On Wed, 2 Jul 2014 13:01:01 -0400, Robert Smallwood <robert@ELECTRONIC-
RECORDS-MANAGEMENT.COM> wrote:

>... Any practitioner worth their salt knows that
>personal archiving should be prohibited in the workplace, as indicated in
>Nancy Flynn's  "The e-Policy Handbook" (AMACOM, 2009).
>
I agree, Robert, it's a bad practice, and a practice that has since been
discontinued at EPA with their migration to a new email system (Lotus Notes
to Office 365).

In regard to email archiving, the storing and backup up processes were
automated, and the personal archiving done by the employee wasn't an
enterprise operation but a personal choice to create her own archive copy.
Again, I agree, this should never be allowed, but it was.  It must be
understood that even using an email archive solution, that's doesn't preclude
emails from being deleted per authorized retention schedules.  If not declared
as a record needing continuing retention, emails wouldn't be saved long term.
You don't save every email forever, even if you can.

I also agree with many of your comments regarding Capstone.  It's NARA's
attempt to get a handle on what they feel they are ultimately responsible for
~ the PERMANENT records of the government.  What is sadly lacking in
Capstone is a unified approach to the retention of non-permanent records.
Thats left up to the agencies, which puts the ball back into the court of those
that are struggling to find an acceptable approach.

And finally, I'm certainly not forgiving the IRS for losing records, and I don't
forgive a manager who says they don't know their agency's policies.  There
should be consequences, but prosecution is reserved for those who
intentionally destroy records, and that's a difficult claim to substantiate.  At
the very least, let's hope these revelations will force new processes and
practices to be established and renewed emphasis on all employees'
responsibilty in record keeping, in all federal agencies, not just those currently
under the spotlight.

No ammunition better for change than press reports or litigation!

Brian Devir
Cincinnati, OH
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