Preventing Mistakes in E-mail Records Management

By Brian Murphy

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Recommendation: Develop a comprehensive e-mail management program immediately:

• Establish appropriate employee e-mail usage and content rules. Monitor employee e-mail to ensure compliance with these rules.
• Apply the organization’s records-retention schedule to e-mail records.
• Establish that e-mail messages are to be saved only for legitimate business or legal reasons.
• Migrate official e-mail records to an approved e-mail management system.
• Purge e-mails that are not official records from the e-mail system on a predetermined schedule.

Mistake 2: Destroying all e-mail by auto-purges or mailbox caps. Some companies, concluding that they need drastic action, implement 30-, 60-, or 90-day e-mail deletion policies or mailbox size limits. This approach is inherently flawed and flies in the face of decades of records-management practices. Records-management best practices dictate that the company determine what it legally and operationally needs to keep, determine the retention period, and implement that policy consistently, regardless of records’ formats.

Recommendation: Do for e-mail what is done for other business records:

• Establish a policy that includes legal and operational needs.
• Train employees and provide ongoing e-mail policy communications and education.
• Give employees the tools by which appropriate e-mail can be archived.
• Allow managers to immediately modify the system to identify and protect additional classes of e-mail as required.

Mistake 3: Using backup tapes as an archive. Many companies think they are archiving their e-mail because they back them up onto tapes. But the goal of tape backup is to create a temporary copy that can be accessed and restored if the primary system has a failure. Backup tapes are not intended for routine exploration, discovery, or retrieval. They are almost impossible to efficiently search because they are not indexed. Locating unindexed, individual e-mail records is difficult and expensive.

Recommendation: Backing up is a critical process, but separate from archiving. Compliance, records management, and legal departments need to work closely with IT to ensure that the backup policy is reasonable and in synch with the organization’s retention policy. A good, reasonable practice is to keep only daily tapes and to rotate those tapes every 30, 60, or 90 days based on the company’s operational requirements.

E-mail business records should be stored and managed in a digital archive designed for low-cost, long-term archiving. This archive should have tools for easy searching, discovery, organization, and retention management.

Mistake 4: Assuming that the company’s existing document-management system can handle e-mail archiving. Companies with a major investment in a document-management system may believe that this system can be adopted for e-mail management archiving. The volume and indexing requirements for enterprise-wide e-mail archiving, however, are dramatically greater than standard document-management volumes.

Recommendation: Determine the company’s monthly and annual e-mail archiving volume and indexing requirements. The IT department needs to determine whether the existing document-management system can scale to support the company’s e-mail volumes. IT should also evaluate the scalability and costs of dedicated e-mail management archiving solutions versus an upgrade to the document-management solutions. In most instances, a dedicated e-mail management solution will be more cost-effective and provide much greater scalability
than enhancing the document-management system.

Mistake 5: Implementing an e-mail retention policy that was optimized for paper. Many companies try to implement paper records–retention policies without considering the unique requirements of e-mail. Implementing e-mail retention based solely on a paper records–retention policy will probably result in an onerous process that employees will not adopt. The user classification processes for paper records don’t work for e-mail because of the volume of e-mail generated. Also, there are too many record classifications for end users to practically classify their e-mail. Administration of e-mail retention cannot be delegated in the same way as with paper records.

Recommendation: The company must make e-mail retention simple for its employees. Existing paper records–retention policies can be used as a framework for developing record classifications, rules, schedules, and policies that have been simplified and optimized for e-mail records. User intervention should be kept to a minimum to help ensure adoption.

What to Do?

If a company is committing one or more of these mistakes, it should consider the following:

• E-mail volumes and potential e-mail storage costs will continue to escalate for the foreseeable future.
• Many lawyers now refer to e-mail as “evidence mail.”
• The rash of accounting irregularities and allegations of wrongful document destruction are driving stronger enforcement of existing regulations as well as new laws with stronger penalties.