Google Vault FAQs for Utah’s State Governmental Entities

What is Google Vault?

A repository for data contained or created in:

• Gmail, including drafts
• Google Drive (though, by default, Drive content is not currently stored in Vault)
• Google chat history

 

Are Google chats saved in Google Vault?

• Yes, if chat history is turned on.

• The ability to turn off chat history can be removed by DTS Vault administrators, depending on the policy or wishes of a state or department’s administrator.

   

How long are records kept in Google Vault?

• From 0 to 99 years, depending on the established settings.

• Default retention for records in Vault is 99 years, so State of Utah/DTS has set it at 99 years from date of creation until agencies have decided what to use.

• This applies to email and chats (not Drive content).

• The exception is items migrated from GMD, GroupWise, and GroupWise “Archives” into Vault, which will be purged at the end of a 10-year retention, as originally planned.

• “Date of creation” means the date that a particular version or iteration of a record is created. Modifying a document creates a new version; the previous version is destroyed 10 years from its creation; the new version is destroyed 10 years from its creation. To the user, this appears as though the record is deleted 10 years after it was last modified.

• A 30-day retention is set as the default for deleted items (those moved to the "Trash" folder in Gmail).

• DTS is currently working on establishing a 7-year deletion policy for emails that fall under the Routine Administrative correspondence schedule. The 7 years will only be applied after an email account becomes inactive (for example, when an account holder moves on from State employment).

• Retention of the records can be adjusted by applying retention rules to datasets, which can be set apart and marked using labels or search filters.

   

How long should emails be kept in Google Vault?

• Utah Code 46-4-501(5) requires that all electronic records created or received by a government agency must be managed according to retention schedules established with the Division of Archives and Records Service and approved by the State Records Committee.

• Retention should be based on the content of the record and its value, not on its format or storage medium.

• Email communications play an essential role in government processes and need to be retained as long as the other records that document that process. Examples include attorney correspondence with clients (Litigated claims case files, record series 274), investigations of utility companies (Investigation and suspension docket, record series 698), getting environmental clearances for construction projects (Construction project files, record series 26199), etc. These types of emails may need to be kept for decades or even transferred to the State Archives for preservation.

• Emails not managed by a more specific schedule, as in the above examples, should be managed according to the state’s general retention schedules for correspondence which were approved by the State Records Committee, per Utah Code 63G-2-604(1) and Utah Code 63G-2-502(1)(b). Below are the general retention schedules for correspondence:

• Transitory correspondence (GRS-1759)
  Incoming and outgoing correspondence, regardless of format or mode of transmission, related to matters of short-term interest. Transmittal correspondence, including email, is transitory unless part of another process. This correspondence does not impact agency functions. When resolved, there is no further use or purpose.
  
  Retention and disposition:
  Retain until resolution of issue, then destroy.
  

• State government routine administrative correspondence (GRS-48)
  Incoming and outgoing business-related correspondence, regardless of format or mode of transmission, created in the course of administering agency functions and programs. Administrative correspondence documents work accomplished, transactions made, or actions taken. This correspondence documents the implementation of agency functions rather than the creation of functions or policies. Business-related correspondence that is related to a core function with an associated retention schedule should follow the associated schedule.
  
  Retention and disposition:
  Retain for 7 years, then destroy.
  

• State agency executive correspondence (GRS-1758)
  Incoming and outgoing business-related correspondence, regardless of format or mode of transmission, that provides unique information relating to the functions, policies, procedures or programs of a state agency. These records document executive decisions made regarding agency interests. Executive decision makers may include the Director, Chief Administrative Officer, Public Information Officer or other internal administrators as identified by the executive office.
  
  Retention and disposition:
  Retain for 5 years after separation, then transfer to the State Archives.

  
  

How can we manage the contents of Google Vault?

• The Division of Archives and Records Service recommends that Google Vault retention rules be adjusted to comply with legally mandated retention schedules.

• Emails of department and division directors should be transferred to the State Archives after 5 years for permanent preservation.

• Departments and Divisions should identify groups of records that need to be kept longer than 7 years, assign them labels, use retention schedules to record how long the group of records needs to be kept, and contact their DTS Vault Administrator to set up retention rules for the records contained in these record series.

• Transitory emails should be deleted from Gmail and may be purged from Google Vault. Agencies may also choose to leave transitory emails in Google Vault to be deleted after 7 years.

• Emails not identified as transitory that also do not need to be kept with a specific group of records should be deleted after 7 years. Once retention rules to accommodate the previously stated points are in place, 7 years can be the default setting in Google Vault.

   

Who has the ability to set the retention length of records or purge records from Google Vault?

• Those who have retention rule privileges:

• For state agencies in Utah, these are known as DTS Vault Administrators.

• Department executive administrators determine what retention rules should be applied and communicate them to the DTS Vault Administrators.

• Departments and Divisions should identify groups of records (known as record series) that need to be kept longer than 7 years, assign them labels, use retention schedules to determine how long the group of records needs to be kept, and contact their DTS Vault Administrator to set up retention rules for the records contained in each record series.

   

Who has access to search and view Google Vault records?

• DTS Vault administrators

• Department-assigned internal Vault administrators

• Those assigned a “Matter” in Google Vault:

• A defined scope sets aside a group of records, known as a matter.

• One’s own email or documents can be a defined scope, so that one can search his/her own email or other records in Vault.

• The ability for individuals to have access to their own records in Vault can be turned on or off, depending on the preference of department administrators.

 

After an item is purged from Google Vault, does any record of its existence remain?

• Vault has an audit log, which shows if a record did exist. The audit log contains the following information: subject line, name of sender and receiver, date and time it was sent, date and time it was destroyed.

   

Are records stored in Google Vault subject to GRAMA requests?

• If an item in Google Vault is a record, as defined by GRAMA (Utah Code 63G-2-103(22)), then it is subject to GRAMA requests.

• Governmental entities may not use the physical form in which a record is stored to deny the rights of a person to inspect and receive a copy of a record under GRAMA (Utah Code 63G-2-201(12)).