U.S. Department of the Treasury

DATE: January 17, 2017

SUBJECT: Department of the Treasury Email Management

1. PURPOSE. This Directive establishes policy and assigns responsibilities for managing email messages within the Department of the Treasury. It also authorizes the release of Treasury Directive Publication (TD P) 80-07, “Email Management.”
2. SCOPE. This Directive applies to all bureaus, offices, and organizations in the Department of the Treasury, including the Offices of Inspectors General within the Department. The provisions of this Directive shall not be construed to interfere with or impede the authorities or independence of the Treasury Inspector General, the Treasury Inspector General for Tax Administration, or the Special Inspector General for TARP.
3. BACKGROUND. Federal agencies are required to manage their email records in accordance with the Federal Records Act and related regulations. Office of Management and Budget (OMB) guidance requires agencies to manage email records, both permanent and temporary, in an accessible electronic format by December 31, 2016. In support of these requirements, the National Archives and Records Administration (NARA) introduced the Capstone approach to email management, which allows federal agencies to categorize and schedule email records based on the work and/or position of the account holder. The Department has determined that the Capstone approach offers a more simplified and automated approach to managing email, as opposed to using “print-and-file” systems or records management applications that require personnel to file email records individually, while appropriately preserving historically significant email records.
4. POLICY. It is the policy of the Department of the Treasury to manage email messages pursuant to the Capstone approach. Under this policy, Treasury will:
   1. manage all email messages electronically, in a manner that complies with applicable law, policy, and OMB and NARA guidance;
   2. manage email messages based upon the account holder’s position in the Department of the Treasury, rather than the specific content of individual email messages;
   3. designate email messages of specific account holders (“Capstone officials”) as permanent records;
   4. preserve email messages that are designated as permanent records for transfer to NARA in approved format and in accordance with federal regulations;
   5. manage email messages of account holders who are not Capstone officials as temporary records, to be preserved in accordance with approved records retention and disposition policies; and
   6. grant responsible bureau officials discretion to determine how to implement policies compliant with the NARA Capstone approach, this Directive, and TD P 80-07, and designate bureau-specific Capstone officials if they receive approval from NARA and the agency Senior Agency Official for records management.
5. DEFINTIONS.
   1. Capstone – An email management approach under which email messages are managed and preserved based upon the account holder’s position, rather than the specific content of individual email messages.
   2. Electronic Mail (Email) Message - A message created or received on an electronic mail system, including any attachments (such as word processing and other electronic documents transmitted with the message), and calendar items that are generated as a commonly available function of the electronic mail system.
   3. Account - Any Departmental account that sends or receives email.
   4. Capstone officials – Departmental personnel occupying the positions identified in NARA General Records Schedule 6.1 (Email Managed under a Capstone Approach) or their bureau equivalent. The list of Departmental Offices Capstone officials will be provided in TD P 80-07, and updated as appropriate.
   5. Records
      1. 1) Email Record – An email message that is:
         • Sent from, or received by a Treasury email system (including, but not limited to email messages, calendar items, and attachments);
         • Created or received under federal law or in connection with the transaction of public business; and
         • Preserved or appropriate for preservation as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the United States Government or because of the informational value of data in them.
      2. 2) Email Non-Record – An email message that does not meet the definition of an email record.
6. RESPONSIBILITIES.
   1. The Assistant Secretary for Management, acting in his or her capacity as the Senior Agency Official (SAO) for the Department-wide records management program, and under the authority of OMB Memorandum M-12-18 (Managing Government Records Directive), will:
      1. 1) guide agency practices, personnel, and funding as necessary to ensure compliance with applicable records management statutes, regulations, NARA policy, and OMB guidance as they pertain to email records;
      2. 2) coordinate with the Deputy Assistant Secretary for Privacy, Transparency, and Records and appropriate Department officials to ensure the Department’s compliance with the above authorities; and
      3. 3) review and approve submissions to NARA that relate to the Department’s implementation of the Capstone approach and require the SAO’s signature.
   2. The Deputy Assistant Secretary for Privacy, Transparency, and Records (DASPTR) will:
      1. 1) lead the development and implementation of email management procedures in accordance with this Directive and other applicable Treasury, OMB, and NARA guidance;
      2. 2) provide guidance to the Chief Human Capital Officer on the identification and designation of specific Capstone officials, consistent with this Directive and NARA requirements;
      3. 3) create and maintain a list of current and former Departmental Offices officials, employees, and contractors who should be designated as Capstone officials pursuant to this Directive and NARA requirements;
      4. 4) support Treasury bureaus in Capstone implementation, including the identification and designation of Capstone officials, consistent with this Directive and NARA requirements;
      5. 5) establish and/or modify retention and disposition schedules for all email records;
      6. 6) create an email management training program, as described in TD P 80-07, to be provided to new Treasury employees and contractors;
      7. 7) ensure that email management training is made available to Treasury bureaus, and/or that a bureau provides a written plan of equivalent training that satisfies the criteria for such training outlined in TD P 80-07;
      8. 8) periodically assess bureau-level implementation of email management requirements, including the Capstone approach;
      9. 9) coordinate external reporting on compliance with email management requirements, including the Capstone approach, on behalf of the Department; and
      10. 10) advise the SAO in reviewing and approving submissions to NARA that relate to the Department’s implementation of the Capstone approach and require the SAO’s signature.
   3. The Office of the Chief Information Officer (OCIO) will:
      1. 1) support the DASPTR in the design and implementation of the email management procedures described in this Directive;
      2. 2) ensure that email messages are accessible and retrievable to support the Treasury mission;
      3. 3) manage and preserve email messages in accordance with Treasury and NARA guidance and applicable records retention and disposition schedules;
      4. 4) protect the integrity and authenticity of email records;
      5. 5) incorporate records management functions into the design, development, and implementation of information systems;
      6. 6) establish controls that maintain reasonable mailbox size limits and encourage efficient email message management; and
      7. 7) implement document preservation directives upon request from the Offices of the General Counsel and/or Bureau Chief Counsel, or DASPTR.
   4. The Bureau Heads will:
      1. 1) ensure bureau compliance with this Directive and applicable federal records requirements as outlined in NARA and Treasury policies and guidance;
      2. 2) collaborate with the bureau’s Records Management Program Office and OCIO on implementation of this Directive;
      3. 3) designate Capstone officials, as provided in this Directive and consistent with NARA requirements;
      4. 4) ensure that email management training is made available to bureau personnel, consistent with NARA requirements; and
      5. 5) support the assessment and reporting of bureau-level implementation of email management requirements, including the Capstone approach, to DASPTR.
   5. The Chief Human Capital Officer will:
      1. 1) collaborate with the DASPTR and OCIO to support the implementation of this Directive.
   6. The Bureau Records Management Officers will:
      1. 1) coordinate the development and implementation of bureau-level email management procedures in accordance with this Directive and other applicable Treasury, OMB, and NARA guidance;
      2. 2) work with the Bureau Heads to create and maintain a list of Capstone officials, based on the guidance in this Directive and NARA requirements;
      3. 3) create and maintain a list of current and former bureau officials, employees, and contractors who should be designated as Capstone officials pursuant to this Directive and NARA requirements;
      4. 4) coordinate the process of obtaining approval from the agency SAO of any submissions to NARA that relate to the bureau’s implementation of the Capstone approach and require SAO signature;
      5. 5) ensure the transfer of permanent email records to NARA in accordance with the bureau’s records retention and disposition schedules and this Directive; and
      6. 6) conduct and report annual audits of compliance on behalf of their bureaus to the DASPTR.
   7. The Office of the General Counsel and the Offices of Chief Counsel of Treasury bureaus and Offices of Inspectors General will:
      1. 1) inform the applicable Records Management Program Office and OCIO of email account holders and/or categories of email messages that are subject to document preservation directives (such as a litigation hold), and provide updates to preservation directives as appropriate; and
      2. 2) maintain a list of document preservation directives applicable to Treasury, as further described in TD P 80-07, and ensure that this list is accessible to the appropriate Treasury personnel.
   8. The Contracting Officer Representatives will:
      1. 1) collaborate with the bureau Records Management Program Office and OCIO to identify contractor email account holders who, by virtue of their work, office, or position, should be designated as Capstone officials, and/or who are subject to document preservation directives;
      2. 2) inform OCIO of contract personnel departure or contract expiration, and provide all necessary permissions to enable access to such email accounts; and
      3. 3) participate in and report annual audits of compliance with email message management policies.
   9. Treasury Email Account Holders will:
      1. 1) manage email records in accordance with this Directive, TD P 80-07, and applicable Treasury records retention schedules; and
      2. 2) periodically review email accounts to identify messages that are personal email, non-records, or transitory records (as those terms are defined in TD P 80-07), and dispose of them as appropriate.
7. REFERENCE.
   1. Treasury Directive (TD) 80-05, “Records and Information Management Program,” dated June 26, 2002.
8. AUTHORITIES.
   1. 36 Code of Federal Regulations (CFR), Chapter XII, Subchapter B
   2. 44 U.S.C. Chapters 21, 29, 31, 33, and 35, “Records Maintenance and Disposition.”
   3. NARA Memorandum AC 23.2016, “Criteria for Managing Email Records.”
   4. NARA Bulletin 2014-06, “Guidance on Managing Email.”
   5. NARA Bulletin 2013-02, “Guidance on a New Approach to Managing Email Records.”
   6. OMB Circular A-130, “Management of Federal Information Resources.”
   7. OMB Memorandum M-12-18, “Managing Government Records Directive.”
9. OFFICE OF PRIMARY INTEREST. Office of the Assistant Secretary for Management. Office of the Deputy Assistant Secretary for Privacy, Transparency, and Records.