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The management of correspondence in

the age of e-mail

Summary research proposal

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James Lappin
School of Business and Economics
Loughborough University
24 April 2015

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Table of Contents
1 E-mail correspondence and historical research!

2 The prevailing approach to the governance of e-mail!

3 Tensions within the prevailing approach to the governance of e-mail!

4 The Capstone policy of the National Archives and Records

Administration (NARA) of the USA!

5 The dilemma facing national archives and other archival authorities!

6 Purpose of this research!

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7 Scope of this research!

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8 Bibliography!

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1 E-mail correspondence and historical research

In his Technology Watch paper on Preserving email, Chris Prom, Archivist for the
University of Illinois, quotes Winton Solberg, a historian of higher education, as saying
historical research will be absolutely impossible in
the future unless your profession finds a way to save
email (Quoted in Prom, 2011 page 5)
This research will explore Solbergs statement. Are archivists failing to preserve
significant e-mail correspondence? If so will this failure make historical research difficult or
impossible? Do collections of e-mail within e-mail accounts have sufficient value to justify
their long term preservation? Or is a collection of e-mail within an e-mail account an
aggregation that is rendered unmanageable by the undifferentiated presence of trivial and
personally sensitive correspondence? If e-mail accounts are indeed unmanageable what
measures could be taken to avoid situations where significant correspondence only exists
inside individual e-mail accounts?
Records are multi-faceted, and have many potential users and uses. Historians are only
one of many stakeholder groups in the existence of good records. However they are
unique among stakeholder groups in the length of time that they have to wait before being
able to pass judgement on whether or not the records of the events that they are
interested in are adequate for the interpretation of those events.
Most nation states operate a twenty or thirty year gap between records being created and
being made available to the public. E-mail was invented in the 1960s but administrations
such as those of the UK and EU only started using e-mail routinely for daily
correspondence in the mid to late 1990s.
At the time of writing historians using records at the various national archives in Europe
and North America do not yet have routine access to administrative records created in the
years since the dominance of e-mail. We therefore do not yet have an empirical means of
ascertaining whether or not historians will experience a problem when they come to
research the actions and decisions of those administrations for years in which e-mail was
the dominant means of exchanging correspondence.

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2 The prevailing approach to the governance of e-mail

A typical e-mail account contains a mixture of business correspondence, trivial
correspondence and personal correspondence. The latter may contain sensitive personal
data (health information, pay and pensions information etc.) about the individual or third
parties.
Most departments/agencies/institutions in most national administrations in Europe, North
America and Australasia have adopted a policy of requiring individuals to move or copy
significant correspondence out of their e-mail accounts and into a separate records system
This policy solves the problem of trivial and personal correspondence, because
individuals are told not to save such correspondence into the records system.
However this approach has had limited success in capturing significant correspondence,
because it is heavily dependent on the motivation, workload and awareness of each
individual employee.

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3 Tensions within the prevailing approach to the

governance of e-mail
Andrew Waugh is the Senior Manager, Standards and Policy at the Public Records Office
Victoria. In a 2014 blogpost for the Australian recordkeeping rountable, he describes email as being central to accountability:
Evidence of the value of email systems as record systems can be found in any
modern governance or accountability investigation, such as a royal commission,
audit report, ombudsmans investigation, or even in investigative journalism.
Without exception, emails form the key planks of a modern investigation and
feature prominently in the final report. In 2012, the then Victorian Auditor
General and Victorias Deputy Ombudsman, independently, told a seminar of
Victorian records professionals that, while their investigators looked at the
records, the smoking gun was always in the email (Waugh, 2014)
Waugh reports that administrations typically address the challenge of managing e-mail by
a policy of requiring users to file emails into a formal record system such as an
EDRMS [electronic document and records management system]. Waugh quotes research
from Brogan (2009) as showing that the main weakness of this approach is that a
significant number of users do not file records.
E-mails that are not filed into an electronic records management system/ SharePoint
system exist in the e-mail accounts of individual end users. Waugh paints a picture of an
almost complete lack of protection for such e-mail in a typical organisation:
Users can delete any email that they send or receive at any time.
IT departments can, and do, impose disposal decisions by fiat
based on the age of the email (or the quantity a user
accumulates), and these time periods are usually absurdly short
and certainly not based on any analysis of the functions the
records support.

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If Waugh is correct that e-mail is crucial to accountability, and that policies requiring users
to file significant e-mails into formal record systems are not working, then the lack of
protection afforded to e-mail sitting within individual e-mail accounts is a source of
concern, and routine e-mail deletions could be viewed as a deletion of memory.

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4 The Capstone policy of the National Archives and

Records Administration (NARA) of the USA
In 2013 NARA issued a Bulletin in which they gave Federal Agenices the option of
selecting the e-mail accounts of senior staff for permanent preservation

An agency may designate email accounts of additional

employees as Capstone when they are in positions that are
likely to create or receive permanent email records. Following
this approach, an agency can schedule all of the email in
Capstone accounts as permanent records.(NARA, 2013 )

NARA called the new policy their Capstone policy because they hoped that the e-mail
accounts of senior staff would function like the capstone of a pyramid - all significant
decisions would at some point have to be discussed with one or more managers and
hence would leave a record within at least one senior management e-mail account.
NARAs policy change has opened up a divergence in archival practice between the US
national archives and most other national archives worldwide
NARAs policy change may help prevent the formation of a black hole in the
administrative record. But it is unclear how far it will help contemporary historians:
The policy does not provide an answer to the presence of personal data in e-mail
accounts (which means that it is unclear whether/when NARA will be able to open the
accounts for historians to access)
The policy leaves it down to individual agencies as to whether or not the agency allows
individual to delete correspondence from their e-mail account (leaving the possibility of
individuals deleting correspondence that they do not wish to be held accountable by)

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5 The dilemma facing national archives and other

archival authorities
National archives outside of the US are facing a policy dilemma. The dilemma centres
around whether or not they should seek to dissuade the departments/agencies/institutions
for which they have a remit to desist from the routine deletion of email.
If a national archive does not intervene to dissuade departments/agencies/institutions to
routinely delete e-mail in e-mail accounts then they could be seen to be implicitly
sanctioning the premature deletion of governmental correspondence
If a national archive does intervene to dissuade agencies/departments/institutions then
they face a different problem.
The standard relationship between governmental departments and national archives runs
in countries with freedom of information legislation is as follows:
Government departments/agencies/institutions hold records until shortly before they are
due to become open to the public, at which point they transfer them to the relevant
national archvies/ archival authority who open them up to the public
Departments/agencies/ institutions are responsible for answering freedom of information
requests whilst they hold the records concerned. When the records are transferred to
the national archives the become open to the public at which point the authority no
longer needs to research answers to freedom of information requests because the
information is in the public domain
If a national archive adopts a Capstone approach to selecting key e-mail accounts for
permanent preservation then
either they or the deperatment/agency/institutions will bear the cost of sensitivity
reviewing the e-mail account to prevent personal data, or data with other sensitivities,
being released to the public OR

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the archive will have to extend the closure period for such e-mail accounts, preventing
researchers from accessing them, and giving the archives the cost of answering freedom
of information enquiries on the correspondence in the e-mail account
The time required for human beings to sensitivity review e-mail accounts is likely to be
exponentially greater than the time required for human beings to sensitivity review files in
filing systems (whether paper or electronic). In filing systems the subject or theme of the
file usually gives a reasonable indication of the sensitivity of all the documents within it.
The legislative framework does not provide an easy way out of this dilemma:
most European, North American and Australasian countries have records legislation that
prevents the premature destruction of government correspondence. Such legislation
could be interpreted as forbidding the routine deletion of significant e-mail accounts
Data Protection legislation in the European Union requires that personal data is held no
longer than necessary. Such legislation could be interpreted as forbidding the
permanent retention of sensitive personal data in e-mail accounts.

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6 Purpose of this research

The purpose of this research is to provide evidence to help national archives and other
archival authorities determine their policy in relation to the issue of:
whether or not to require/encourage the permanent preservation of significant e-mail
accounts
whether or not to forbid/discourage the routine deletion of e-mail from significant e-mail
accounts
It will also assess whether there is a way out of this dilemma:
Is there any means by which a department/agency/institute could manage incoming and
outgoing correspondence in such a way that avoids having significant e-mail, personal email and trivial e-mail building up in an undifferentiated manner within individual e-mail
accounts OR
Is there any reliable means by which a department/agency/institution could use
technology to differentiate between significant, trivial and personal communications
within an e-mail account?

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7 Scope of this research

The research will seek to answer these questions by:
evaluating the way e-mail has been managed within the UK Government
evaluating the progress made in the application of the Capstone policy in the US
evaluating the management of e-mail within a third national or pan-national
administration (to be selected)
evaluating existing and potential approaches to the management of e-mail in the light of
archival and records management theory
evaluating existing and potential approaches to e-mail suggested by the information
governance perspective, or from a big data perspective
evaluating product offerings from the vendor market and their potential application to the
challenges posed by e-mail
evaluating actual or possible configurations/customisations and adaptions to e-mail
made by organisations

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8 Bibliography
NARA, 2013. Guidance on a New Approach to Managing Email Records NARA Bulletin
2013-02. NARA website, available from http://www.archives.gov/records-mgmt/bulletins/
2013/2013-02.html [accessed 23 April 2015]
Prom, Christopher J. Preserving Email, DPC Technology Watch Report 1-01 December
2011, available from http://www.dpconline.org/component/docman/doc_download/739dpctw11-01pdf
Waugh, Andrew, 30 June 2014. Email - a bellwether records system. Recordkeeping
Roundtable blog (www,rkroundtable,org). Available at http://rkroundtable.org/2014/06/30/
email-a-bellwether-records-system/#_edn2 [accessed 22 April 2015]
Brogan, Mark, May 2009 Clipping Mercurys Wings: The Challenge of Email Archiving,
Archives and Manuscripts, Vol 37 No 1,, pp13-26