February 18, 1999

IRM BULLETIN NO. 1999-001

To: Heads of Offices
Office of the Secretary Employees
From: Daryl W. White/signed by/
Chief Information Officer

Subject: Transitioning to Lotus Notes Electronic Mail - Records Management Guidance

The purpose of this Information Resources Management Bulletin is to provide records management guidance to all Offices of the Secretary (OS) that are or will transition from cc:Mail to Lotus Notes. This guidance is based on current policy issued by the National Archives and Records Administration (NARA). NARA's regulations declare that depending on the nature of the message, electronic mail (E-mail) can be considered a record (Record), under the Federal Records Act, 44 U.S.C. §3301. This means that an E-mail message considered to be a Record must be filed in an agency-approved recordkeeping system, along with associated attachments and transmission data.

The OS's current recordkeeping system is the existing paper records filing system. Until a NARA-approved electronic recordkeeping system is selected, tested, and installed, all official E-mail messages and attachments that meet the definition of a Record must be added to the organization's files by printing them out (including the essential transmission data) and filing them with all related paper records.

DEFINITION OF AN ELECTRONIC MAIL RECORD

E-mail messages are Records when they (1) are created or received in the transaction of agency business, and (2) are appropriate for preservation as evidence of Department of the Interior's (DOI) functions and activities, or are valuable because of the information they contain. (44 U.S.C. §3301)

As a guide for determining whether a document, such as an E-mail message, meets the statutory definition of a Record (above), the Department of Justice applies ten criteria. As adopted for DOI use and listed below, these criteria should be helpful in determining whether an E-mail message is a Record.

1. It contains unique, valuable information developed in preparing position papers, reports, studies, etc.;

2. It reflects significant actions taken in the course of conducting DOI business;

3. It conveys unique, valuable information about DOI programs, policies, decisions, or essential actions;

4. It conveys statements of policy or the rationale for decisions or actions;

5. It documents oral exchanges (in person or by telephone), during which policy is formulated or other DOI activities are planned or transacted;

6. It adds to the proper understanding of the formulation or execution of DOI actions or of DOI operations and responsibilities;

7. It documents important meetings;

8. It facilitates action by DOI officials and their successors in office;

9. It makes possible a proper scrutiny by the Congress or other duly authorized agencies of the Government;

10. It protects the financial, legal, and other rights of the Government and of persons directly affected by the Government's actions.

Appropriate Use of Electronic Mail. Government-provided electronic mail is intended for official and authorized purposes. E-mail users must exercise common sense, good judgment, and propriety in the use of this Government resource. While short personal messages are acceptable, parallel to the way Government telephones are sometimes used, other nonofficial uses are prohibited. Messages and loose language could be taken out of context and lead to inappropriate or potentially damaging conclusions. The use of profanity, racial or ethnic slurs, sexually harassing language, slander, and other such language is as inappropriate in E-mail as in any other medium. Unless authorized to do so, avoid the use of E-mail to send messages that contain confidential and/or sensitive information or private information about an individual or employee.
To ensure that we follow Federal records management policy, the transition from cc:Mail to Lotus Notes will require some adjustments in our E-mail records management business practices due to the software constraints and improvements. Following are changes which will affect E-mail Records:

1. Retention of E-mail Messages - Current policy (formulated to support cc:Mail) dictates that Local Area Network (LAN) Administrators delete mail from individual employee E-mail boxes after 30 days. Lotus Notes does not function based on a time limit. Instead, each employee's E-mail box is limited to approximately 40 megabytes of storage for mail. This equates to approximately 200 messages (possibly more, depending upon the length of the messages), including messages received, sent, and drafts (saved but not sent). After a mailbox has reached the 40 megabyte limit, an employee will be able to receive messages but not send additional messages until his or her E-mail box is cleaned out. Therefore, OS LAN Administrators will no longer perform "automatic" deletions of E-mail messages. This new space limitation will require employees to be vigilant in managing the number of messages in their mail box, copying and filing E-mail Records into the appropriate paper filing system, and deleting those messages that do not constitute Records.

2. Archiving - Archiving (or storing E-mail messages on your hard drive) is not an acceptable Records storage method because the records are not easily accessible to other employees. The Lotus Notes archiving feature should only be used for storing "personal" copies of reference documents, not for the storage of official E-mail Records. Official E-mail Records must be printed in paper and filed in the agency paper filing system. Until an electronic recordkeeping system is implemented, we have no means to electronically store and manage E-mail Records in accordance with Federal recordkeeping requirements. Employees may also store E-mail Records, for unofficial use , with their word processing files located on a shared (public) directory for easier retrieval and use.

3. Maintenance of Message Recipients - In cc:Mail, the information screen containing the complete transmission data (e.g., full mailing lists) was sometimes separate from the message, requiring employees to print this separate screen for recordkeeping purposes. In most cases, Lotus Notes includes the transmission data directly on the message. While this arrangement may appear to make the message cluttered, it is an important part of the message and must be copied and retained as part of all E-mail Records. However, if all of the transmission data (e.g., complete list of message recipients) does not appear on the message, a complete list of the message recipients must be printed and filed with the paper copy E-mail message. An example of this is usually found in messages sent to address "groups" (e.g., OS_PIR).

4. Return Receipt - The automatic message acknowledging receipt of an E-mail message is not necessarily a Record, but may be helpful or required for recordkeeping by the regulations of a particular program. Contact your Lotus Notes System Administrator for assistance in developing a standard return receipt for your messages.

5. Saved Draft Messages - Lotus Notes permits the user to save a draft message and send or delete it later at the user's convenience. Please be aware that these saved draft messages, or portions of them, may be releasable under the Freedom of Information Act (FOIA) or under an order to produce the documents as a part of litigation (see paragraph 9).

6. Replication on Laptops - E-mail systems and documents are often replicated on an employee's laptop computer. Please be aware that all documents (E-mail, word processing, spreadsheets, etc.) on a laptop, that meet the definition of a Record, are considered to be separate documents from similar documents maintained on the computer in the employee's office until they are synchronized and identical. This means that a search for Records pursuant to the FOIA or discovery must include a search for documents on laptops used for government business.

7. Forwarding Prevention Option - Under Lotus Notes, an E-mail sender may send the message in a way to prevent further forwarding. When mail is sent using this option, the recipient may not forward or copy the E-mail, but the message can still be printed by using the print screen command. This feature is most often used when sending official messages that may contain confidential, sensitive, or private information (see reference in the paragraph on the Appropriate Use of E-mail).

8. Attachments and Links to other Documents - Transmission of E-mail messages containing attachments and/or direct links to Web pages is a function of Lotus Notes. If the E-mail is considered a Record, the sender and the recipient(s) must print a copy of any attachments and certain linked document(s) and file it with the E-mail message. Links to documents that are publicly accessible (Internet sites) do not need to be printed. Links to nonpublic (Intranet sites) or significant links that contribute to the context of the message must be printed and filed with the E-mail message.

9. FOIA Considerations - E-mail messages may contain information that must be disclosed to the public, upon request. E-mail messages that are the subject of active FOIA requests or appeals procedures may not be deleted or otherwise disposed of even if they constitute Records and are authorized for destruction by an approved records schedule.

An electronic copy of this bulletin and additional information regarding basic records management is available at the following DOI Website www.doi.gov/oirm/records. Click on "Managing Your Electronic Mail Records, an Employee Guide" for detailed guidance regarding E-mail Records.

If you have any questions about managing your E-mail Records, please contact Sam Saunders, the OS Records Officer, at (202) 208-6637 or Sharon Michel, the Departmental Records Officer, at (202) 208-3321.

Reference: IRM Bulletin No. 96-06, July 25, 1996, Policy and Guidance for Managing the Creation, Retention, and Disposition of Electronic Mail Documents