Catalog of Sample Policies for Pennsylvania's Conservation Districts

Policy on the Retention & Disposition of Records Created on Electronic Mail Systems
(PSATS)

Purpose:
Establish and clarify records management policy for local governments with respect to the retention and disposition of records created on electronic mail (e-mail) systems.

Scope:
Applies to local governments subject to the Municipal Records Act.

Objectives:

• Integrate records on e-mail systems into the Municipal Records Schedule issued by the Local Government Records Committee.
• Provide information needed by local governments to determine properly the disposition of records created on e-mail systems.
• Ensure that records created on e-mail systems will be accessible in conformance with records retention and disposition schedules and procedures approved by the Local Government Records Committee.

Definitions:

• Electronic - Relating to technology having electrical, digital, magnetic, wireless, optical, electromagnetic or similar capabilities.
• Electronic Record - A record created, generated, sent, communicated, received, or stored by electronic means.
• Electronic Mail (e-mail) System - A system that enables users to compose, transmit, receive and manage text and/or graphic electronic messages and images across local area networks and through gateways connecting other networks. This information consists primarily of messages, but may include attachments such as calendars, directories, distribution lists, word processing documents, spreadsheets, and other electronic documents.
• Receipt Data - Information in e-mail systems regarding date and time of receipt of a message, and/or acknowledgment of receipt or access by addressee(s).
• Record - Any recorded information, regardless of physical form or characteristics, that documents a transaction or activity that is created, received or retained in pursuance of law or in connection with the transaction of official business.
• Record-keeping System - A system (manual or electronic) for organizing and identifying records to speed their retrieval, use and disposition and to provide adequate documentation of the local government's functions and business transactions.
• Record Series - A group of records that may be treated as a unit for purposes of classification, designation, description, management, or disposition because they relate to a particular subject or function, result from the same activity, have a particular physical form, or because of some other relationship arising out of their creation, receipt, or use.
• Records Retention and Disposition Schedule - A comprehensive statement approved by the applicable approving authority showing retention periods and all actions to be taken with respect to the disposition of records.
• Transmission Data - Information in e-mail systems regarding the identities of sender and addressee(s), and the date and time messages were sent.

Policy:

• E-mail messages and attachments that meet the definition of records shall be disposed of in accordance with applicable law and records retention and disposition schedules approved by the Local Government Records Committee. E-mail messages and attachments that do not meet the definition of records should be deleted immediately.
• E-mail messages, in and of themselves, are not a single record series. Retention and disposition of e-mail messages depends on the function and content of the individual message.
• Records created in e-mail systems must be retrievable and available for the retention period listed on a records retention schedule approved by the Local Government Records Committee.
• Records may be deleted from an e-mail system if their required retention period has expired or after they have been copied to a record-keeping system. Records may be maintained on a manual or electronic record-keeping system. Records shall include transmission or receipt data.
• When duplicate copies of e-mail messages are sent internally, the sender should be responsible for maintaining the primary copy for the full applicable retention period.
• All other copies should be disposed of in accordance with approved records retention schedules relating to transitory messages.

Responsibilities:
If local governments maintain e-mail systems to transact government business:

• Local governments shall retain and dispose of records created in e-mail systems in accordance with the procedures in this policy.
• Local governments shall ensure that employees are familiar with and comply with the requirements for creation, maintenance, and disposition of records in e-mail systems.

Procedures:

• Local governments shall establish standards/procedures to manage the storage of records on e-mail and shall not rely on e-mail server backup procedures to manage the retention and disposition of records created in e-mail systems.
• E-mail messages shall be systematically filed for retrieval following standardized filing rules within the local government. E-mail messages shall be indexed in an organized and consistent pattern, and reflect the way the files will be used and referenced.
• Local governments that do not have the technical capability to manage e-mail messages for the full retention period in an electronic format shall create an analog copy (paper or microfilm). Local governments with computer systems capable of maintaining e-mail messages in an electronic format for the required retention period may also decide that current requirements are best served by printing electronic messages to paper or microfilm. In addition to the content, the following information shall be retained about each message: name of sender, name of recipient, date and time of transmission and/or receipt. Records printed from e-mail systems shall be filed in accordance with standard office procedures.
• All records, whether stored in paper or similar format or in an electronic records system, must be retrievable and available for the retention period listed on a records retention and disposition schedule approved by the Local Government Records Committee.
• E-mail messages eligible for destruction shall be disposed of in an manner that ensures protection of any sensitive, proprietary or confidential information.