Email and Information Technology (IT) Device Data Retention Policy

Purpose

This policy provides guidance for implementing and managing the records retention of General Services Administration’s (GSA) email messages, attachments, and IT device data as required by OMB M-19-21, Transition to Electronic Records, and the Federal Records Act, as amended.

Background

1. OMB M-19-21, Transition to Electronic Records provided that “Federal agencies have been required to manage all (permanent and temporary) email records in an electronic format since 2016 and are expected to continue to do so.”
2. On January 5, 2023, NARA Bulletin 2023-02 expanded its existing guidance on retaining the emails of High-Level Officials (known as Capstone officials) to similarly apply to other types of electronic messages for preservation. For recordkeeping purposes, GSA has two categories of email records scheduled with the National Archives and Records Administration (NARA) based on the role of the email account user. The schedule was originally submitted to NARA in November 2016.
3. GSA complies with the Federal Records Act by ensuring all agency records are preserved according to agency records schedules. In some cases, this may mean records are preserved in more than one place. The role-based capture of emails does not eliminate the requirement that employees with their individual GSA email accounts maintain complete recordkeeping files in their appropriate, subject, case or project file.
4. This Order provides guidance on how determinations are made regarding the retention and management of email and IT device data.
5. IT devices include but are not limited to GSA-furnished computer workstations, laptops, and mobile devices such as cell phones and tablets. IT device data include electronic records, files, and texts stored on IT devices.

Applicability

1. This Order applies to all GSA employees, political appointees, contractors, and other individuals who possess a GSA IT device(s) and/or a GSA-supported email account.
2. The Office of Inspector General (OIG) is exempt from this Order. The OIG has set up its own email records management policy, using the same GSA records schedule for its email system.
3. This Order applies to the Civilian Board of Contract Appeals (CBCA) only to the extent that the CBCA determines it is consistent with the CBCA’s independent authority under the Contract Disputes Act.
4. This Order does not supersede any elements of GSA Directive CIO 1820.2 Records Management Program. This Order does not eliminate the requirement that employees maintain complete recordkeeping files with the inclusion of records created or received in email.

Cancellation

This Order cancels and supersedes CIO 1828.2 Email Retention Policy, dated October 27, 2021.

Summary of Changes

This order provides for consistency with Federal requirements and program implementation changes. This order:

1. Expands the management and retention of records to IT device data
2. Updates outdated references and links

Roles and Responsibilities

The Office of GSA IT is responsible for:

1. Retrieval, storage, and management of email and IT device data in accordance with this order and GSA records retention schedule.

The Office of General Counsel (OGC) is responsible for:

1. Coordinating with GSA IT, records officers, and OHRM to implement the preservation of departing employee information that is subject to a litigation hold.
2. Ensuring that any materials of departing employees are preserved in a manner which identifies the matter, specific litigation hold, and the individual (custodian) who was the source.
3. Communicating and issuing litigation hold notices and releases to all parties involved.