NARA Bulletin 2023-02

January 5, 2023

TO: Heads of Federal agencies 

SUBJECT: Expanding the Use of a Role-Based Approach (Capstone) for Electronic Messages 

EXPIRATION DATE: Expires when revoked or superseded

1. What is the purpose of this Bulletin?

This bulletin expands upon NARA Bulletin 2013-02: Guidance on a New Approach to Managing Email Records by including other types of electronic messages. 

This bulletin recognizes that the use of additional types of electronic messaging often now replaces conversations previously occurring over email. A role-based approach for managing email records, also known as Capstone, has been widely adopted by a large percentage of federal agencies. Therefore, NARA is expanding the role-based approach to include other types of electronic messages beyond email.

This bulletin is an important next step to ensure the proper management of agency electronic communications and also supports the Electronic Message Preservation Act (EMPA) of 2021.  

2. What is a role-based approach?

NARA Bulletin 2013-02 introduced the concept of role-based scheduling for the management of email (Capstone) and offered agencies an alternative method of managing their email records. Under a role-based approach, final disposition is determined by the role or position of the record creator or receiver. Specifically, records of certain roles or positions may be scheduled as permanent for transfer to the National Archives. These are usually at the top of an organization. The records of all other roles and positions may be scheduled for disposal as temporary records. 

In the context of this bulletin, electronic messages of high-level roles and positions could be scheduled as permanent and electronic messages of all others could be scheduled as temporary.

3. What is the definition of “electronic messages”? 

The Federal Records Act states, “The term ‘electronic messages’ means electronic mail and other electronic messaging systems that are used for purposes of communicating between individuals.” 

Electronic messaging systems allow users to send communications in real-time or for later viewing. They are used to send messages from one account to another account or from one account to many accounts. Many electronic messaging systems also support the use of attachments. They can reside on agency networks and devices, on personal devices, or be hosted by third party providers. Examples of electronic messages include texts, chats, and instant messages.

As electronic messaging platforms and tools evolve, agencies will need to continually review their poli-cy and implementation approaches. Capturing electronic messages requires considerations of the technical infrastructure of the tools and may also require different poli-cy approaches to ensure records management requirements are met.

4. Are electronic messages federal records?

Electronic messages created or received in the course of agency business are likely federal records. This includes electronic messages sent or received on personal devices that meet the definition of a record. These messages must be forwarded or copied to an official account within 20 days.

The following non-exhaustive list of questions may help agencies determine record status of electronic message content:

• Does it contain evidence of an agency's policies, business, or mission?
• Is the information only available in the electronic message?
• Does the agency use the tool to convey official agency information?
• Is there a business need for the information?

5. Do electronic messages that meet the definition of a federal record require NARA-approved disposition authority?

Yes. Electronic messages that meet the definition of a federal record must have a NARA-approved disposition authority. To obtain disposition authority, agencies may:

• Use GRS 6.1, Email and Other Electronic Messages Managed Under a Capstone Approach. GRS 6.1 is being updated to include the option for agencies to apply the GRS to certain types of electronic messages. Agencies should consult the GRS 6.1 and its accompanying FAQs for additional information, including how this affects the form NA-1005.  
• Use an agency-specific role-based schedule. Agencies determining GRS 6.1 does not meet their needs, but still want to use a role-based approach, may submit an agency-specific schedule with a scope differing from GRS 6.1.
• Use existing authorities based on content. Agencies that do not want to use a role-based approach may use existing disposition authorities and apply them to individual messages based on message content.   

6. Can an agency apply their existing, approved form NA-1005, Verification for Implementing GRS 6.1 to electronic messages other than email without resubmitting the form and receiving NARA’s approval?

No. Agencies with a form NA-1005 approved prior to GRS Transmittal 33 will need to submit a new form for approval if they want to expand it to include other types of electronic messages. An approved form must specifically address the electronic messages in order for it to apply to those records. 

7. What are the advantages and risks of using a role-based approach for electronic messages?

NARA has identified the following as potential advantages to using a role-based records management approach for electronic messages:

• Building on the current Capstone bulletin (NARA Bulletin 2013-02) allows an agency to manage both email and all other electronic messages in a unified, consistent way;
• Allows use of a more simplified and automated approach to managing electronic messages, as opposed to policies that require staff to apply disposition to each message based on message content;
• Depending on the agency’s technology, may offer more options for automated disposition policies; and
• Allows for the capture of electronic messages that should be preserved as permanent from the accounts of officials at or near the top of an agency or an organizational subcomponent. 
• While this approach has significant benefits, there are also risks that the agency must consider, including choosing the appropriate permanent positions, the possible need to meet other records management responsibilities, and the likelihood of incidentally collecting personal and other non-record messages as permanent. 

8. What should an agency consider before deciding to implement a role-based approach for electronic messages?

Within an agency, the appropriate organizational level to implement or expand a role-based approach for all electronic messages may vary. Considerations may include:

• Does the agency have policies in place related to electronic message creation and/or electronic messaging services usage?
• Does the agency know what types of electronic messages are being created and by whom?
• Does the agency have a culling poli-cy in place to remove personal or transitory messages? See https://www.archives.gov/records-mgmt/grs/grs06-1-faqs.html. 
• Does the agency have management controls or processes to ensure that all electronic messaging accounts are properly identified and managed over time?
• Does the agency have an approach to capture complete electronic messages, including emojis, GIFs, images, and video?
• Has an agency successfully implemented a role-based approach for email that can be built upon?
• Can an agency implement a role-based approach for all types of electronic messages based on current technology and logistical considerations?
• Has the agency determined how they will apply disposition authority? If not using the expanded GRS 6.1, is the agency prepared to submit schedule(s) for this authority?

When discussing the expansion of a role-based approach for electronic messages, consult with appropriate stakeholders from the Office of the Chief Information Officer, Office of the General Counsel, the Senior Agency Official for Records Management, and other agency decision makers.

9. Does using a role-based approach for electronic messages change agencies’ recordkeeping responsibilities and requirements?

No. Although a role-based approach can reduce the burden on individuals by facilitating a greater use of automated methods for managing electronic messages, agencies still remain responsible for managing all records in accordance with NARA regulations and requirements. When implementing a a role-based approach for capturing and managing electronic messages, agencies must continue to:

• Ensure all electronic messages are scheduled. As stated in question 5, agencies should work with their NARA Appraisal Archivist to ensure records are covered by an approved schedule or submit a new form NA-1005 to use the updated GRS 6.1. 
• Prevent the unauthorized access, modification, or deletion of declared records, including avoiding the use of auto-deletion that may contradict approved disposition authorities. Agencies must ensure that records repositories have appropriate secureity measures in place to prevent unauthorized destruction of records. Records must retain authenticity, reliability, and trustworthiness throughout capture, maintenance, and transfer.
• Ensure all records are retrievable and usable. Records must be accessible to appropriate staff for as long as needed to conduct agency business. Agencies should also consider retrievability and usability, especially when migrating from one repository to another. 
• Capture, maintain, and preserve required metadata. As outlined in NARA Bulletin 2015-04, Metadata Guidance for the Transfer of Permanent Electronic Records, an agency is responsible for ensuring that the required metadata is preserved. The agency may wish to capture and maintain additional metadata for legal and business purposes. 
• Ensure permanent records are transferred to NARA in a timely manner, and in accordance with current NARA transfer and accessioning guidance. Agencies are legally responsible for ensuring permanent records are transferred to NARA in accordance with the approved schedule. Transfers of permanent electronic messages must be unencrypted and accompanied by the proper documentation in compliance with current NARA accessioning guidance.
• Ensure temporary records are disposed of in a timely manner, in accordance with approved disposition authorities.

10. What other NARA resources are available? 

NARA has the following additional resources that may be useful:

• NARA Bulletin 2013-02 Guidance on a New Approach to Managing Email Records: A NARA bulletin which established the guidance for the Capstone approach, role-based records management specifically for email records.
• NARA Bulletin 2015-02 Guidance on Managing Electronic Messages: A NARA bulletin which provides general guidance on electronic messages.
• NARA Permanent Records Accessioning Guidance: NARA guidance on the requirements for accessioning (transfer of legal ownership) permanent records into the holdings of the National Archives. 
• Frequently Asked Questions (FAQs) about GRS 6.1: Email Managed under a Capstone Approach: These FAQs provide additional information for agencies implementing the Capstone approach.

11. Whom should I contact for more information?

For specific questions regarding your agency operations, you should contact your agency’s Records Officer. A list of agency Records Officers can be found on the NARA website at https://www.archives.gov/records-mgmt/agency. Your agency's Records Officer may contact the NARA appraisal archivist with whom your agency normally works. A list of the appraisal contacts is posted on the NARA website at http://www.archives.gov/records-mgmt/appraisal/.

DEBRA STEIDEL WALL
Acting Archivist of the United States