Email as a Record in a Departing Employee's Account
A program manager resigns with two weeks' notice. Her email account contains 14,000 messages, including correspondence with a regulator about an open compliance matter, contracts negotiated last year, and routine scheduling. The IT policy deletes accounts 30 days after departure. The records schedule covers 'contract files' and 'compliance correspondence' but says nothing about email as a format. The compliance team says it needs the regulator correspondence. The contracts team says the executed contracts are in the contract system, but the negotiation history is only in email. The manager's assistant asks whether to export the whole mailbox to a shared drive 'so nothing is lost.'
1. Should the whole mailbox be exported to a shared drive? Evaluate the assistant's proposal.
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Exporting the entire mailbox to a shared drive is a blunt response that creates new problems. It captures routine scheduling and personal material alongside records, it places records outside any controlled repository, and it may conflict with privacy expectations and the 30-day deletion policy. A shared-drive dump is also hard to search, hard to apply retention to, and easy to lose track of.
The better approach is to identify the record-bearing portions: regulator correspondence on the open matter and negotiation history for contracts. Those should be captured into the appropriate recordkeeping system with metadata and retention applied. The remaining messages can follow the normal account deletion process. The assistant's instinct to preserve is right, but the method should be targeted capture, not wholesale copying.
2. The schedule does not mention email. How should the manager classify the regulator correspondence?
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The manager should classify by content and function, not by format. The schedule's 'compliance correspondence' entry describes a function; email that conducts that function is compliance correspondence in email form. The absence of the word 'email' does not exclude it. The manager should map the regulator messages to the compliance correspondence series, apply that series' retention, and ensure the open matter triggers preservation.
This requires a documented classification decision so future staff can follow it, and ideally an update to the schedule or guidance clarifying that format does not change the series. The manager should also coordinate with compliance so the captured messages are usable in the matter, and should record why the routine scheduling messages were not treated as records.