Okay, I’ve sat back long enough….

The situation with email losses at both IRS and EPA are both completely
plausible and don’t reflect a lack of records mgmt programs, or a grand
conspiracy, but rather, the likely possibility that the individuals whose
computers crashed weren’t following the established policies and procedures.
Policies and Procedures were in place.

Email which meet the standard of a federal record are to be retained in
a “recordkeeping system”.  That DOESN’T have to mean electronically (the
recent NARA/OMB directive will require that by the end of 2016).  The IRS
stated they had a ‘print and file’ policy for record emails.  You may think that’s
stupid or archaic, so be it, but it’s within the regulations and if you can
comply with a regulation without spending major funds you’re generally going
to be forced to take that path.  The size limit on mailboxes forced individuals
to remove email from their accounts.  The individual created an archive file to
keep electronic reference copies, but unfortunately, stored that archive on
their computer’s hard drive, which routinely are NOT backed up by network
administrators.  IRS email server backups (for disaster recovery only) are only
retained six months.  So, more than six months past the time in question you
have a pc crash, electronic copy of email gone.  Simple.  No requirement to
have that electronic copy, no law broken.  If records weren’t retained in a
recordkeeping system, in this case hard copy, now you have a problem ~ and
that’s what the IRS is looking at, and that’s the situation in which NARA has
stated the IRS did not promptly notify NARA of the loss of federal records.
I’ve read the IRS manager in question said “she didn’t know she had to keep
hard copies of records”.  I don’t know what training the IRS provided in regard
to email records, but I think we can all relate to managers who have taken
hours of required training on subjects and later swore no one ever told them
something.

From what I’ve read, the EPA situation was all too similar, the difference being
that the EPA has an electronic recordkeeping system for their email, thus
the ‘print and file’ situation of the IRS didn’t come into play, but it was still up
to an individual to declare an email as a record to be retained in the content
management system.  If they didn’t, the rest of the story is the same…. Size
limits on accounts force emails to be removed, if you wanted to keep a copy
you created an archive file, and again, it sounds as if the individual put their
archive copy on their hard drive.  Crash, no email.

We all know it’s difficult to force employees to do things they don’t want to
do, and records management falls squarely into that category.  We can
continue to train staff on their responsibilities, we can monitor the level of
activity, but do I know if a particular employee should be saving 5 emails a
day or 5 emails a month?   That’s a difficult area to monitor actual
compliance.

I understand we’re talking about ‘best practices’ not being followed, but the
reality of government IT funding and the constant requirements to provide
more services with less cost doesn’t always allow for best practices.  You and
I, the taxpayers, will not support the level of funding that would require best
practices in all areas.


Brian Devir
Cincinnati, OH
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