Overview
Throughout 2023-2025, systematic retention policies for M365 emails and chats were rolled out agency by agency. Secretary of State Archives Division and Enterprise Information Systems - Shared Services coordinated with State agencies throughout the implementation process.
If you were not able to attend one of our information sessions, watch the recording below and review the FAQ on this page.
Still have questions? Contact us at
records.management@sos.oregon.gov
Information Sessions
Recording from Feb. 8, 2023 session:
M365 Retention Informational Session (YouTube)
M365 retention Informational Session
Guidance Documents
Role-Based Retention Method for ROs
M365 Role-Based Retention IT guide
Role-Based Retention Authorization
Master Agency M365 Retention List
FAQ
General Questions
Q: What's this all about?
A: Throughout 2023- 2025 the Enterprise Information Services M365 team and SOS Archives deployed retention policies for electronic communications in M365. This means all emails and Teams Peer-to-Peer Chats will be managed for retention automatically through system settings based on retention policies. There will not be any direct action required by employees.
Q: When is this going to happen?
A: SOS Archives began working with agencies in spring 2023 to identify retention groups. This will continue until all agencies have a plan in place.
Q: How do I learn more?
A: Be sure to watch the recorded information session about the project. Also keep your eye on this webpage; we'll be adding content as the project progresses.
Q: What do I need to do at this point?
A: Most importantly, watch the recorded informational session. Let us know if you have any questions or if you'd like to schedule a meeting to get started. Our first step together will be to review your Special Schedule together and make any needed updates. This will ensure we are assigning users to M365 Retention Groups based on the most current information.
Q: What if our agency isn't ready yet? What if we don't get it done on time? We don't want all of our stuff to disappear on us!
A: No agency will have emails destroyed per new retention policies until they have completed the analysis process with SOS and are ready to go. This is a collaborative process we'll be working on together. Agencies which are not ready by the go-live date will be kept on a temporary hold while we continue working towards completion.
Project Scope
Q:What types of Chats will be included in the scope of this project?
A: Only Peer-to-Peer Chats will be included (chats between two or more users that can be found under the “Chat" tab in Teams. Posts and replies on Teams channels will be addressed in a future phase.
Q: I see an option to delete Chats myself. Is that part of this project?
A: As of early 2023, you now can remove Chats within Teams. This deletes the Chat from your individual list of Chats, however other members of the Chat will still be able to see the Chat in their own list. A copy of the Chat will be saved in the M365 archive until the end of the retention period for that Chat. This feature was rolled out by Microsoft and is unrelated to our retention rollout. If you have any questions about this feature or are not able to delete Chats, contact your IT support desk for more information.
Q: What about records stored in Teams, SharePoint, and OneDrive?
A: This initial rollout is targeting emails and Peer-to-Peer Chats, but the same policies will be used in later phases for Teams, SharePoint sites, and other M365 applications. You will have plenty of advance notice ahead of the launch of additional phases of the move towards role-based retention for records in M365.
Roles and Responsibilities
Q: Who should I talk to in my agency about this?
A: Agency CIOs, agency directors, and agency records officers have received introductory information as part of the communication plan. Everyone is encouraged to share the information session recording and resources from this page to other key stakeholders in their agency. The effort will mostly involve people with records expertise and divisional organization knowledge. Agencies will also need agency administration support and cooperation with direct IT support. These will all be identified as the SOS Archives team works with each agency.
Q: Am I going to need to get everyone at my agency to change how they use email and chats?
A: Nope! This will all be happening on the back end and most end users will not need to do anything differently. You may want to send out an internal communication as an FYI; this could be an opportunity to refresh folks on your agency's policy on Acceptable Use of Technology and/or provide a reminder that all chats and email fall under the umbrella of public records.
Q: Will employees need to manually move or file any emails going forward?
A: Only in limited special cases. Those cases will be identified during the rollout process and alternative procedures will be developed for the units in question. The filing requirements for even those groups will be quite light. All other users can keep managing their inbox as they have been.
Q: My board or commission doesn't have in-house IT or records staff to do the work. What do we do?
A: The rollout team will identify IT support for each affected entity and work directly with them. Members of the SOS team will be able to assist small entities which lack internal staffing for records decisions.
Q: I work for a large agency and I really don't know what every employee does. How will I figure that out?
A: You can lean on the Records Coordinators in your agency's divisions or units to help you pull together this information. Administrative Specialists or Executive Support Staff are also excellent resources for helping you figure out who does what. You can also search for teams or employees in Workday to see what someone's classification or job title is and where they are positioned in the organization.
Q: Who tracks which users are in which group? How am I going to keep track of this?
A: Though the application of retention policies will be completed by IT, Records Officers will be identifying which users go into which retention groups. Depending on the agency different methods may be employed for this. The SOS team will have suggestions and guidance when your agency begins work with them.
Records Retention
Q: Our agency schedule is out of date/doesn't exist and I'm not sure what to do. Will there be anyone to help?
A: The SOS Archives team has already identified agencies which will need special schedule work, and will walk you through the process. If you would like to get started on your agency special schedule, please email records.management@sos.oregon.gov to begin the process.
Q: Don't my emails already go away after 2 years?
A: They move to your Online Archive mailbox after 2 years but are still accessible via search or by looking in the Archives folder in Outlook. These new policies address when the emails go away for good.
Q: Is it true that all emails will be kept 3 years?
A: The default (most common) setting will be 3 years, however all agencies will work with SOS to identify which users will fall into the longer retention groups.
Q: What if there's not a match between the longest retention period for a user and one of the M365 retention groups?
A: Initially there will be 6 retention groups: 3 years, 5 years, 7 years, 10 years, 26 years, and Permanent. If the retention doesn't match one of these, round up to the closest group. For example, if you have a user with the longest retention period of 6 years per your Special Schedule, round them up to the 7 Year 365 Retention Group.
Q: Some of my users create a type of record that has a very long term retention, but those records are already stored in a different system. Sometimes we email copies to coworkers or to the public as part of our work. Does that mean that those users need to be assigned to one of the longer retention periods?
A: Nope! So long as those records have an official copy in another designated system, any copies attached to emails would be considered duplicates or convenience copies. You do not need to include the longer retention for records stored in another system when identifying the retention period for that user's email.
Q: We also follow Federal retention schedules. Will this be considered? Is this retention method compliant with Federal standards?
A: If Federal retention schedules are used at your agency in conjunction with State schedules, we will consider both when determining which M365 User Group to assign. We will ensure that all retention periods that apply are met fully.
Q: What will happen to Teams chats when the people in the chat fall into different M365 Retention Groups?
A: The chat in Teams will disappear from the view of the users when the first retention period is met, however the messages will remain accessible within the eDiscovery portal for public records requests until the longest retention is met.
Q: Some of my users fall into the “Permanent" retention category. Does my agency really need to keep their emails forever? How do we plan for user licenses for these records?
A: The Permanent policy will be applied to those accounts that are listed as permanent retention in the agency's special retention schedule. This will prevent emails from those accounts from being deleted from the system. They will not live in M365 forever, however. Permanent records eventually get transferred to the State Archives for preservation. When this occurs will depend on the office and the tenure of the employees in question.
Q: Isn't it against OAR 166 to over-retain records?
A: OAR 166-030-0026 (2) states that “Retention periods for state agency records are both a minimum retention and a maximum retention period." The intent behind this rule is to ensure that agencies do not unnecessarily keep records well past their scheduled retention. There has always been consideration for practical capabilities, however. Slight over-retention to allow for greater efficiency, such as grouping records into one slightly longer retention group, is in keeping with the spirit of this rule.
Q: What about accounts for users that have already left the agency? Will these retention policies be applied to deactivated mailboxes as well?
A: The specific policies being used in M365 for active accounts will not apply to existing backfile of deactivated accounts. However, the work to identify retention groups by programs/units will allow agencies to make decisions about which of those accounts can be safely deleted and which will need to be retained for some time yet.
Q: After the retention period is met, will the email archives still be available in eDiscovery? Will we still be able to get copies for litigation purposes or public records requests?
A: When the retention period is completed, the records will be destroyed (deleted) from all archived locations, including the eDiscovery portal. This is a cornerstone of defensible disposition and is in line with the expectations of legal and regulatory professionals. Please consult with your legal counsel if you need assistance with explaining this in your response to a legal discovery or public records request.
Q: What if we have a legal hold due to ongoing litigation, or need to prevent destruction due to ongoing records requests?
A: Legal holds can be applied within M365 for all content and will automatically override any retention policies in place. No records will be destroyed until all applicable holds have been removed.