LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  Policy 1200.10 Email Maintenance and Disposal 
 
  PROCEDURES
  1. Emails that are not deleted by workforce members shall be automatically disposed (permanently deleted) after three (3) years as a retention standard.
     
  2. During the 3-year maintenance period, email messages shall be automatically preserved by the system in a manner that provides an unchallengeable record of those electronic communications, regardless of the sender’s or receiver’s actions, such as modification or deletion of the messages.
     
  3. Non-record or transitory electronic communications that have reference value can be saved outside of the email system beyond the maintenance period, but not as part of a record (e.g., on a network directory). This type of information can be vendor contact information or general technical or business information (e.g., how to use software, how to search, etc.).
     
  4. When a workforce member transfers within the Department or interdepartmentally to another County Department, leaves, or is terminated from Los Angeles County employment (no longer works for DMH), the email account and all its contents shall be permanently deleted after 30 days.
     
  5. In order to prevent potential risks of unauthorized access, accounts that have been inactive in excess of 90 days are automatically disabled. Upon return, the workforce member must contact CIOB Helpdesk to request the restoration and reinstatement of their access to network resources including but not limited to their email account.
     
  6. In the event any email account is required by litigation or investigation, a hold shall be placed on the email account to extend the 3-year maintenance period and preserve all email messages until the hold is lifted, including both existing and new messages.
     
    1. A hold for any email account may be authorized by any of the following individuals:   
                             
      1. Administrative Deputy
         
      2. Human Resources Manager
         
      3. Compliance Officer 
                   
    2. The hold shall remain in place until it is lifted by the individual who authorized the hold; or in the absence of the individual who placed the hold, by any other individual authorized to place a hold on an email account as described in Section F.1.
       
    3. In the case of an administrative leave which may involve a future dispute where user’s emails and email box might serve as valuable evidence, the workforce member’s upper management or DMH Human Resource Bureau must immediately submit an email preservation request so that the inactive automated account removal process does not permanently delete the evidence that might be needed at a later time.
       
  7. Workforce members are responsible for managing their email boxes and ensuring they are in working order at all times. This includes routinely deleting messages when they are no longer needed.
     
    1. Email that contains Protected Health Information (PHI) that is sent or received by workforce members must be deleted from their Inbox or Sent Items folders as soon as the message has served its purpose. All information pertaining to clients must be extracted from the email box and uploaded for storage into the DMH electronic health record system where the official client records must remain. No PHI should be left in the workforce member’s email box for an extended period unless deemed necessary to completing one’s duties.
       
  8. Workforce members are prohibited from doing the following solely for the purpose of circumventing this disposal policy:
     
    1. Exporting County email to Personal Storage Table, Extensible Markup Language (XML), plain text, Portable Document Format files, or printing messages to paper, except as required if the electronic communications are deemed electronic records under Board Policy 3.040 and the Departmental Records Retention Schedules;
       
    2. Forwarding County email to personal accounts or systems or to their own or others’ County email accounts or systems; or
       
    3. Using any other methods to circumvent the 3-year retention period for such communications.
       
  9. County business-related electronic communications stored on non-County computers or electronic communications accounts may be subject to public records requests, legal discovery, court-ordered production, audit review, and records retention requirements. Such business related electronic communications stored on non-County computers or electronic communications accounts of workforce members are considered County electronic communications and workforce members have no reasonable expectation of privacy in County business-related electronic com