This page provides sample policy language options that address the retention of email and other electronic records for local governments in Washington State.
It is part of MRSC's Electronic Records Policy Tool Kit, created in partnership with the Washington State Auditor's Center for Government Innovation.
Overview
While it is theoretically possible for an agency to retain electronic records permanently, there are several reasons why that is not a good policy over the long term. Electronic records have a life cycle - comparatively few need to be retained permanently under Local Government Records Retention Schedules. Failure to follow proper retention practices will result in an ever-increasing need for storage space and make searches for responsive electronic records more time-consuming.
Below are three approaches that can be taken to address electronic records retention.
Delete Emails After 90 Days Unless Placed in Specific Folders with Pre-Assigned Retention Periods
Bellevue requires its employees and officials to determine if an email meets the definition of a public record within 90 days. If so, it needs to be placed in an appropriate email folder that is pre-assigned a particular retention period. Emails that are not placed in folders are assumed to be either non-public records or records with no retention value and are purged from the city system. Note that this policy language applies to emails only.
Save Records for Seven Years Unless Deleted or Placed in Folders with Longer Retention
Olympia has created archiving folders which are used by all staff, including a standard (minimum) seven-year retention folder, folders with longer retention period, and one folder with a permanent retention period. Emails that are deleted are placed in a 90-day journaling account where they can still be retrieved within 90 days; after 90 days, they are purged. Emails on which no action is taken are automatically transferred to the seven-year archiving folder. Note that electronic records are addressed generally in subsections (a), (b) and (c)(1) and (2); emails are addressed in subsection (c)(3).
Categorize Employees into Separate Groups and Retention Period Assigned to Each Group
Mercer Island requires that substantive city business be done by city email (as opposed to personal email or other forms of electronic communications) and requires employees to manage their email in accordance with retention requirements. It provides employee training and sets forth retention guidance in its policy.
Note that this policy option creates three separate groups of employees and officials and assigns an email retention period for each group. This approach does not directly incorporate the Washington State Local Records Committee Records Retention Schedule and may result in longer retention periods than those set forth in the State Schedules. It simplifies the retention process by assigning a retention period to agency positions instead of the subject of an email at the expense of potentially longer record retention.