Microsoft 365 has become one of the world’s most accessed products for office collaboration. Jeff Teper, the ‘father of SharePoint’ at Microsoft, tweeted on 27 April 2021 that Teams had 145 million daily active users. (As reported in by the team at Office365ITPros.com.) According to the website ‘Microsoft Office Statistics and Facts (2021) | By the Numbers‘ , Microsoft Teams usage grew 40% during the COVID lockdowns.
Although organisations create, capture and store a range of records using the various Microsoft 365 applications, most records are likely to be created or captured in Exchange mailboxes or SharePoint (including OneDrive).
The volume and range of records has, in many respects, overwhelmed traditional standards-based models that required records (including emails) to be copied to a central electronic document and records management system (EDRMS) or identified and then ‘declared’ as records.
Given the reality of the new paradigm, organisations have tried various ways to manage records in Microsoft 365, including by retaining the EDRMS (for high value records), acquiring third-party products that promise to address the ‘gap’ in recordkeeping functionality, or working with the ‘out of the box’ capability.
Whichever method is chose, records managers need to have a very good understanding of where the records are in Microsoft 365 and how they can be managed. In many cases, leaving and managing them where they were created or captured (‘in place’ management), and using new and emerging capability to leverage the power of AI-based tools is likely to be the future state.
With the above in mind, and regardless of which method you follow, the following are ten points that I think are important to consider when managing records in Microsoft 365.
What are your recordkeeping obligations?
It is perhaps the most obvious question but organisations have sometimes rolled out Microsoft 365 without consideration of their obligations for managing records.
Records provide evidence of business activities and accordingly need to be protected to ensure their authenticity, integrity and reliability as evidence. The most common way of achieving this outcome until now has been to ‘lock’ digital records from change. Is this practical in the digital world? How do you lock Teams chats or stop a new thread in an email exchange? Could the same outcome be achieved by recording all changes and ensuring these are retained?
Records are usually subject to minimum retention requirements and understanding what these are is essential. Where there are minimum retention requirements, records cannot be destroyed before a specific period of time based on a particular trigger or event. These requirements are defined in legislation (sometimes based on statutes of limitation) or, for government agencies, in records disposal authorities or schedules (as shown in the example above).
As a starting point, look at these retention requirements and consider how these will be applied to Teams 1:1 chats, or team chats, or emails still in Exchange mailboxes, or OneDrive content. And then extend this to the content stored in Teams/Group-based SharePoint sites and sites not linked with Microsoft 365 Groups.
Consider also what is required to manage the outcome of retention. Do you need to review records due for destruction? Do you need to keep a record of what was destroyed? For all records?
There may be a requirement to categorise or classify records (especially to group them by context and/or for retention purposes where retention is based on classification). How will this outcome be achieved for Teams chats or emails that remain in Exchange mailboxes, or OneDrive content? What other metadata do you need for records?
Your recordkeeping obligations, in particular records retention requirements, should guide the management of records in Microsoft 365.
Where are the records created or captured in Microsoft 365?
Neither Microsoft 365 nor SharePoint is a dedicated recordkeeping system like an EDRMS (see my post ‘SharePoint is not an EDRMS’). Rather, it is an ecosystem of multiple applications that are used to create, capture, store and manage records.
Most records are likely to be stored in either SharePoint (OneDrive is a SharePoint service) or Exchange mailboxes.
A compliance copy of Teams chats are stored in a hidden folder of Exchange mailboxes. Content stored in the ‘Files’ tab is either stored in SharePoint or (for 1:1 chat) in OneDrive.
Of course, there will be some other records – Yammer conversations, tasks and plans, communication sites, calendar entries, forms and even WhiteBoard sessions. But, more than 95% are stored in Exchange mailboxes or SharePoint/OneDrive.
Knowing your recordkeeping obligations and the location of records are the main starting points. In fact, you can map your recordkeeping obligations (especially metadata and retention) to the location of the records.
Do you control the creation of Teams and SharePoint sites or not?
There two, broadly speaking, two approaches to controlling the creation of Teams and SharePoint sites:
- Yes, we have controls – There is some kind of control or decision ‘gate’ for the creation of Teams and SharePoint sites.
- No, we don’t have controls – End-users can create Teams and SharePoint sites whenever they want. In this case, the points below may not be of much use. You will likely rely on the built-in ‘records management’ capability to manage the records.
If your answer to the question above was ‘No’, then you will probably need third-party products and/or rely heavily on AI-based solutions to manage the records (which is the default Microsoft position).
Map sites and Teams to business functions – don’t mix content
Almost every organisation has a range of business functions. Some of these are common to all or most organisations (e.g., information technology, human resources, financial management, legal, property, etc) while others are ‘core’ (e.g., engineering, manufacturing, research, sales and marketing, etc).
Many organisations are structured around these business functions, and most records retention schedules are based on function (or business function).
If you can map new Teams and SharePoint sites to these functions, this will facilitate the management of records down the track. Mixing content across multiple functions – except where it makes sense to do this, such where there are related but smaller numbers of records in project sites – is going to make it harder to manage the records in the longer term – and more or less the same as letting end-users put whatever they want into a paper box for long-term storage.
A common example where records might be mixed are ‘Corporate Services’ areas that create or capture records across multiple functions, including property, IT, finance and so on. Unless all the records in a Team-based site can be kept for the same period of time, it may be a good idea to separate the records into different sites.
Also keep in mind that some business areas may exist for a long time; having a single (Teams-based) document library that has folders linked to channels may not be the best way to manage records long-term.
The suggestions above don’t take into account Exchange mailboxes, Teams chats or OneDrive accounts because these cannot be mapped to functions.
Naming conventions for sites and teams, and libraries
The main reasons for having naming conventions for SharePoint sites and Teams are:
- It is good practice, to avoid acronyms and other less than useful names.
- To prevent unnecessarily long names that end up creating very long URLs (e.g., ‘https://tenantname.sharepoint.com/sites/ExecutiveCommittee20202021MeetingsHeldDuringLockdownandrecordedviaMSTeamsSeniorManagersOnly‘.) It is important to know the difference between the URL name and the display name.
Ideally, the original names of Teams and SharePoint sites should be restricted to no more than 14 characters so that Document IDs (that have a 12 character prefix) can be the same as, or very close to, the URL name of the site. For example:
- URL (original) name: ExecMgtCtte
- Display name: Organisation Executive Management Committee
- Document ID: EXECMGTCTTE
Aside from the default ‘Documents’ library of every Teams-based site, library names should also be subject to naming conventions and restricted to around 20 characters. There are several reasons for this.
- The first is how they appear in the left hand navigation of a SharePoint site. There isn’t much point having multiple library names that aren’t easily visible (the two examples below have completely different names after ‘Financial Management’).
- The second is that long library names, especially if they include spaces, look terrible if they are sent as a URL. Spaces are replaced by ‘%20’:- h**ps://tenantname.sharepoint.com/sites/CorporateRecords/Financial%20Management%20%20Accounting%20%20Invoices%202021
- The third reason is that it is good practice to have some form of naming conventions.
Ideally, library names should map to the activities that produce the records AND include the year where this is relevant, e.g., ‘Meetings2021’.
There is NO need to repeat words in the tenant or site name – e.g., h**ps://tenantname.sharepoint.com/sites/TenantNameCorporateRecords/TenantNameFinancial%20Management%20%20Accounting%20%20Invoices%202021/Forms/AllItems.aspx
As noted above, this doesn’t apply to the default ‘Documents’ library in Teams-based SharePoint sites (the actual name is ‘Shared%20Documents’).
Metadata and Content Types
For many organisations, the minimum metadata requirements consist of (a) agent (e.g., the person who did something), (b) dates (when they did something) and (c) a unique identifier. That is, who did what and when?
If you need to add more metadata for certain types of records you can really only do this in SharePoint document libraries, including by adding them from the SharePoint Term Store (see below example). It can also be done in Outlook but these metadata terms are not linked with the SharePoint terms.
As for Content Types, do you really need them? SharePoint is made up of multiple Content Types already, including the default ‘Document’ Content Type. It is important to understand how Content Types work in SharePoint before making the assumption that they are required.
In many cases, choice metadata fields can replace the need for Content Types. Custom Content Types may only be needed for specific or high value record types.
Document retention policies and labels
In the first section about recordkeeping obligations, it was noted that most records will be subject to minimum retention requirements. Retention labels and policies are created in the Compliance admin portal of Microsoft 365.
Unfortunately, the current Compliance admin portal provides very little information to show what label or policy was applied where. The only way to do this is to document it yourself. One way to do this is to create a spreadsheet that lists on each row:
- The business function and activity from a File Plan or Business Classification Scheme (e.g., Financial Management – Accounting)
- Each retention class for that function/activity pair, including the reference number
- If that class has been created as a label, what the label name is. If it has been created as a non-label retention policy, what that retention policy name is. (Generally speaking, disposal authority classes don’t refer to Exchange mailboxes, SharePoint sites, MS Teams chats or OneDrive content, so the organisation may need to determine what this minimum retention period should be and how it will manage the retention outcomes).
- (Note, the above can be created in the File Plan section of the Records Management part of the Compliance admin portal, E5 licences only. However, it only documents the above information and does not show where the label has been applied.)
- Where the label has been applied ‘manually’ – to which SharePoint site/document library, Exchange mailbox or OneDrive account. This point may have multiple location references.
- Where the label has been auto-applied through the basic E3 option or, for E5 licences, the document understanding model (DUM) in SharePoint Syntex, or via trainable classifiers.
- When the retention will expire.
- Retention outcome – If a disposition review (E5 only) exists, the records will be destroyed automatically without any record kept, or ‘do nothing’. See also below.
Remember that retention labels and policies apply to individual items (emails, Teams chat, SharePoint or OneDrive content stored in libraries), not to aggregations (e.g., the entire library or site). The aggregation will continue to exist after the content has been destroyed and no ‘stub’ (a record of what used to exist) will remain.
How will you manage retention outcomes?
Generally speaking, Microsoft 365 retention policies destroy records when they are due for destruction unless they are subject to a label that has the disposition review option enabled or the ‘do nothing’ option has been selected.
Organisations need to understand how they will manage these retention outcomes especially as, in most cases, a review process is required. (See ‘Recordkeeping obligations’ above).
Even when retention label have the disposition review option enabled (E5 only), there are two points that need to be understood:
- The ‘disposition review’ interface presents individual records with no context except for the original site URL name. Some additional (default) metadata is now included (from May 2021) but not any added metadata. In most cases, it will be necessary to return to the original library to view the context of the records presented for disposal, and if there are any others.
- If records are destroyed through that review process, only basic metadata is retained about what was destroyed.
Organisations that have an obligation to undertake a full review of records due for disposal will likely need to consider establishing workarounds such as exporting the full set of metadata from a document library and then using that to review whether the content of the library can be destroyed. If approval is granted, that decision should be recorded, along with the metadata extract.
Allow end-users to get on with their work
End-users generally don’t have much interest in the management of records beyond the period of time they are important to them. They want to do whatever they want, whenever they want, using the applications they have available to them.
Collaboration no longer consists of email exchanges and document-based records. Creating control gates for the creation of Teams and sites, and insisting on naming conventions for sites and libraries (and folders) may be interpreted negatively.
There needs to be a fine balance between control and freedom and this can impact the creation, capture and management of records. Some of the ways to minimise the impact of recordkeeping requirements include:
- Enabling Document IDs on every site.
- Creating custom metadata columns on sites or libraries with default values.
- Applying non-label ‘safety net’ retention policies to all workloads. Retention policies (along with the Recycle Bin for 90 days) helps with the recovery of accidentally deleted content.
- Using various communication methods to highlight useful features including sharing (instead of attaching), the Recycle Bin, versioning in SharePoint/OneDrive, and the ability to have a ‘single source of truth’. These features can be used to ‘soften’ the impact of other recordkeeping obligations in some sites.
- Pro-actively monitoring activity across the Microsoft 365 ecosystem, including by monitoring the various dashboards, searches, and audit logs, and responding to events.
- Learning more about the Microsoft Graph Explorer and the potential to use AI-based options to manage records.
Use the system for other recordkeeping purposes
The Microsoft 365 environment can be used for other recordkeeping purposes as well. For example:
- Managing physical records stored offsite in a SharePoint list.
- Keeping a record of records (and SharePoint sites or other systems) that have been destroyed, as well as ongoing destruction review and approval processes.
- Publishing policies and procedures (in a SharePoint site, not necessarily a communication site).
- Communicating information about managing records (communication site).
- Archiving social media content (to Exchange mailboxes).
- Searching for content stored in other locations or systems including File Explorer and Line of Business systems (via connectors).
- Archiving network file share content, where it can be better protected and then subject to retention and disposal outcomes.
- Understanding where records are stored (via dashboards and Power BI reporting).
Records about the world 