You can't ask employees to classify every email they send. You also can't keep everything forever and call it compliance. This template offers a middle path: a role-based email Records Control Schedule that scales without requiring individual judgment calls on every message.
The City of New York runs a three-tier system that assigns retention periods based on job function, not content. It works because it removes the decision from the end user. You define the roles once, assign mailboxes to those roles, and let automation handle the rest.
Purpose of This Template
This policy template classifies employee mailboxes into retention tiers based on the recordkeeping obligations attached to each role. It answers a single question: how long must we keep email from this person's position?
Use this when:
- Your organization sends thousands or millions of emails daily.
- Manual email classification has failed or never scaled.
- You need defensible disposal that survives audit scrutiny.
- Regulatory requirements vary by job function (executives vs. customer service vs. HR).
This is not an email Accessioning strategy. Accessioning everything creates liability and cost. This is a Records Control Schedule applied at the mailbox level.
Prerequisites
Before deploying this template, confirm you have:
Authority to classify by role. Review your General Records Schedule or sector-specific regulations (e.g., SEC Rule 17a-4, FINRA, state public records laws) to verify that role-based retention satisfies your compliance obligations. Some regulations require content-level classification; most permit functional classification.
An inventory of job functions. You need a list of roles with distinct recordkeeping duties. Start with organizational charts, but refine by actual responsibility. A "Manager" title means nothing; "Manager with signature authority on contracts over $50K" defines a retention tier.
Integration capability. This policy only works if your email system can apply retention rules automatically. You need connectors that read mailbox metadata (job title, department, role assignment) and enforce disposition without user intervention.
Executive sponsorship. Role-based retention means deleting executive email after a defined period. Legal and the C-suite must agree that permanent retention of all leadership communication creates more risk than it mitigates.
The Template
EMAIL Records Control Schedule: ROLE-BASED CLASSIFICATION
Effective Date: [DATE]
Authority: [[RECORDS DISPOSITION AUTHORITY](/glossary/records-disposition-authority) NUMBER]
SECTION 1: SCOPE
This policy applies to all employee mailboxes hosted on [SYSTEM NAME].
It does not apply to:
- Litigation hold mailboxes (see [Records Freeze](/glossary/records-freeze) procedures)
- Shared/generic mailboxes (covered in Section 4)
- External archives subject to separate retention schedules
SECTION 2: ROLE TIERS
TIER 1: POLICYMAKING ROLES
Retention Period: Permanent
Trigger: [Cutoff](/glossary/cutoff) upon separation from role
Roles Included:
- [Chief Executive Officer]
- [Board Members]
- [General Counsel]
- [Add roles with regulatory, legal, or historical significance]
Rationale: Communications from these roles document organizational
decision-making and carry evidentiary weight in litigation or public
accountability proceedings.
TIER 2: OPERATIONAL ROLES
Retention Period: [8] years after Cutoff
Trigger: Cutoff on December 31 of separation year
Roles Included:
- [Department Heads without policymaking authority]
- [Compliance Officers]
- [HR Managers]
- [Project Managers]
- [Add roles with regulatory or operational recordkeeping duties]
Rationale: These roles generate records subject to [STATUTE/REGULATION],
which mandates retention for [PERIOD]. The 8-year period aligns with
[STATUTE OF LIMITATIONS / REGULATORY REQUIREMENT].
TIER 3: TRANSACTIONAL ROLES
Retention Period: [3] years after Cutoff
Trigger: Cutoff on December 31 of separation year
Roles Included:
- [Customer Service Representatives]
- [Sales Associates (non-contract)]
- [Administrative Assistants]
- [Add roles with minimal recordkeeping obligations]
Rationale: Email from these roles typically documents routine transactions
with short-term business value and minimal legal risk after [PERIOD].
SECTION 3: ASSIGNMENT PROCESS
Role assignments are managed by [DEPARTMENT/SYSTEM].
- New employees are assigned a tier within [5] business days of hire
- Role changes trigger re-classification within [10] business days
- Departing employees' mailboxes are flagged for Cutoff on separation date
SECTION 4: SHARED AND GENERIC MAILBOXES
Shared mailboxes (e.g., info@, support@, hr@) are retained until
administratively determined to be no longer useful, with review every
[2] years by [ROLE/COMMITTEE].
SECTION 5: EXCEPTIONS
Legal Hold: Any mailbox subject to a Records Freeze is excluded from
automated disposition until the hold is lifted.
Regulatory Investigation: [COMPLIANCE OFFICER] may suspend disposition
on any mailbox pending investigation.
SECTION 6: DISPOSAL PROCEDURES
Disposition is automated via [SYSTEM/CONNECTOR] and occurs [FREQUENCY].
Disposal certificates are generated and retained per [[RECORDS SCHEDULE](/glossary/records-schedule)].
SECTION 7: REVIEW
This policy is reviewed annually by [GOVERNANCE COMMITTEE] or upon
regulatory change, whichever occurs first.
How to Customize It
Adjust the tier count. Three tiers work for most organizations. If you operate in a heavily regulated sector (financial services, healthcare, government), you may need five or six tiers to reflect varying obligations. Fewer is better; each tier adds administrative overhead.
Set retention periods to your regulatory floor, not your comfort ceiling. If your statute of limitations is six years, don't default to ten "just in case." Over-retention is a liability in discovery. Align each tier's period to a specific legal or business requirement and document that rationale.
Define "policymaking" precisely. Permanent retention should be rare. In the New York City model, policymaking means roles that shape organizational direction or bind the organization legally. It does not mean "important people." A VP of Marketing may be senior but if they don't set policy or sign binding agreements, they belong in Tier 2.
Automate role assignment. Manual tier assignment will fail within six months. Integrate this policy with your HR system so job title changes trigger automatic re-classification. If your email platform can't read HR metadata, you need a better connector.
Plan for departures. Cutoff on separation is the cleanest trigger. When an employee leaves, their mailbox enters a retention hold until the defined period expires. This prevents premature deletion and establishes a clear audit trail.
Validation Steps
Map every active mailbox to a tier. Run a report showing mailbox count by tier. If Tier 1 contains more than 5% of your organization, you've misclassified. Permanent retention should be the exception.
Test automated Cutoff. Create a test mailbox, assign it to Tier 3, simulate a separation date, and verify that the system flags it for disposal after the defined period. Confirm disposal certificates are generated.
Audit role assignments quarterly. Pull a list of employees who changed roles in the past 90 days. Verify their mailboxes were re-classified. Missed re-classifications are the most common failure mode.
Document your rationale. For each tier, write a one-paragraph justification citing the regulation, statute of limitations, or business requirement that dictates the retention period. You will need this documentation when opposing counsel challenges your disposition practices.
Run a legal hold test. Place a Tier 3 mailbox under a Records Freeze and confirm that automated disposition does not run. Accidental deletion of hold mailboxes is a sanctions-level mistake.
This template removes the impossible burden of per-message classification and replaces it with a defensible, auditable framework. Customize the tiers to your regulatory environment, integrate it with your email system, and enforce it without exception.
