Comment Re:Preservation rule question (Score 1) 371
The statute and regulations specifically made her responsible for assuring that the policies were implemented. This has nothing to do with the technician, IT or anything or anyone else.
Where did I get that copying and forwarding emails is specifically disallowed?
Previously quoted text from the document:
NARA regulations codified in 2009 also specified that agencies must not use an electronic mail system to store the recordkeeping copy of electronic mail messages identified as Federal records unless that system contains specific features.
The system used by State does not contain those features. Therefore, the use of an email system to store the records is specifically disallowed.
Secondly, the forwarding that is allowed is only in conjunction with forwarding to the official email account of the employee (not other employees) when the Capstone system is being used.
From the linked document:
In 2004, NARA issued a bulletin noting that officials and employees "must know how to ensure that records are incorporated into files or electronic recordkeeping systems, especially records that were generated electronically on personal computers."
There were three recordkeeping systems that were an option for emails. Copying and forwarding is not one of them. Therefore, copying and forwarding are specifically prohibited.
Here's more from the linked document:
Since 1995, the FAM has instructed employees, "until technology allowing archival capabilities for long-term electronic storage and retrieval of E-mail messages is available and installed," emails warranting preservation as records must be printed out and filed with related Department records.
In no case is it considered preservation of records to copy or forward an email to another employee of the Department.
From the document, again:
In 2009, IRM introduced SMART throughout the Department, enabling employees to preserve a record copy of emails through their Department email accounts without having to print and file them. However, the Office of the Secretary elected not to use SMART to preserve emails, in part because of concerns that the system would allow overly broad access to sensitive materials. As a result, printing and filing remained the only option by which emails could properly be preserved within the Office of the Secretary in full compliance with existing FAM guidance.
You seem to be hung up on how you would technically implement a search system to find emails rather than on what the National Archives under the Federal Recordkeeping act requires of all federal employees. Secretary Clinton was specifically charged with assuring compliance within the Department of State. Maybe her failure to assure compliance is the reason State is being ripped apart in the courts in their active FOIA lawsuits. The IG's report doesn't blame technicians or miscommunication between management and IT; it blames the Secretary and her staff for doing things they were prohibited from doing and failing to do things they were required to do under statute.