Email Retention Policy
In accordance with SUNY and NYS record retention policies, Purchase College email systems will automatically retain messages for three years on active email servers. After three years, email messages will be automatically purged from the system. This automatic deletion policy applies to messages within all folders (inbox, sent, draft file folders, etc.) on Purchase College email servers.
In addition, Purchase College email systems are also configured to purge items in the “deleted items” after 90 days. Items in the “deleted Items” folder are messages that were marked for deletion by the recipient.
All Purchase College email system users are expected to:
- Regularly check for new messages;
- Move messages with lasting value to dedicated storage on departmental/office networked file system; and to
- Delete transitory messages as quickly as possible.
The policy provides Purchase College with an email management policy that brings us into compliance with legal and regulatory requirements, and improves the College’s operational efficiency and effectiveness. This email retention policy applies to:
1. All Purchase College email systems
2. All users and account holders of Purchase College email accounts
3. All email sent or received using Purchase College email systems
These email messages are normally created for purposes of routine communication or information exchange, and as such, they are not considered official College records. These messages should be considered transitory messages that do not have lasting value (defined below) and should be:
1. Read and promptly deleted; or
2. Read and retained on the active server for no longer than the default retention period (defined below) or until their usefulness has ended (whichever occurs first), and then promptly deleted; or
3. Read and moved off the active server when job requirements necessitate retention for periods longer than the default retention period, and then promptly deleted when their usefulness has ended.
Examples of transitory messages:
- Announcements, notices about meetings or events, etc.
- Internal requests for information
- An inquiry about department course offerings or scheduling issues
Lasting Value Messages
Email is not a record retention or document management system, so messages with lasting value:
1. Should be moved to dedicated storage on departmental/office networked file systems; and
2. Should not be stored exclusively within individual users’ email folders/files.
These email messages exhibit one or more of the following characteristics that imply lasting value:
Have operational value (required by a department to perform its primary function)
- Administrative actions taken or planned
- Assignment of work or tasks to employees
- Distribution of reports or recommendations
- Distribution of policies, procedures, guidelines, rubrics, or templates
Have legal or evidentiary value (required to be kept by law or of value in prosecution of a claim)
- Falls within a litigation hold or internal investigation (see “Litigation Holds” below)
Have fiscal value (related to the financial transactions of the campus)
- Required for financial reporting and audits
Has historical significance (of long term value to document past events)
- Relating to an exceptional and/or significant event
Contain vital information critical to maintaining operational continuity after a disruption or disaster
Vital records or information may fall into any one of the above value categories
Examples of Lasting Value messages:
Announcement of or change to college or departmental policy
A message assigning an employee to perform a task
Responsibility for Retention of Messages with Lasting Value
Only the departments responsible for retention of specific types of records need to store and control the disposition of that information. For example,
1. If a department issues a policy change announcement via broadcast email, then that department is responsible for retaining that record (and not every recipient);
2. If a department manager was cc’d on a message that Purchasing used to send an electronic copy of a Purchase Order to a vendor, then the department manager does not need to retain a copy of the Purchase Order record; the Purchasing Office is responsible for retention of all purchasing records.
Electronic mail (email) messages enable us communicate internally with the Purchase College community and externally with prospective students, applicants, prospective employees, alumni, vendors, and colleagues across the world. The 2006 amendment to the Federal Rules of Civil Procedure addressing the discovery of electronically stored information requires institutions to establish email retention policies. New York State also has specific Records Retention Policies. This Purchase College Email Retention Policy establishes the default retention period for email stored on college email servers. This policy also identifies roles and responsibilities for litigation holds with respect to materials stored on college email servers.
Under normal circumstances, official records (policy documents, personnel records, financial transactions, etc.) will exist outside of the college’s email messaging system, and are retained in those source locations rather than in email messaging systems. For this reason, email messages are not normally considered “official records.” While official records are often transmitted through email messaging systems, copies of those official records must be retained by the office which originated the records.
The responsibility for determining whether a specific message has lasting value falls to the holder of the message. Senders and recipients should not retain messages any longer than necessary for their respective job purposes. When that need no longer exists, the messages should be destroyed.
For messages that the holder determines are of lasting value, the holder should store those messages outside of the messaging system – to a file folder in a personal home directory or a departmental file share. Messages can be moved to a file folder by drag-and-drop (to preserve message header information).
Questions about the proper classification (transitory or lasting value) of a specific message, record, or piece of information should be directed to the employee’s unit head, manager, or department chair.
New York State Records Retention Policy ‐ Default Retention Periods:
New York State Records Retention Policy states that normal business materials should be retained for three business cycles (three years), and financial records should be retained for seven business cycles (seven years.) At the end of that retention period, the records should be destroyed.
Backup copies of Purchase College email system files are kept for six months. These backups are for system restoration and disaster recovery purposes, and are not designed to or intended to facilitate retrieval of deleted messages.
While email may be considered transitory or of lasting value, the contents of email are subject to discovery when a litigation hold is issued. When litigation against the college or its employees is pending or reasonably expected, the college may receive a litigation hold notice from SUNY legal counsel instructing us to preserve all documents and records relevant to the matter being litigated.
A litigation hold directive overrides this email retention policy, as well as any record retention schedules that may have otherwise called for the transfer, disposal or destruction of relevant documents, until the hold has been cleared.
Email and account contents of separated employees that have been placed on litigation hold status must be maintained by the Campus Technology Services (CTS) until the hold is released.
No employee who has received a litigation hold notice may alter or delete an electronic record that falls within the scope of that notice. A litigation hold may also cover access to electronic records that the subject has downloaded, saved, or moved to other storage accounts or devices.
IV. ROLES & RESPONSIBILITIES
Campus Technology Services (CTS) will:
- Establish and publish standards for email account administration, storage allocations, and automatic archiving of messages (that must be retained for periods longer than the default retention period) to users’ local computer folders/files
- Provide facilities and instructions for moving messages with lasting value to dedicated storage on departmental/office networked file systems
- Manage technical implementations of litigation holds that are issued by SUNY counsel
- Suspend automatic deletion processes as necessary to preserve specific electronic messages, records and information that fall within the scope of the litigation hold, and that reside on active servers.
Department heads and unit managers are responsible for reviewing records retention policies and providing guidance to staff and faculty within their respective units. The guidance provided must be in accordance with this policy.
Originators of electronic messages, records, and information that have lasting value are responsible for:
- Appropriately identifying and retaining such records in accordance with this policy and
- Seeking assistance from management when unsure about how to categorize specific messages.
College employees who have been notified by management of a litigation hold are responsible for preserving all messages, records, and information that fall within the scope of the hold that they have downloaded and/or stored locally, and must provide copies of all records related to the litigation hold to HR.
Human Resources (HR) will:
Moderate review of records that may be relevant to HR investigation or litigation hold requests
Act as custodian for records that are deemed relevant to HR investigation or litigation hold requests
V. RELATED INFORMATION: