4 Considerations When Setting Email Retention Policies
Your Guide to Integrated Correspondence Management, Retention & Implementation
All email is not created equal. The first decision we make when filtering through our inbox is: “Is this email important or not?” This is the same decision we ask our employees to determine when dealing with documents every day. Why then, do we treat email differently than say, the mailroom?
The Cause of Email Management Problems
Most organizations have already invested in a document management system, which typically serves as their official records management and retention system as well. We invest heavily in technologies, like electronic/smart forms, which help us automate data entry, workflow and document management. However, most organizations do not have tools that integrate with email messages and their attachments to provide similar functionality.
Email transactions themselves are quite structured. However, the content within email systems are highly unstructured. This inherently is why email has been so difficult to manage by individuals. If your IT department has invested in email management technology, it is most likely a system which journals and archives all email on the server side into a separate, disparate archive platform.
A New Way to Manage Email
What if we were able to treat email messages and their attachments like an electronic form or smart form? What if we were able to fill out some basic information about an email before it was sent or just after it was received and from then on, it would be automatically tracked and integrated with our existing document management system?
We’d then be able to leverage our existing DM/ECM system for email, which is an integral part of both our daily workflows and records management strategy. At the same time our users would have more centralized search and better access to this information, our records management and retention strategy would be unified into one system vs. two or three. Below, are four categories to consider when setting up your email retention policies?
Varying Email Retention Requirements
When considering your email retention policy, know that different types of email should be retained longer than others. Email management and retention requirements are predominantly based on the incorporation status of your organization.
- Federal Government
- State & Local Government
- Publicly Held
- Privately Held
- Non-Profit Institution
To varying degrees, each incorporation type is subject to certain regulatory requirements, which most often trickle down at the federal level and/or are based on judicial precedent. In the mid-2000s, local, state, and federal court systems began authorizing the admissibility of electronic documents without requiring the original paper copies. Admissibility still varies to some degree, but the most important factors to consider here are immutability and the chain of command. Can you show intent and control of your electronic information? Audit trail information and automation are key here.
In general, the following guidelines might be used to start to develop a more detailed records retention strategy. If you have already set up taxonomies and classification within your DM/ECM system, then certainly start there to better understand how your organization currently leverages meta data to manage information.
Always consult legal counsel or your records management administrator if your organization is highly regulated.
Categorization, Distribution & Retention Guidelines by Email Type
- Administrative correspondence 7% (4 years)
- Fiscal correspondence 3% (4 years)
- General correspondence 60% (3 years)
- Ephemeral correspondence 30% (12 months)
Administrative correspondence makes up roughly 7% of your organization’s total email and includes email relating to holidays, dress code and workplace behavior among others. Additionally, administrative correspondence can derive from Human Resources and be specific to individual employees. Emails that include confidential information such as wages, hours worked, and benefits are also considered to fall into the administrative correspondence category. As a general rule of thumb, all correspondence labeled “Management Only” needs to be treated as administrative.
Fiscal correspondence encompasses all information related to revenue and expenses for the company. Although this category is typically not voluminous, it does require a longer retention period. We recommend implementing a retention policy for at least four years for e-discovery purposes.
General correspondence covers information that relates to customer interactions and the operational decisions of the business. The individual employee is responsible for email retention of this type of correspondence, which tends to be the largest for most organizations. We recommend retaining general business correspondence for at least three years. The challenge here is discerning general correspondence from ephemeral correspondence.
By definition, these are records of a preliminary or informational nature received or sent that do not contain significant information about an institution’s programs, fiscal status, or routine agency operations. Ephemeral correspondence is the second largest category of email in your organization and should be deleted immediately. However, enforcing this policy on employees is nearly impossible.
CMA, along with its email management and automation technologies can assist you and your organization to better classify, track and archive email in a manner consistent with your firm’s email retention policies.