What is the cost of treating every email as a record?

What are the cost implications of managing every email inside your organisation as a record? The question, posed in a Linkedin forum by ECM consultant Dean Fisk, resulted in one of the most vigorous on long-running discussions to appear in the social networking forum.

Specifically, Fisk asked “What are PROS and CONS of managing non-records, as well as records, using the corporate records management application?”

He referred to the example of an organisation that is implementing a records management solution for email, one that does not have another application that manages the retention of non-records and “want to just create some "big buckets" in RM with short retention periods.”

“What is the overhead cost for managing a record?” asked Fisk.

Responses came from across the globe, showing a distinct philosophical divide between those happy to treat everything as a record and those who warned that way leads to madness.

One of the first to respond was New York-based ECM consultant David Champeau who considers all information has a lifecycle so everything can be considered a "record".

“The lifecycle of some content may be very short. Another question is "what is the cost of not managing it?" it will be discoverable, storage will continue to grow, etc,” he posted.

Dean Fisk responded “I fully support managing it ... just trying to determine the additional overhead of managing it as a "record" versus using another retention tool. e.g. since it is email, setting rules to delete after 90 days.

“It seems obvious that it would cost more to store the email in a repository, declare it as a record (perhaps in another repository) and then go through a record lifecycle process to review and eventually dispose of something that has little business value. I am looking for some "real cost" estimates.”

Although Robert Sandusky, Records Manager at New York-based Fulton Financial Corporation, asked, “If they only want to keep emails 90 days why bother moving them off the email system? Talk about a useless cost. Furthermore that may not be a successful tactic as an email may be a "record" depending on its content and '90 days and gone' may put them in a lot of hot water.

“If they are talking about moving those emails that are "records" off the email system what about metadata? Can that be moved too and can you prove that you have security in place to prove the record is "faithful" to the original. Without the metadata it is legally useless.

“CON if you can have a record but can't prove it's legal viability you might as well not have it.

“PRO for managing "non-records" is if the RM is any good they might be surprised to find out how many "non-records" are actually records. All information should be managed, if it isn't you lose control of related expenses and you may even lose vital information.

“As to overhead, the time it takes to setup and manage the new "buckets" is your overhead and that cost is highly variable and unique to an organisation so there is no general answer to that. Without knowing the system capabilities it is impossible to know how much time it will take to setup and manage the new buckets or even if it is doable. You also have to include the all of five seconds it is going to take for the user to move the item to the bucket.”

Consultant Charmaine Brooks pointed out there are costs associated with where users place those non-records if they are not in the system, which must be factored in.

“Buckets are an easy way to manage content in a system, but a more effective way is a Functional Classification or File Plan mapped to records retention schedules. Then employees file the record by the context of the record or non-record and then they can be managed,” said Brooks.

“Users can determine that the document is Administrative versus a Contract and place it in the right category. One of the problems with Buckets is the user has to decide if it is a 90 day, three year or ten year record. With a classification scheme they just indicate the class of record based on the business activity.
“Not including "non-records" in an information system just means "someone" will need to go back and clean them up at a later date, which rarely happens. Hence the large stores of unstructured records in organisations.

“This is the main area that my clients are addressing. If you can identify and categorise the content, you can manage it.”

Paula Smith, a consultant with Techtonics NZ, takes the view that  just because something has a 'lifecycle' does not mean that it’s therefore automatically a record.

“Having said that in some cases the definition is an academic one as all information needs to be managed in order that the wheat can be sorted from the chaff.

“Information is the lifeblood of any organisation whether it’s a formal record or an interesting piece of information that helps put you on a path.

“That is why the sensible organisations and vendors are looking at Content Management not records or document management, restricting the behaviours to only 'records' does not achieve the ultimate aim and you are reliant on users "declaring" items as records which can be problematic in itself.”

So should users be given the right to decide the value of an email? Consultant Julia Kuksin believes it is the right approach.

“I think users might be given the right to decide about the value of an e-mail. If it has valuable information, it is moved to the records management system, indexed, classified, becomes a "record" and falls into one of existing record types. If not it is just kept on the mail server, which is regularly cleaned of anything older than 90 days.The cost of maintaining the mail server is relatively low under condition that it is regularly cleaned. Of course, the organisation records management policy should be adjusted accordingly.”

Others disagree.

“Personally I do not like the "let the user decide" approach as they will declare virtually everything since the definition of a record is vague,” wrote consultant David Champeau.

Stephen Clarke, Principal Advisor, Information Management at New Zealand’s Inland Revenue department, is grateful for the fact that legislation in his country states that any information created or received in the course of business" is a record.

“Therefore we don't have to make these meaningless (and frankly nonsensical) distinctions between records and "non-records". You manage all content as if it is a record, you are basically covered, and if  it turns out not to be a record, well no big deal.

“Even in jurisdictions like the US, these debates about "is it a record?", "has it been declared?', etc. are broadly meaningless, as if it is discoverable it is a record from a legal perspective, so all these fine-grained distinctions are rendered pointless anyway.

“I'm also amazed by the prescience of all these records manages who know well in advance whether any given piece of content is going to be a record or not so they can decide if they should manage it or not! They should be living off their lottery winnings not agonising about "recordness."

According to Robert Sandusky, “Legally (in private industry) there is a significant difference so everything is not a record. Records laws in the US are based on content, so if the content is regulated you must keep that in whatever form it is created.

“Everything else you can treat as you please. So let us take emails for example; those with regulated content must be kept the mandated (minimum) time period, those that aren't can be deleted tomorrow, and as long as you do it consistently within your defined policy, there are no ramifications to not having the data.

“Now is that a smart approach, of course not you have business needs for information above and beyond the strictly legal. However once you start to treat items as an "official" record with in your corporate structure you attach legal obligations to the maintenance of that information that did not exist before.

“Remember while information is a valuable tool it can also be used as a weapon against you and your corporation (and also in America you can get a grand jury to indict a ham sandwich and jury to award a woman damages because she put the coffee between her legs while driving and it is the server's fault the coffee is hot).

“Legally deleting information according to your policies is a valid defence in court, the second you treat everything as a "record" is the same moment you hand anybody who wants to attack you (government, disgruntled employee, etc.) another arrow in the quiver.

“Information is valuable, it can also be dangerous.”

In the end, Robert Fisk did not get the answer he was looking for, in terms of a real cost estimate of managing email in a records management application. Although the discussion continues on the Electronic Documents and Records Management Professionals Group at linkedin.com.