Whether it takes place in Gmail, Chat or Drive, school districts frequently use Google Workspace for both communication and recordkeeping. Overall governance of how long items are maintained will be set by an organization’s policies or perhaps state regulations. Google Workspace addresses data governance and eDiscovery with Vault (vault.google.com). Having a solid strategy for managing communication and data within and beyond your default retention timeframe is key to ensuring data that is critical in personnel, student or legal matters is not mistakenly lost.
From establishing a solid retention strategy to managing potential issues throughout their lifecycle, it is important to develop strong partnerships with both your organization’s legal counsel and the district administrators responsible for managing these matters.
You will need to ensure that the interpretation of the retention policies and regulations is consistent to ensure that Vault rules are set up to meet the need. They will also be responsible for notifying you of the need to create a new matter and associated holds, be requesting data from the system and advise of the closure of matters.
What is eDiscovery?
Electronic Discovery (eDiscovery) is the process of reviewing and investigating electronic content for legal purposes. In K-12 education we often see this overflow into student discipline issues; requests for records as allowed by legislation such as Family Educational Rights and Privacy Act (FERPA) or Sunshine Law; and personnel matters.
Understanding the Basics of Google Vault
Vault has a new interface roll out at vault.google.com which makes this a little bit easier to understand over the “classic” (ediscovery.google.com) if you were a previous vault user. Here is a basic breakdown of what you will be using:
- Retention: This is where you set up how long things are kept (even if deleted by the user) in Vault and how things will be handled after this window of time passes. This is broken down by the type of record (Mail, Drive, Chat, etc). These settings can be domain-wide or more granular (i.e. staff vs students). Be sure to work with leadership on what these rules should be to keep in line with policies and legislation.
- Matters: This is where you will build out different situations that are requiring discovery. Examples would include a principal contacting you regarding a student discipline concern or human resources reaching out to request items be kept related to an employee matter. Within a matter you will have:
- Holds: This is where you establish extra retention. This prevents items from following the actions of the end of their retention period (such as to delete).
- Searches: This is where you will pull results for defined criteria such as things that are between specific people or include a specific phrase or word.
- Exports: After finding specific items you need to take out of the system to handoff, you will export them. The progress of the export will show and they will be available for a temporary period for you to download in MBOX or PST format.
- Audit: This is the section where you can see logs about what has been done in Vault for this specific matter. This is a compliance piece but can also be helpful in confirming your efforts or diligence.
- Reports: This is similar to the audit section for a matter but is on a Vault-wide scale. It’s going to provide details on all matters, regardless of if they are no longer listed.
Tips and Tricks for Google Vault Implementation
- Avoiding deletion of accounts on hold: One of the few things (if not the only thing) that can overrule retention rules is account deletion. Unfortunately, Google sees a deletion as just that. Data will be lost, and matters and holds will not be taken into consideration by Google. If you are using automation, you’ll probably have the same people on holds in your Active Directory system. Setting up a process to exclude these users from normal cleanup is key. Establishing a tracking system for who, what and why people’s accounts are to be held is important. This can be maintained in a Google Sheet with references in account descriptions. This spreadsheet also provides a great place to review with those individuals who are managing the matters with legal counsel and others to determine what has been resolved and can be closed out.
- Conversion of files: Once you export into MBOX or PST, usually you will either hand off the export to legal counsel who will have it in its “raw” form to import into their eDiscovery system or you will need to make it usable for an administrator to process through (such as a principal working a discipline issue). Using a mail client to open these is less than ideal if handing off to an administrator as it will put things into a folder structure. I have found it works well to use a converter tool to make the files into PDF. An example of this is the product Aid4Mail. Redaction tools through a favorite PDF application can then be used if necessary.
- Document your use: Keep good notes and descriptions on matters. I create a new matter for each situation even though the discipline ones all start to be similar and low impact. Because of the high level of access and visibility to everyone’s information you have — including Superintendent and Board Member level email — you want to leave no question on if your actions were legitimate, who requested the information, etc. I’ve found using my email as a paper trail works well. I generally ask that specific requests be emailed to me and I reply back or, when sending the email with the results, I start with “In follow up to our conversation” and provide details of what search terms were used. If you were to be called in by the legal council and asked to explain everything on the Reports Audit page, would you have the breadcrumbs to do so? The names and descriptions of matters are a great way to tie user and requestor information to the matter as well.
Want to dive into the new Vault interface? Or need a better understanding of what Google Vault provides? Knowledge KIT: Vault can provide the overview and training that you need to get up to speed.