The Capstone Emai l Approach And Records Management Best Pract ices
An IMC and Integro White Paper Prepared by
Information Management Consultants, Inc.
11480 Commerce Park Drive
Reston, VA 20191
Phone: (703) 871-8700
Integro, Inc.
88 Inverness Circle East N 106 Englewood CO 80112
Phone (303) 575-9300
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The Capstone Emai l Approach And Records Management Best Pract ices
The Good, The Bad, and The Ugly of Email Management
The Office of the President has placed an increasing emphasis on the
management of electronic records in an effort to save costs and increase
efficiency. This is based upon the belief that documents "born digital" are
more effec vely managed and processed if they remain in a digital format.
However, the ease with which organiza ons can create and process
informa on in digital formats merely increases the volumes of informa on
to be managed, which in turn creates its own set of challenges.
Email is a significant concern. Its sheer volume is cause for special a en on.
A recent survey by the GigaOM Group found that email use by workers has
increased by 78% over the past five years. Eighty‐three percent of those
workers surveyed indicate they use email as a primary business
communica ons tool. A 2011 study by the Radica Group predicts that a 7%
growth rate will result in 4.1 billion email accounts by the end of 2015.
The Radica Group also says the typical corporate email user sends and
receives approximately 105 email messages per day. While the rate of
growth for email messages is slowing somewhat, the amount of total
communica ons con nues to increase –it is just moving to other channels,
e.g., instant messaging
and social networks. Is it
any wonder that 57% of
the respondents in the
GigaOM survey describe
feeling overwhelmed and
50% blame email for
workplace tensions? This
is the classic "love‐hate”
rela onship.
“GAO Report 08-742 says that email systems must not be used to store record-keeping copies of email messages identified as records. Email must be stored in
an appropriate record-keeping system.”
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The Capstone Emai l Approach And Records Management Best Pract ices
The US Government Accountability
Office (GAO) issued a report, GAO‐
08‐742, which states that email
systems must not be used to store
record‐keeping copies of email
messages iden fied as records, and
that email must be stored in an
appropriate record‐keeping system.
The report also noted that email
transmission data and distribu on
lists must be maintained.
The Good
So why do we love our email? Email
can offer organiza ons and
individuals tremendous benefits as
a communica ons tool. The cost is
rela vely low when compared to
exchanging paper documents or
even telephone calls. Most systems
allow for simultaneous distribu on
to mul ple recipients with ease,
and the transmission is nearly real
me. It is easy to understand and
use, enhancing user adop on.
Especially for large and
geographically dispersed
organiza ons and working groups,
email solves two basic problems of
communica on – synchroniza on
and logis cs, the problems of
"any me/anywhere."
Synchroniza on. For mee ngs and
phone calls, par cipants must be
synchronized – they have to meet
on the same schedule and spend
the same amount of me in the
mee ng or call. Using email as the
communica on tool, users do not
need to operate on the same
schedule, be in the same place at
the same me, or spend the same
amount of me processing the
informa on. Email allows for
asynchrony – it solves the challenge
of "any me."
Logis cs: This is the challenge of
"anywhere." In today's world,
people are more mobile and
organiza ons are increasingly
distributed. Federal government
agencies especially face this
challenge. People are no longer
physically in the same building,
area, or even country. Thus se ng
up and a ending an in‐person
mee ng, telephone call, or
conference call can be
inconvenient, me‐consuming, and
costly. Again, with email,
par cipants in a business process
do not need to be in the same
place at the same me. And with
mobile devices growing in
prevalence, place becomes even
“Email use by workers
has increased 78% over
the past five years”—
GigaOM Group Survey
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The Capstone Emai l Approach And Records Management Best Pract ices
less of a concern. Workers no
longer need to be in an office.
The Bad
Then what do we hate about
email? Es mates indicate that
knowledge workers spend nearly a
third of their day working day on
email – reading it, ordering it,
sor ng it, and wri ng it.
Along with the increasing volume
of email, there are several
problems that can be specific to
email communica ons, including:
Lack of context. Because of the
ease of distribu on to large groups
of people, users are o en copied
on emails for which they have no
context. Time is then spent by the
recipients determining context,
which can lead to unintended effort
expended by the recipients in an
a empt to process or respond to
emailed informa on.
Informa on overload. Email is a
push technology – the sender
controls who receives the
informa on. Convenient availability
of mailing lists and use of "copy all"
can lead to people receiving
unwanted or irrelevant informa on
of no use to them. Who among us
hasn’t received unintended and
unnecessary communica ons from
senders availing themselves of the
"reply all" func on in most email
systems?
Inconsistency. Email can duplicate
informa on. This can be a problem,
for example, when a large team is
working on a document. If they are
not in constant contact with the
other members of their team, they
can create shadow files and
mul ple versions resul ng in
addi onal storage costs and legal
risk to the organiza on.
The Ugly
The prolifera on of electronic
communica ons, par cularly email,
means that everything we do and
communicate ends up documented
and stored in mul ple loca ons.
What used to be an informal water
cooler conversa on may now
become a business record email
maintained in mul ple repositories
across several organiza ons.
This makes email a par cularly rich
target for li ga on discovery and
freedom of informa on act (FOIA)
requests. Good email management
is more important than ever. Email
which rises to the level of a
"government record" must be
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The Capstone Emai l Approach And Records Management Best Pract ices
properly maintained, whereas non‐
record email must be deleted in a
mely fashion in order to avoid the
costs of storing and managing
valueless data; the poten al legal
risk and reputa onal
embarrassment; as well as the legal
and IT costs in the event of legal
discovery or FOIA requests.
People are prone to dash off
informal comments in an email in a
manner they never would with a
formal le er. Less care is given to
grammar and context. A signature
is generally omi ed, so
authen ca ng an email presents
issues not associated with a
tradi onal le er with its formal
le erhead, paragraph structure
and signature block.
A big challenge with the use of
email as evidence is that email is
arguably more suscep ble to
altera on a er‐the‐fact. Most
email systems allow a person
forwarding an email to edit the
message being forwarded. This kind
of altera on would not generally
be discernible to recipients. Emails
are also more prone to a kind of
hearsay‐within‐hearsay problem:
an "email stream" or “email within
email” is created when an email
includes every email that came
before it in a discussion. It may not
be sufficient to get the most‐recent
email into evidence if that email
a aches a stream of previous
emails. All the prior a ached emails
may need to be separately
authen cated before it can be held
to be admissible.
While there are a number of
challenges to using email as
evidence, authen ca on is
arguably of most concern. The bar
set for establishing authen city is
not high under the Federal Rule of
Evidence 901. According to the 3rd
U.S. Circuit Court of Appeals, a
court need only be able to
legi mately infer that a document
is genuine to find it to be
"authen c." In the 2006 court case
of the United States v. Safavian, the
court held that detailed
authen ca on was not required
when faced with a large volume of
email.
The Capstone Answer
Confronted with these challenges
of volume, regulatory and legal
concerns, and ghter budgets, how
can government agencies address
the problem of email
management? It will certainly be a
challenge, and no one solu on will
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The Capstone Emai l Approach And Records Management Best Pract ices
be right for every organiza on and situa on. Agencies and organiza ons
will have to evaluate a number of factors and invest me in addressing the
challenges of technology and governance.
With the Administra on's imposi on of a 2016 deadline to address the
challenges of managing email, Government agencies have limited me to
solve such a big problem. In recogni on of this, the Na onal Archives and
Records Administra on (NARA) is circula ng a dra memorandum en tled,
"Guidance on a New Approach to Managing Email Records," in which NARA
proposes the "Capstone approach":
"NARA developed the Capstone approach as part of NARA's
con nuing efforts to evaluate how agencies have used email
repositories to manage email records. This approach was
developed in recogni on of the difficulty in prac cing
tradi onal records management on the overwhelming
volume of email that federal agencies produce. Capstone will
provide agencies with more workable solu ons to email
records management challenges, especially as they consider
cloud‐based solu ons. Moreover, the Capstone approach
supports the Presiden al Memorandum on Managing
Government Records and allows agencies to comply with the
requirement in OMB/NARA M‐12‐18 Managing Government
Records Direc ve to 'manage both permanent and
temporary email records in an accessible electronic format'
by December 31, 2016."
NARA developed the
Capstone approach in
recognition of the
difficulty of practicing
traditional records
management on the
overwhelming volume of
email federal agencies
produce.
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The Capstone Emai l Approach And Records Management Best Pract ices
The Capstone approach gives
agencies the op on to easily
automate email management for
permanent email records only from
"the accounts of officials at or near
the top of an agency or an
organiza onal subcomponent." The
main assump on behind this
approach is that Capstone email
accounts are for people that create
or receive presump vely
permanent email records. This
means that all email in accounts
designated as Capstone accounts
would be categorized as permanent
records. The remaining email
accounts would be considered to
have temporary records, and would
be preserved only for a period
based on the agency's need.
This approach offers the
advantages of expediency and
simplicity. The process of
submi ng records to an archive
system can be easily automated. It
ensures that all record emails are
captured. It eases the burden of
email management on end‐users
where no automated solu ons are
in place. What this approach does
not do is eliminate an agency's
responsibility to manage record
emails consistent with federal laws,
regula ons and policies (see 36 CFR
1236.20).
However, the approach raises a
number of concerns, many of
which are acknowledged by NARA.
It also fails to take into account the
capabili es of rapidly maturing
technology solu ons, which aid
email management and provide
automa c categoriza on of
content and records declara on.
The broad "dragnet" approach
taken for the capture and reten on
of Capstone accounts does not, as
NARA notes, "op mize access to
records responsive to discovery or
FOIA requests." Such an approach
could significantly increase the size
of the archive, increasing the cost
and complexity of finding
responsive emails. In addi on, non‐
record emails would be ingested
into the repository, thus increasing
the legal exposure of the agency
and its officials – a concern NARA
acknowledges. Studies have found
that even for users that would
qualify as Capstone accounts, easily
95% of their email is of a transient
nature and would be over‐retained.
All Capstone email messages will be
maintained permanently, which
increases the overall costs of
“The Capstone approach
does not optimize access
to records responsive to
discovery or FOIA
requests, and could
significantly increase the
size of the archive, and
the cost and complexity
of fulfilling requests.”
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The Capstone Emai l Approach And Records Management Best Pract ices
storage and future processing, such
as declassifica on reviews. All non‐
capstone messages will be assigned
a single temporary reten on, which
means historically important
messages may be deleted, while
redundant, obsolete or trivial
(ROT™) messages may be kept
much longer than required – again,
increasing the total cost of storage
and increasing the size of the
repository.
This approach also fails to take into
account the context, subject ma er
or a achments of a non‐capstone
email message. Records
management best prac ces would
require that the message and
associated a achments be
categorized into an appropriate
records schedule based on their
subject ma er, and not based on
medium or user level. It would
certainly not be best prac ce to
retain all paper documents
regardless of content, but based on
only the creator or recipient.
Technology‐Enhanced Email
Management
It must be acknowledged that the
most common email systems are
not designed with an eye to
content and records management.
They perform the func on of
handling email very well, but were
never designed to serve as high‐
volume, enterprise class content
repositories or records
management systems. This leaves
agencies with a choice between
making significant modifica ons to
these systems and moving those
emails that are records to an
appropriate records repository. The
earliest a empts around email
management required extra steps
by users. Within any organiza on
or agency, records management is
a responsibility of everyone, but it
is the primary job of only a few.
Most email users are concerned
with their primary jobs. Records
management adds to the users’
tasks, and is o en seen as an
intrusion into their daily work.
Capstone addresses this
shortcoming by making it easier to
automate the process, but at the
expense of accuracy and best
prac ces.
Email must be managed, not just
archived. Most studies indicate that
approximately 80% of all email is
either redundant, outdated, or
trivial. The result of a bulk‐
archiving approach without regard
to the value of the content will
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The Capstone Emai l Approach And Records Management Best Pract ices
result in exponen ally increasing
costs well into the future.
Newer products such as Integro
Email Manager (IEM) and IBM
Content Collector (ICC), combined
with auto‐categoriza on
technologies, have matured
significantly in their ability to
automate the categoriza on,
metadata capture, and declara on
of record emails. These
technologies can be deployed to
make records management
ac vi es less burdensome on end‐
users, while maintaining best‐
prac ce records management
procedures.
IEM provides proper declara on
and classifica on of email content
while automa cally disposing of
transient, non‐essen al email. IEM
is the only product in the market
that enables “auto‐classifica on
with human oversight,” delivered
via Integro’s patent‐pending
SmartAssist®. With SmartAssist,
IEM is designed to auto‐categorize
emails to the extent possible, while
providing end users with the
ul mate control in approving the
categoriza on.
IBM Content Collector for Email
collects, processes, and archives
content from Exchange, .PST files,
and Notes servers. It supports both
email and public folders along with
several archiving paradigms
including:
Journaling for compliance
Mailbox management for
storage savings
User driven mailbox archiving
for business value
Advanced PST processing
capabili es to help manage
personal archives
IBM Content Classifica on Module
can be deployed to support ICC.
The Content Classifica on Module
has natural language processing
technology that can analyze digital
content and apply a predefined
taxonomy to discover possible
categories and relevancy scores.
This process can be invoked as part
of an ICC process to:
Iden fy emails that should be
declared as records ‐ This will
ensure agency compliance with
record reten on and
disposi on policies,
automa cally analyze emails for
sensi ve data such as
personally iden fiable
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The Capstone Emai l Approach And Records Management Best Pract ices
informa on (PII), tag them with
a confiden al unclassified
informa on (CUI) marking, and
declare such emails as records ‐
without user input.
Assign a folder path and record
category ‐ This supports
archiving emails or documents
on file systems into known
folders and assigning a record
category to invoke the
appropriate disposi on
schedule.
Add metadata proper es ‐ The
metadata of the archived
emails can be populated with
the top category names and
other extracted informa on,
along with the "header"
informa on required under the
CFR.
These technologies are trainable,
meaning they can learn to
categorize email by record types.
They are ini ally trained by
compiling a corpus of iden fied
informa on and submi ng it to
the system for processing so the
technology learns to iden fy record
types. ICM so ware also has the
ability to learn from any feedback
provided to it by end users. As end
users override or suggest changes
to content categoriza ons through
their normal course of business,
the system adapts its training and
understanding in real me. The
so ware can also review items that
do not fit into the current records
file plan or category structure and
provide category sugges ons in a
clear, priori zed list.
The US Army realized the need to
properly manage email messages
as records, but also understood
that expec ng soldiers in the field
or suppor ng combat opera ons to
be knowledgeable about records
management procedures and
policies was not prac cal.
Recognizing that technology could
poten ally support these
requirements, the Army elected to
test ICC and Content Classifica on
Module to support email
management. A pilot project was
conducted using 16 offices focusing
on approximately 400 email users.
The pilot program included 314
records categories applying to
these selected offices. The pilot ran
for approximately 90 days a er
ini al training of the system. The
system was, a er real‐ me
training, able to recognize 98.4% of
emails.
In a US Army pilot
project consisting of 400
email users, IBM’s
Content Classification
Module achieved 98.4%
recognition.
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The Capstone Emai l Approach And Records Management Best Pract ices
Summary
Clearly the Capstone Procedure is a well‐considered op on for federal
agencies pushed to comply with email management requirements.
However, the procedure does not allow for the necessary "sani zing" of the
email messages so that personal, trivial or redundant messages are not
passed to a records repository.
While we concede the appeal of such a simplified approach, we believe it
does not comport with records management best prac ces while also
exposing agencies to an increase in costs and legal risk. We believe the
Capstone approach severely underes mates the long‐term costs and
poten al adverse consequences of bulk‐archiving.
We believe that technologies have now matured to the point that agencies
can take advantage of these technologies to automate the process of email
management. This will reduce the cost of long‐term storage, lower legal
risks, and decrease labor costs by significantly lowering the total me
required to review and sani ze email files, and make agencies more
responsive. Therefore, we believe agencies should consider pilot projects
for these email management technologies.
At IMC and Integro, we know how to help agencies comply with NARA
regula ons, reduce your exposure and save money. Let us show you how
we can help you solve the challenge of email management.
About IMC
For over 30 years, Informa on Management Consultants, Inc. (IMC) has been providing
proven methodologies, exper se and award‐winning technologies, services, and powerful,
flexible, and scalable ECM solu ons to leading public sector and commercial clients. IMC’s
solu ons allow clients to use informa on as a strategic asset and enable them to make
be er decisions, improve service levels, reduce risk and manage compliance.
About Integro An industry recognized product and services company, Integro specializes in solu ons for
Enterprise Content Management, Informa on Governance, Email Management,
eDiscovery, and Records Management. Integro’s email management product, Integro
Email Manager (IEM) offers value‐based archiving, which enables companies to keep the
email that is important for business, legal and regulatory obliga ons, while elimina ng the
costs and risk exposure of over‐reten on of email.
The use of automated
categorization
technologies will:
Reduce long-term costs;
Lower legal risks;
Lower labor costs;
Make agencies more
responsive.
The Capstone Approach
And Records Management
Best Practices
The Good, The Bad, and The Ugly
©2013 IMC, Inc.
Information Management Consultants, Inc.
11480 Commerce Park Drive
Reston, VA 20191
Phone: (703) 871-8700
http://www.imc.com
http://www.accessimc.com
Integro, Inc.
Phone: (303) 575-9300
www.integro.com