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COUNCIL ITEM OF SPECIAL INTEREST: EMAIL RETENTION
Staff Contact and Presenter: Julie K. Bower, City Clerk
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Purpose and Recommended Action
Recommendation [enter the recommendation here]
This item is follow up to a Council item of Special Interest (CIOSI) by Councilmember Turner and Vice Mayor Hugh related to length of retention for the City’s email.
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Background
At the September 6, 2016 City Council Workshop, Councilmember Turner, with support from Vice Mayor Hugh, requested the City Clerk review the retention policy for emails and other documents and bring the information forward for Council to review. Staff determined there were three phases to the project:
• Phase 1 - Collect, review and analyze state and national data regarding email retention. Investigate and determine if there are agencies that provide standards and recognition for organizational transparency. Analyze electronic document management systems (EDMS) which would efficiently manage email based on its content. Analyze the cost of storage if the length of retention is increased and the cost of a possible EDMS.
• Phase 2 - Implement an EDMS that would assist staff with the storage and retrieval of important email communications as well as all other City documents.
• Phase 3 - Develop and provide training to City staff regarding how to determine if email messages are subject to longer retention and provide training in the use of the EDMS.
At its December 20, 2016 Workshop, Council provided staff with direction to proceed with Phase 1 of the email retention project.
Analysis
Survey Results
The Clerk’s Office surveyed 15 states and 17 cities and towns. The survey found that email records were not treated differently than other records and it was the content of the email that determined the length of retention.
The retention of email on email servers varied greatly. Email was retained for periods as short as 30 days and as long as 3 years, for an average retention of 325 days. Two cities used a separate archiving product and only IT personnel could access the records once the email was archived.
In Arizona, A.R.S. 41.151, states that all public records are property of the state and gives the director of the state library the authority to establish retention schedules. The retention period for an electronic communications record depends upon the content and intent of that communication.
For example, the retention for constituent correspondence is two years. If the email is classified as general correspondence, it is retained until the administrative or reference value has been served. The majority of email correspondence would be considered general correspondence, meaning that once the email has been read, its value has been served and it can be deleted.
The Clerk’s Office was unable to identify any agencies that provide standards and recognition for organizational transparency.
Email System
The email system is a communication tool not a document management system. The system receives an average of 1,046,679 emails per month. If a public records request (PRR) is received that may require the entire email repository of over 12 million documents to be searched, it can present difficulties.
The system cannot handle searching all or a large portion of the repository at once, so the IT Department has to break the search up into smaller pieces. Once IT has completed the PRR search, the records that are found are forwarded to the Clerk’s Office for review. A staff member must review each record, remove non-pertinent records and redact sensitive information. It can be a very lengthy process.
Current Policies
The City does provide guidance and policies for its employees regarding the management of email. Every employee has the responsibility to actively manage email, sent or received, based on the content of the email. Each department also has a designated records control officer who is responsible for maintaining the department’s records in accordance with applicable retention schedules.
Possible Solutions
The current policy, ITPY-150.04, establishes a storage period for email on the email server of 365 days. In December 2016, in order to allow time to study the issue, that storage period was increased to two years.
A possible solution would be to make the increased storage period permanent. It should be noted that a longer email server retention period will exacerbate the problems encountered when conducting the PRR searches and does not relieve the user from the responsibility of determining the appropriate length of retention for each email record.
An alternate solution would be to invest in an electronic document management system (EDMS). In addition to allowing users to import emails into the system with one click and build in retention based on the record type, the EDMS also provides document imaging, document management, a workflow system and records management functionality. It would be used by departments throughout the organization. It would allow the consolidation of all public documents - minutes, ordinances, contracts, etc. - on the City’s website and provide a public portal where citizens could search for all of the documents in one location.
Any solution should also include updating the email policy and developing ongoing employee training that addresses how to assess the content and intent of email and apply the appropriate retention schedule.
Community Benefit/Public Involvement
The EDMS will provide greater transparency to the public with regard to public records. Records will be consolidated in one place on the website and search capabilities will be greatly improved. Currently, the public has to look in different locations on the website to retrieve information on contracts, minutes, ordinances, etc. The EDMS will provide a public portal where citizens can search for all of the documents in one location. The entire document will be searchable instead of just the document title, which is the case now.
Budget and Financial Impacts
The Clerk’s Office will be including a request for funding of an EDMS in the FY17-18 budget in the amount of $380,000. This includes one-time costs of $313,000 for software, professional services, conversion of 3.5 million records and annual costs of $67,000 for maintenance, hosting and cloud storage.