QUESTION
What changes were made to the email retention policy for non-policy makers and what were the reasons?
4:55:40
·
3 min
Commissioner Pauline Toole clarifies that the email retention period for non-policy makers was revised to 3 years to save costs and manage data effectively.
- The shift in email retention policy from 8 years to 3 years, not 4, aims to streamline data management and cost savings.
- Migration to Microsoft 365 for city agencies led to reevaluation of email retention, focusing on the necessity of records.
- Identification processes for litigation holds and Adult SURVIVORS Act filings ensure necessary emails are preserved.
- The policy was developed in consultation with the law department, incorporating multiple safeguards for a thorough disposal process.
- The overall goals are to eliminate unneeded records, save the city $1 million, and maintain essential data protections.
Lincoln Restler
4:55:40
And I'd like to ask about the recent article that indicated a shift in regular retention policy for emails of non policy makers indicating their emails would be deleted after 4 years instead of 8 years.
4:55:55
Could you advise was that report accurate?
Pauline Toole
4:55:59
I think it's after 3 years, not 4 years.
4:56:01
Excellent.
4:56:03
So it is accurate.
4:56:04
And it's not
Ken Cobb
4:56:08
you know, this was
Pauline Toole
4:56:11
we've had several conversations with the office of technology and innovation.
4:56:17
In 2019 2020, as I mentioned in my testimony, they moved city agencies to MS 365 and our Outlook, which is the email service as well as, you know, a lot of other services.
4:56:33
When they did that, they only migrated the accounts of people who were still existing in city government.
4:56:40
Some of those people may have subsequently left.
4:56:42
But they're in the MS 365 Cloud.
4:56:46
Those people who had left city government before 29 team.
4:56:51
The email was all on an enterprise vault system, and they did not migrate those those all state on that enterprise vault server, which is now out of support, and the cost of maintaining that server and the service was about a $1,000,000 in an OTI costs.
4:57:14
So our discussion was, are these records going to be of value to anyone?
4:57:20
Now there's rule a, which is policy maker email on that inter size vault server as well.
4:57:26
Those records under our policy are transferred to the municipal archives.
4:57:30
And the role b email, which would have been deletable after 8 years.
4:57:37
We could keep it for 4 more years.
Lincoln Restler
4:57:39
What that meant?
4:57:39
The role
Pauline Toole
4:57:40
b role b or non policy makers.
4:57:42
So they're they're anyone in in city government who has a computer who's been using the computer system since I think OTI expanded email access back in 2002.
4:57:55
So all of that has been sitting there, and in in our judgment, there was no reason to retain it for additional time because it's not been utilized.
4:58:06
We checked for litigation holds.
4:58:08
If there are lit holes, that mail also gets transferred back to its agency to the MS 365 cloud.
4:58:16
We looked at filings under the Adult SURVIVORS Act, and if there were agencies that had the number of filings or if they had a lot of litigation, Those all of that email will also be transferred to the agency's MS 365 Cloud.
4:58:30
And the bulk that remains are emails of people who left government before 2019.
4:58:37
If they come back, it's unlikely in my experience that they are going to go back to their same agency and in the same role.
4:58:45
So it made a lot of sense to help the city save a $1,000,000 and manage that disposal process.
4:58:53
So it's not like the people at OTI are just pushing a button is the agencies need to complete need to go through that.
4:59:01
Litigation holds.
4:59:02
They need to identify anyone role be that might have a hold that info gets transferred back to them, and then submit a disposal application that is reviewed by the law department by the municipal archivist and by me before disposal can actually happen.
4:59:21
So we've maintained all of the safeguards in a way of saving money and getting rid of records that will never have a use.
Lincoln Restler
4:59:29
And this policy was developed, it sounds like by you and Doris, NOTI.
Pauline Toole
4:59:34
By Doris, NOTI in consultation with the law department.
Lincoln Restler
4:59:37
Sure.