Thursday, July 2, 2015

Fremont's email retention policy subject of Alameda County Grand Jury report


An Alameda County Grand Jury probe into City of Fremont's email retention policy has found purging most email records after 30 days deprives residents access to crucial information about how and why public policy, regulations and laws are formulated.
"Destroying emails prematurely not only prevents public access to vital information, but also impedes investigations of wrongdoing," the report released Monday said. The grand jury concluded the city's interpretation of state statutes cited in the report are "contrary to the spirit of open and transparent government and must be changed."
Based on a citizen's complaint alleging a violation of state law, the grand jury started an investigation into the city's administrative regulations defining all unsaved emails as "preliminary drafts" which are destroyed after a 30-day period -- as a result excluding them from disclosure under the California Public Records Act. After 30 days, the emails are automatically deleted unless an individual employee or advisory volunteer determines the email is a record that needs to be retained.
"The grand jury examined California state statutes and Fremont policies governing the retention and purging of public documents, and spoke to advocates on both sides of the issue concerning the retention of emails. The grand jury is deeply concerned with Fremont's loose interpretation of California government transparency and retention statutes and the city's apparent intentional efforts to exclude the public from accessing city emails," the report said.
City employees and volunteers who use the municipal email system -- about 1,300 individual mailboxes -- receive approximately 3,000 emails per day, the report said. The investigation included interviews with city employees and a representative of a nonprofit organization dedicated to First Amendment quarrels.
California's Public Records Act provides the public with the ability to request documents and records from government agencies, including emails, which help to explain how and why important decisions are made. However, the law has certain exceptions preventing governmental agencies from disclosing some forms of information, such as medical and personnel records to protect an individual's right to privacy.
Also, it specifically exempts public access to preliminary drafts, notes and inter-and intra-governmental agency memos. The act does not specify how long a public record must be retained by governmental agencies.
The bulk of city records must be retained for at least two years under the statute's requirements. However, "records" is not defined.
"Some public agencies have taken the position that their organization's emails are not records even though the Public Records Act clearly defines records to include email communications."
Fremont's definition of a public record is not based on the Public Records Act. Rather, it is based on a more than two decade old state attorney general opinion, which describes a public record as —... a thing which constitutes an objective lasting indication of a writing event or other information which is (retained) ... because it is necessary or convenient to the discharge of the public officer's duties and was made or retained for the purpose of preserving its informational content for future reference.
"It is the position of the city that its unsaved emails do not fit within the attorney general opinion; therefore, they are not public records as understood by the state's record retention statute," the report said.
As a result, Fremont maintains it is not required to retain all emails for two years like other public records in its possession. Because city emails are purged after 30 days (meaning the documents are not kept in the regular course of business), the city maintains they amount to preliminary drafts that are exempt from disclosure under the Public Records Act. From the grand jury's perspective, Fremont's questionable logic appears to exempt all emails (unless separately saved) from disclosure, even though the Public Records Act specifically includes emails."
In its findings, the grand jury said classification of emails as preliminary drafts denies the public opportunities to watch over government operations and classification of emails as records not kept in the regular course of business, unless specifically saved, deprives the public of significant opportunities to monitor government.
As recommendations, the grand jury suggested a change in email retention policy to require emails are stored and retained for at least two years and another change in email retention policy so that no emails are classified as preliminary drafts. Instead, all such emails are retained in the regular course of business and subject to the Public Records Act.
Fremont Mayor Bill Harrison said the city's email retention policy developed over time as Internet technology has changed.
"It's something we've evolved on for sure," Harrison said Tuesday. He noted the city's first email policy dates back 15 years.
Prior to having a meeting with the grand jury members to discuss the findings, Harrison said a new system was put into place to retain emails for up to 90 days. Further, the city is looking to extend preservation of emails to two years from the original "sent" date and to budget funds for the data storage, he said.
The city has until Sept. 29 to formulate a response to the report indicating agreement or disagreement with the findings and to describe actions taken on implementation of the recommendations.
July 2, 2015
San Jose Mercury News
By Julian J. Ramos – Fremont Bulletin

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