal

concerns, and ghter budgets, how

can government agencies address

the problem of email

management? It will certainly be a

challenge, and no one solu on will


be right for every organiza on and situa on. Agencies and organiza ons

will have to evaluate a number of factors and invest me in addressing the

challenges of technology and governance.

With the Administra on's imposi on of a 2016 deadline to address the

challenges of managing email, Government agencies have limited me to

solve such a big problem. In recogni on of this, the Na onal Archives and

Records Administra on (NARA) is circula ng a dra memorandum en tled,

"Guidance on a New Approach to Managing Email Records," in which NARA

proposes the "Capstone approach":

"NARA developed the Capstone approach as part of NARA's

con nuing efforts to evaluate how agencies have used email

repositories to manage email records. This approach was

developed in recogni on of the difficulty in prac cing

tradi onal records management on the overwhelming

volume of email that federal agencies produce. Capstone will

provide agencies with more workable solu ons to email

records management challenges, especially as they consider

cloud‐based solu ons. Moreover, the Capstone approach

supports the Presiden al Memorandum on Managing

Government Records and allows agencies to comply with the

requirement in OMB/NARA M‐12‐18 Managing Government

Records Direc ve to 'manage both permanent and

temporary email records in an accessible electronic format'

by December 31, 2016."

NARA developed the

Capstone approach in

recognition of the

difficulty of practicing

traditional records

management on the

overwhelming volume of

email federal agencies

produce.


The Capstone approach gives

agencies the op on to easily

automate email management for

permanent email records only from

"the accounts of officials at or near

the top of an agency or an

organiza onal subcomponent." The

main assump on behind this

approach is that Capstone email

accounts are for people that create

or receive presump vely

permanent email records. This

means that all email in accounts

designated as Capstone accounts

would be categorized as permanent

records. The remaining email

accounts would be considered to

have temporary records, and would

be preserved only for a period

based on the agency's need.

This approach offers the

advantages of expediency and

simplicity. The process of

submi ng records to an archive

system can be easily automated. It

ensures that all record emails are

captured. It eases the burden of

email management on end‐users

where no automated solu ons are

in place. What this approach does

not do is eliminate an agency's

responsibility to manage record

emails consistent with federal laws,

regula ons and policies (see 36 CFR

1236.20).

However, the approach raises a

number of concerns, many of

which are acknowledged by NARA.

It also fails to take into account the

capabili es of rapidly maturing

technology solu ons, which aid

email management and provide

automa c categoriza on of

content and records declara on.

The broad "dragnet" approach

taken for the capture and reten on

of Capstone accounts does not, as

NARA notes, "op mize access to

records responsive to discovery or

FOIA requests." Such an approach

could significantly increase the size

of the archive, increasing the cost

and complexity of finding

responsive emails. In addi on, non‐

record emails would be ingested

into the repository, thus increasing

the legal exposure of the agency

and its officials – a concern NARA

acknowledges. Studies have found

that even for users that would

qualify as Capstone accounts, easily

95% of their email is of a transient

nature and would be over‐retained.

All Capstone email messages will be

maintained permanently, which

increases the overall costs of

“The Capstone approach

does not optimize access

to records responsive to

discovery or FOIA

requests, and could

significantly increase the

size of the archive, and

the cost and complexity

of fulfilling requests.”


storage and future processing, such

as declassifica on reviews. All non‐

capstone messages will be assigned

a single temporary reten on, which

means historically important

messages may be deleted, while

redundant, obsolete or trivial

(ROT™) messages may be kept

much longer than required – again,

increasing the total cost of storage

and increasing the size of the

repository.

This approach also fails to take into

account the context, subject ma er

or a achments of a non‐capstone

email message. Records

management best prac ces would

require that the message and

associated a achments be

categorized into an appropriate

records schedule based on their

subject ma er, and not based on

medium or user level. It would

certainly not be best prac ce to

retain all paper documents

regardless of content, but based on

only the creator or recipient.

Technology‐Enhanced Email

Management

It must be acknowledged that the

most common email systems are

not designed with an eye to

content and records management.

They perform the func on of

handling email very well, but were

never designed to serve as high‐

volume, enterprise class content

repositories or records

management systems. This leaves

agencies with a choice between

making significant modifica ons to

these systems and moving those

emails that are records to an

appropriate records repository. The

earliest a empts around email

management required extra steps

by users. Within any organiza on

or agency, records management is

a responsibility of everyone, but it

is the primary job of only a few.

Most email users are concerned

with their primary jobs. Records

management adds to the users’

tasks, and is o en seen as an

intrusion into their daily work.

Capstone addresses this

shortcoming by making it easier to

automate the process, but at the

expense of accuracy and best

prac ces.

Email must be managed, not just

archived. Most studies indicate that

approximately 80% of all email is

either redundant, outdated, or

trivial. The result of a bulk‐

archiving approach without regard

to the value of the content will


result in exponen ally increasing

costs well into the future.

Newer products such as Integro

Email Manager (IEM) and IBM

Content Collector (ICC), combined

with auto‐categoriza on

technologies, have matured

significantly in their ability to

automate the categoriza on,

metadata capture, and declara on

of record emails. These

technologies can be deployed to

make records management

ac vi es less burdensome on end‐

users, while maintaining best‐

prac ce records management

procedures.

IEM provides proper declara on

and classifica on of email content

while automa cally disposing of

transient, non‐essen al email. IEM

is the only product in the market

that enables “auto‐classifica on

with human oversight,” delivered

via Integro’s patent‐pending

SmartAssist®. With SmartAssist,

IEM is designed to auto‐categorize

emails to the extent possible, while

providing end users with the

ul mate control in approving the

categoriza on.

IBM Content Collector for Email

collects, processes, and archives

content from Exchange, .PST files,

and Notes servers. It supports both

email and public folders along with

several archiving paradigms

including:

Journaling for compliance

Mailbox management for

storage savings

User driven mailbox archiving

for business value

Advanced PST processing

capabili es to help manage

personal archives

IBM Content Classifica on Module

can be deployed to support ICC.

The Content Classifica on Module

has natural language processing

technology that can analyze digital

content and apply a predefined

taxonomy to discover possible

categories and relevancy scores.

This process can be invoked as part

of an ICC process to:

Iden fy emails that should be

declared as records ‐ This will

ensure agency compliance with

record reten on and

disposi on policies,

automa cally analyze emails for

sensi ve data such as

personally iden fiable


informa on (PII), tag them with

a confiden al unclassified

informa on (CUI) marking, and

declare such emails as records ‐

without user input.

Assign a folder path and record

category ‐ This supports

archiving emails or documents

on file systems into known

folders and assigning a record

category to invoke the

appropriate disposi on

schedule.

Add metadata proper es ‐ The

metadata of the archived

emails can be populated with

the top category names and

other extracted informa on,

along with the "header"

informa on required under the

CFR.

These technologies are trainable,

meaning they can learn to

categorize email by record types.

They are ini ally trained by

compiling a corpus of iden fied

informa on and submi ng it to

the system for processing so the

technology learns to iden fy record

types. ICM so ware also has the

ability to learn from any feedback

provided to it by end users. As end

users override or suggest changes

to content categoriza ons through

their normal course of business,

the system adapts its training and

understanding in real me. The

so ware can also review items that

do not fit into the current records

file plan or category structure and

provide category sugges ons in a

clear, priori zed list.

The US Army realized the need to

properly manage email messages

as records, but also understood

that expec ng soldiers in the field

or suppor ng combat opera ons to

be knowledgeable about records

management procedures and

policies was not prac cal.

Recognizing that technology could

poten ally support these

requirements, the Army elected to

test ICC and Content Classifica on

Module to support email

management. A pilot project was

conducted using 16 offices focusing

on approximately 400 email users.

The pilot program included 314

records categories applying to

these selected offices. The pilot ran

for approximately 90 days a er

ini al training of the system. The

system was, a er real‐ me

training, able to recognize 98.4% of

emails.

In a US Army pilot

project consisting of 400

email users, IBM’s

Content Classification

Module achieved 98.4%

recognition.


Summary

Clearly the Capstone Procedure is a well‐considered op on for federal

agencies pushed to comply with email management requirements.

However, the procedure does not allow for the necessary "sani zing" of the

email messages so that personal, trivial or redundant messages are not

passed to a records repository.

While we concede the appeal of such a simplified approach, we believe it

does not comport with records management best prac ces while also

exposing agencies to an increase in costs and legal risk. We believe the

Capstone approach severely underes mates the long‐term costs and

poten al adverse consequences of bulk‐archiving.

We believe that technologies have now matured to the point that agencies

can take advantage of these technologies to automate the process of email

management. This will reduce the cost of long‐term storage, lower legal

risks, and decrease labor costs by significantly lowering the total me

required to review and sani ze email files, and make agencies more

responsive. Therefore, we believe agencies should consider pilot projects

for these email management technologies.

At IMC and Integro, we know how to help agencies comply with NARA

regula ons, reduce your exposure and save money. Let us show you how

we can help you solve the challenge of email management.

About IMC

For over 30 years, Informa on Management Consultants, Inc. (IMC) has been providing

proven methodologies, exper se and award‐winning technologies, services, and powerful,

flexible, and scalable ECM solu ons to leading public sector and commercial clients. IMC’s

solu ons allow clients to use informa on as a strategic asset and enable them to make

be er decisions, improve service levels, reduce risk and manage compliance.

About Integro An industry recognized product and services company, Integro specializes in solu ons for

Enterprise Content Management, Informa on Governance, Email Management,

eDiscovery, and Records Management. Integro’s email management product, Integro

Email Manager (IEM) offers value‐based archiving, which enables companies to keep the

email that is important for business, legal and regulatory obliga ons, while elimina ng the

costs and risk exposure of over‐reten on of email.

The use of automated

categorization

technologies will:

Reduce long-term costs;

Lower legal risks;

Lower labor costs;

Make agencies more

responsive.

The Capstone Approach

And Records Management

Best Practices

The Good, The Bad, and The Ugly

©2013 IMC, Inc.

Information Management Consultants, Inc.

11480 Commerce Park Drive

Reston, VA 20191

Phone: (703) 871-8700

http://www.imc.com

http://www.accessimc.com

[email protected]

Integro, Inc.

Phone: (303) 575-9300

www.integro.com

[email protected]

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