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Gmail Retention Policy Challenge and Strategy 26 March 2011 Challenge: The goal of this strategy is to uphold the

commitment to authorized users to enable retention of Lotus archived e-mail subject files in GMAIL limitless cloud storage and provide easier e-discovery for the system administration staff WHILE complying with NARA Code of Federal Regulations to retain transitory e-mail no more than 180 days. Recommended Strategy: As suggested by Sonny and Nate, establish the retention setting to a rolling 180 days for the GMD Server, the enterprise (GSA-wide) vehicle for FOIA and related e-discovery requests. Establish an unlimited retention period for messages in individual authorized users Gmail cloud folders as a critical element of our ZEF electronic desktop. Lotus e-mail will be migrated into Gmail but not able to be migrated into GMD. Gmail in individual accounts is also e-discoverable and may be searched from the server by system administration. Architecture:

GSAs e-mail system has two storage and processing elements: Gmail server for individual mail and the GMD Google Mail Discovery server, which are separate from one another. Gmail: Gmail is cloud-based and will replace the current Lotus Notes application. GMD (Google Mail Discovery) Server: This component of our new email system provides the capability of capturing and retaining all emails received for an indefinite period for the purposes of discovery. The settings of this server are flexible and can conform to directed levels up to 5 years. Lotus Notes Emails: Upon implementation of Gmail for users, Lotus notes emails and archives will be migrated to individual Gmail accounts but are not able to be migrated to the GMD.

Implementation Steps: Set GMD, the enterprise e-mail server, to 180 days. Establish a NARA Records Disposition Schedule for GMD of 180 days to recognize transitory nature of most e-mail. (Exception litigation e-mails.) Set individual Gmail accounts to unlimited time retention and 25 gigabytes size. Establish a NARA Records Disposition Schedule for electronic mail to recognize short- and long-term temporary and permanent working records. Update GSA Electronic Messaging Directive (CIO 2160.2A) accordingly. retention periods be identified in e-mail policy. CFR 36.1236.22 requires

Establish a business case based on ZEF, Cloud, and savings to justify a waiver to the NARA CFR 36 1236.22 (d) (1) to allow storage of transitory e-mail in Gmail. Although Gmail is not an approved Records Management System (according to features of which are listed in 1236.20(b), it serves as our electronic (ZEF) desktop of temporary and permanent records. Justification will also state our intent to find and implement a Google-compatible records/document management system as well as efforts to educate users in proper electronic records management. Educate users on records retention responsibility--E-Mail is an electronic record. Educate users on legal requirements and pros and cons of e-discovery. Educate and encourage users to use the Google Docs collaborative site primarily; Instant Messaging (IM) for transitory comments. Establish no retention or records disposition schedule for IM. Work with Unisys to find a compatible Document Management System application that will enable automatic transfer from Gmail to a Document Management System. Provide Google via Unisys with the features specified in CFR 36 1236.20(b) to determine if Gmail currently can qualify as a records management system or has or plans to incorporate them in the future. In the meantime, instruct users on how to copy Federal records (long-term temporary and permanent records) from Gmail to a recordkeeping system in accordance with 1236.201(b)(2) without printing to paperprinting would conflict with our ZEF goals. Remind users of their responsibility to manage migrated mail, preferably prior to migration, especially to delete their transitory mail. Before migration, temporary and permanent e-mail can be saved by subject to shared drives using Lotus PDF creator. Nate is exploring tools to enable users to save post-migrated Gmail messages in PDF or another format for storage on their local shared server by using a desktop side tool to pull the messages down and then saving to PDF using a PDF printer application. Nate and Robert are exploring compatible document management systems. GMD is fully e-discoverable and made much easier through Google Search than Lotus Notes e-discovery processes. E-discovery of individual Gmail accounts can be conducted by system administrator. To handle a FOIA or other e-discovery search of Gmail accounts (outside of GMD), using the Audit API, GSA/Unisys Gmail can download the user's current mailbox in mbox format. The administrator can then search the mbox file for specific messages. Information about the Audit API can be found here: http://code.google.com/googleapps/domain/audit/docs/1.0/audit_developers_guide_protocol.html#downlo ading_mailbox Regarding impact of retention changes on contract and funding, recommend amount established to pay for a 5-year GMD can be applied to a Google or Google-compatible Document Management System.

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