by Erica Rice

[Edited 7/16/20: This post was updated to include new information about applying retention policies in Teams.]

The great Dr. Patricia C. Franks once wrote, “Records and information managers who understand the way work is conducted in their organizations have a better chance of identifying and providing intellectual and/or physical control over the records created.”¹ Ever since the pandemic hit, “the way work is conducted” has changed fast. Organizations have rushed to adopt new technologies and remote communication software, often before records management capabilities have been evaluated. In this multi-part series, we will be exploring the various software environments that records managers may need to contend with. Even after the shut-down ends, Teams and Zoom may be here to stay. Microsoft Teams now has over 75 million daily users², and this number will only continue to grow as adoption rises.

There are many different types of collaborative software and communication platforms. For simplicity’s sake, I am going to refer to Microsoft Teams (referred to hereafter as just “Teams”) when I talk about how to manage records in this type of application. This is not an endorsement of this particular product, but it is the application that is mentioned most often in the consulting questions we receive.

Teams is just one of the tools that is integrated into Microsoft’s Office 365 suite, along with Outlook, OneDrive, etc. For this article, I am just going to focus on the chatting and draft-document-editing capabilities of Teams.

But first, allow me to present the Golden Rule of this blog post — this rule works in conjunction with all the tips listed below:

Work with IT!

Whether you are implementing collaborative software for the first time, or your IT department has been tasked with making sure the software is in compliance (whether it’s security, records retention, privacy, etc.), now is the perfect time for the Records Management and IT departments to work together on an agency-wide initiative. With complex, enterprise-wide software like Teams, usually no one outside of the IT department will have the ability to edit permissions, to apply retention rules, or to just fiddle with the general software settings. Let IT know what your retention requirements are: your wildest dreams AND your bottom-line, minimum “must-haves.” In turn, IT can dash your dreams – errr… let you know what the software capabilities actually are, and you can work together to find a solution that works.

On to the rest of the tips…

There are two general approaches that you can take towards managing retention in Teams: avoid it or embrace it.

First determine who is using Teams and why — who is the audience, and what is the purpose of the application? In other words, why was it installed on all your computers and cellphones in the first place? Did your government want to facilitate communication? Handle document storage and sharing? Either way, your government will want to have a policy in place that dictates acceptable use of the application. This should align with your other electronic records policies: email, social media, texting, etc.

Avoid Retention: Focus on Transitory Information

I’m listing this option first because it is the simplest. Your organization has the option to create a policy that only allows for transitory information to be exchanged within Teams.

For local governments (GR1000-50) and state agencies (1.1.057), Transitory Information may be destroyed any time after it no longer has administrative value or its purpose has been served. Here is a quick reminder on what constitutes “transitory information”:

Records of temporary usefulness that are not an integral part of a records series of an agency or local government and are not essential to the fulfillment of statutory obligations or to the documentation of agency functions. Some examples of transitory information, which can be in any medium (voice mail, fax, email, hard copy, etc.) are routine messages; telephone message notifications; internal meeting notices; routing slips; incoming letters or memoranda of transmittal that add nothing of substance to enclosures; and similar routine information used for communication, but not for the documentation, of a specific agency transaction.

Examples of transitory messages exchanged in Teams and adjacent applications might be:

• “Meeting starts in 5 minutes!”
• “Can you link me to that report?”
• “Want to discuss it over lunch?”

For more examples of Transitory Information, check out this handy infographic: for local governments and for state agencies.

Messages like these that do not document any government business can be deleted at any time. This means that your organization could decide to delete all chat messages at regular intervals, such as every 30 days. However, an auto-deletion policy is acceptable only if employees can certify that they are not exchanging any messages above the level of transitory information. If any conversation rises to the level of a record that documents government business, it must be retained for the correct amount of time (either within Teams or offline), before it is deleted.

Which brings us to the other option…

Embrace Retention: Transform Teams into a Retention-Conscious Tool

As we advise time and time again, TSLAC’s published retention schedules are media-neutral. That means that all records must be retained according to the purpose and function of the records; record format does not dictate retention. You will not see a “Microsoft Teams” record series on any of our retention schedules. Thus, any records that a Texas government employee creates in Teams will follow the same retention rules as records created anywhere else — on paper, in email, or on film. Additionally, any records created in Teams are still subject to Public Information Act (open records) requests.

Retention-Conscious Channels

Applying retention policies to records becomes a lot easier when the records are organized around a retention schedule. Organization in Teams is based around “channels,” which can be created to work on specific projects or to facilitate communication within a work group.

So, tie retention periods to channels dedicated to specific projects. Avoid creating channels for general topics like “Records”; broad topics can potentially generate discussion that may fall under several different records categories. Instead, create channels for specific projects.

For example, the RMA Unit could create a channel for discussion of blog post ideas. This is an ongoing, routine project that TSLAC would retain under Publication Development Files, which has a retention period of “AV.” Content and channels can be managed manually; retention codes can simply be added to the channel name as a reminder. Thus, the name of our example channel might be “Blog Post Ideas (AV).”

[Updated 7/16/20]: Teams also allows the use of automated retention policies, but it requires some behind-the-scenes work and a bit of IT knowledge — it does not work the same way as SharePoint retention policies and does not support retention labels³. For detailed instructions on how to apply retention policies to teams, channels, or users, consult this help page from Microsoft. Keep in mind that once data is auto-deleted, it cannot be recovered. The “disposition review” feature for retention labels cannot be used with retention policies. If your records management policy requires authorization to be obtained before destruction, this process may bypass that step.

Also consider creating standard naming conventions for your channel names. This is especially important because Teams channels do not allow the use of certain special characters commonly used in retention periods, such as the plus sign (+). For example, you might create a policy that each channel must have a descriptive title and a retention period:

• “Channel Name” (Retention Period)
• e.g. Social Media Communications (FE-2Y)
• e.g. 2020 Annual Report Working Files (3Y)

For any channels dedicated to more general discussion of a broad topic, these might be classified as general correspondence, which has a retention period of 2 years for both local and state governments. For these types of general posts, the team admin may want to pin a “sticky” post at the top of the channel, to remind participants that it is only meant for routine messages.

Once a channel is no longer needed, the team admin may hide it so that it is not visible to other team members — it should not be modified. It is also a good idea to add an end date to either the title or description of the channel, so that disposition dates can easily be calculated.

Store Final Products Offline or Outside of Teams

The channel examples used in the previous section are meant to be used as informal discussion platforms. In other words, nothing rises above the level of transitory information, or working papers, or general correspondence regarding ongoing project work. But what do you do when the discussion eventually leads to a final product? Your team has been discussing the 2020 annual report and sharing working papers on the channel, and now you have a finished report to maintain permanently.

Well, we wouldn’t recommend storing any long-term or permanent records within Teams itself. For one thing, it adds yet another application that must be searched for open records requests. And, as technology evolves and file formats become obsolete at an ever-increasing rate, the chances of that permanent annual report remaining accessible and readable in Teams for the next 50 years are near zero.

Teams just isn’t built for retention. Keep in mind, if you ever delete a team from the Teams platform, all the files, channels, and conversations associated with that team will also be deleted. You would have to be very careful not to delete disbanded teams if there are records within that team that have not yet met retention.

For any records that have retention periods longer than 2-3 years, store them outside of Teams in a hard drive or shared drive that is backed up regularly. The naming conventions discussed earlier will come in handy here; if the naming conventions for your channels and your share drive folders are the same, dragging and dropping files for storage is a breeze. For long-term records with retention periods longer than 10 years, you may want to store multiple copies in multiple locations, or even print to paper as a backup. For more information and requirements for long-term electronic storage, see Bulletin B (for local governments) or Bulletin 1 (for state agencies).

Applications like Teams are meant to facilitate communication, not to store long-term electronic documents. In general, you want to avoid sharing or storing any essential/vital records, or any records that may contain sensitive/confidential information like HR records, or any records containing personally identifiable information (PII). This should be addressed in your acceptable use policy for Teams.

There is no single “right” way to use a collaborative application like Teams. Every local government and state agency needs to decide how software can be customized and utilized to fit their unique functions and workplace culture. The tips we presented may help you manage records retention within collaborative systems. You can use all of them or a combination of them, or you may be inspired to come up with your own unique guidelines. Let us know in the comments section if you’re doing something interesting with Teams.

Stay safe working from home, and stay tuned for Part II: Zoom Records!

Notes

1. Patricia C. Franks, Records & Information Management (Chicago: Neal-Schuman, 2013), 22.

2. Jared Spataro, “2 years of digital transformation in 2 months,” Microsoft, accessed July 7, 2020, https://www.microsoft.com/en-us/microsoft-365/blog/2020/04/30/2-years-digital-transformation-2-months/.

3. “Learn about retention labels,” Microsoft, accessed July 7, 2020, https://docs.microsoft.com/en-us/microsoft-365/compliance/labels?view=o365-worldwide.