Although most agencies are on track to meet a presidential directive to archive email records electronically, a few will need more time.
Federal agencies are required to manage all email records in electronic format by the end of 2016. According to self-assessment reports filed with the National Archives and Records Administration, most agencies are on track to meet the deadline. However, a few will miss the mark.
The Office of the Comptroller of the Currency (OCC), the Defense Intelligence Agency and the Nuclear Regulatory Commission have said they will not meet the deadline. The Department of Homeland Security has not yet turned in its self-assessment report. The reports were due by Jan. 29.
Open-government group National Security Archive was the first to call attention to the missed deadlines.
NARA and the Office of Management and Budget issued the Managing Government Records Directive in 2012. It requires federal agencies to save email messages that qualify as temporary or permanent government records in electronic format. NARA also released guidance dubbed Capstone to give agencies a path to capturing email records based on job functions.
"There are a few notable exceptions," said Lisa Haralampus, NARA's director of records management policy and outreach. "That doesn't mean they're not managing their email, but it means they don't feel they're where they need to be with the whole life cycle of email management."
Haralampus spoke with FCW on the sidelines of Alfresco Software's Content.gov records management event on April 13. She said budget, policies and not having the right technical staff were some of the reasons agencies gave for not being able to comply with the directive.
"A lot of times, they may be saying, 'I'm not meeting 2016. I'm going to need another few months,' which is much different than saying, 'I don't know how I'm going to manage my email,'" she said, adding that 54 percent of agencies plan to use the Capstone approach.
OCC officials said in their report to NARA that they would not meet the 2016 deadline because they are establishing a cross-functional team to comply with all aspects of the directive for email and instant messaging. Defense Intelligence Agency officials said they're awaiting internal approval for NARA's Capstone approach. However, they added that they would be able to meet the 20-day requirement for copying or forwarding personal email messages related to work by the 2016 deadline.
NRC said its records team is implementing a solution based on Capstone and putting together an email capture and management working group.
On April 13, NARA published the criteria for managing email on its "Records Express" blog in an effort to clarify the requirements. The post said successful electronic email management means "having policies and systems in place to ensure that email records can be used [and] accessed."
"Their concern was everybody had a different idea of what managing email meant," Haralampus said in her presentation at the Content.gov event. Some agencies would have plans and working groups in place, but not systems.
The directive also requires agencies to manage all electronic records, including social media posts, in their original format by the end of 2019. According to the self-assessments, 80 percent of agencies are on track to meet that deadline.