Letter: E-mail rules already exist

Regarding “Panel would reform records storage”: Although I applaud the efforts of the House Oversight and Government Reform Committee, I'm sort of at a loss to understand why there is so much angst here and also the focus on e-mails, aside from the fact that they have been knowingly deleted.   

The requirements for managing anything that meets the definition of a “record” in federal agencies couldn't be any clearer than what is spelled out in 36 CFR, Subchapter B. Anyone who has ever worked for a federal agency or for a contractor funded by one should have no questions about the practices, and in reality, they should consider themselves fortunate because they are black and white — there are no gray areas.

The reason I mentioned a concern about looking at e-mail independently is because the practice in the federal arena is to manage records by the series they belong to, which is loosely based on the functional area they support (admin, human resources, finance, procurement, etc.) and then the content of the record — not the media, form, format or method of conveyance. To look at an e-mail message as an item and determine how long it's kept would be like looking at envelopes as an item and assigning a retention period to them.  

E-mail is a conveyance, nothing more. It's the content of the e-mail message that you base your retention decisions on. And guidance on managing e-mail is clearly spelled out in 36 CFR Part 1234.24. Overall guidance for managing electronically generated or received records is covered in 36 CFR Part 1234. The reason for these formats of records having separate guidance is to address the unique challenges of managing and providing persistent access to content that is subject to a need for conversion and/or migration practices to ensure it remains accessible for its entire retention period.  

This is also the reason for the seemingly arcane guidance that electronically formatted records be printed and retained on paper if there is no viable plan in place for effectively managing and migrating them to meet their required retention.

So why is a committee needed to investigate the application of existing laws and regulations? And why is it going to take years to comply with requirements that have existed for more than a decade? I guess that's just another example of our government at work.

Larry Medina
Danville, Calif.


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