Posted in Compliance, Electronic records, Exchange Online, Information Management, Microsoft Teams, Records management, Retention and disposal, Security

Using MS Teams without an Exchange Online mailbox

When people chat in Microsoft Teams (MS Teams), a ‘compliance’ copy of the chat is saved to either personal or (Microsoft 365) Group mailboxes. This copy is subject to retention policies, and can be found and exported via Content Search.

But what happens if there is no Exchange Online mailbox? It seems the chats become inaccessible which could be an issue from a recordkeeping and compliance point of view.

This post explains what happens, and why it may not be a good idea (from a compliance and recordkeeping point of view) not to disable the Exchange Online mailbox option as part of licence provisioning.

Licences and Exchange Online mailboxes

When an end-user is allocated a licence for Microsoft 365, a decision (sometimes incorporated into a script) is made about which of the purchased licences – and apps in those licences – will be assigned to that person.

E1, E3 and E5 licences include ‘Exchange Online’ as an option under ‘Apps’. This option is checked by default (along with many of the other options), but it can be disabled (as shown below).

If the checkbox option is disabled as part of the licence assigning process (not after), the end-user won’t have an Exchange mailbox and so won’t see the Outlook option when they log on to office.com portal. (Note – If they have an on-premise mailbox, that will continue to exist, nothing changes).

Having an Exchange Online mailbox is important if end-users are using MS Teams, because the ‘compliance’ copy of 1:1 chat messages in MS Teams are stored in a hidden folder (/Conversation History/Team Chat) in the Exchange Online mailbox of every participant in the chat. If the mailbox doesn’t exist, those copies aren’t made and so aren’t accessible and may be deleted.

If end-users chat with other end-users who don’t have an Exchange mailbox as shown in the example below, the same thing happen – no compliance copy is kept. The chat remains inaccessible (unless the Global Admins take over the account).

The exchange above, between Roger Bond and Charles, includes some specific key words. As we will see below, these chats cannot be found via a Content Search.

(On a related note, if the ability to create private channels is enabled and they create a private channel and chat there, the chats are also not saved because a compliance copy of private channel chats are stored in the mailboxes of the individual participants.)

Searching for chats when no mailbox exists

As we can see above, the word ‘mosquito’ was contained in the chat messages between Roger and Charles.

Content Searches are carried out via the Compliance portal and are more or less the same as eDiscovery searches in that they are created as cases.

From the Content Search option, a new search is created by clicking on ‘+New Search’, as shown below. The word ‘mosquito’ has been added as a keyword.

We then need to determine where the search will look. In this case the search will look through all the options shown below, including all mailboxes and Teams messages.

When the search was run, the results area shows the words ‘No results found’.

Clicking on ‘Status details’ in the search results, the following information is displayed – ‘0 items’ found. The ‘5 unindexed items’ is unrelated to this search and simply indicates that there are 5 unindexed items.

Double-checking the results

To confirm the results were accurate, another search was conducted where the end-user originally did not have a mailbox, and then was assigned one.

If the end-user didn’t have a mailbox but the other recipient/s of the message did, the Content Search found one copy of the chat message in the mailbox of the other participants. Only one item was found.

When the Exchange Online option was enabled for the end-user who previously did not have a mailbox (so they were now assigned a mailbox), a copy of the chat was found in the mailbox of both participants, as shown in the details below (‘2 items’).

Summary and implications

In summary:

  • If end users chat in the 1:1 area of MS Teams and don’t have an Exchange Online mailbox, no compliance copy of the chat will be saved, and so it will not be found via Content Search.
  • If any of the participants in the 1:1 chat have an Exchange Online mailbox, the chat will appear in the mailboxes of those participants.
  • If all participants in the 1:1 chat have an Exchange Online mailbox, the chat will be found in the mailbox of all participants.

Further to the above:

  • If end users can delete chats (via Teams policies) and don’t have a mailbox, no copy of the chat will exist.
  • If end-users with a mailbox can delete Teams chats, but a retention policy has been applied to the chats, the chats will be retained as per the retention policy (in a hidden folder).

And finally, if you allow private channels, end-users can create private channels in the Organisation Team. The chats in these private channels are usually stored in the personal mailboxes of participants (not the Group mailbox) – so these chats will also be inaccessible and cannot be found via Content Search.

The implications for the above are that, if you need to ensure that personal chat messages can be accessed (from Content Search), then the participants in the chat must have an Exchange Online mailbox.

Further, if you allow deletion of chats but need to be able to recover them for compliance purposes, a retention policy should be applied to Teams 1:1 chat.

Posted in Classification, Compliance, Exchange Online, Information Management, Microsoft Teams, Office 365, Office 365 Groups, Products and applications, Records management, Retention and disposal, SharePoint Online, Training and education

Planning for records retention in Office 365

Office 365 is sometimes referred to as an ‘ecosystem’. In theory this means that records could be stored anywhere across that ecosystem.

Unlike the ‘old’ on-premise world of standalone servers for each Microsoft application (Exchange, SharePoint, Skype) – and where specific retention policies could apply (including the Exchange Messaging Records Management MRM policy), the various elements that make up Office 365 are interconnected.

The most obvious example of this interconnectivity is Microsoft Teams which stores chat content in Exchange and provides access to content stored in both SharePoint (primarily the SharePoint site of the linked Office 365 Group) and OneDrive, and has links to other elements such as Planner.

Records continue to be created and kept in the various applications but retention policies are set centrally and can apply to any or all of the content across the ecosystem.

Managing records in Office 365, and applying retention rules to those records, requires an understanding of at least the key parts of the ecosystem – Exchange, Teams, SharePoint and OneDrive and how they interrelate, and from there establishing a plan for the implementation of retention.

What types of records are created in Office 365?

Records are defined as ‘evidence of business activity’ and are often associated with some form of metadata.

Evidence of business activity is an overarching term that can include:

  • Emails
  • Calendars
  • Documents and notebooks (in the sense of text on a page)
  • Plans, including both project plans and architectural plans and diagrams
  • Images/photographs and video
  • Chat and/or messages
  • Conversations (audio and/or video based)
  • Social media posts

All digital records contain some form of metadata, usually displayed as ‘Properties’.

Where are the records stored in Office 365?

Most records created organisations using Office 365 are likely to be created or stored in the following parts of the ecosystem:

  • Exchange/Outlook – for emails and calendars.
  • SharePoint and OneDrive – for documents and notebooks (in the sense of text on a page), plans, images/photographs and video.
  • Stream – for audio and video recordings.
  • MS Teams – for chat and/or messages, conversations (audio and/or video based). Note that 1:1 chats are stored in a hidden folder of the Exchange mailbox of the end-user/s participating in the chat, while Teams channel chat is stored in a hidden folder of the linked Office 365 Group mailbox.
  • Yammer – for (internal) social media posts.

It is also possible to import and archive certain external content such as Twitter tweets and Facebook content in Office 365.

The diagram below provides a overview of the main Office 365 applications and locations where records are created or stored. Under SharePoint, the term ‘Sites’ refers to all types of SharePoint sites, including those associated with Office 365 Groups. Libraries are shown separately because of the potential to apply a retention policy to a library – see below.

O365WheretheRecordsare

Note also that this diagram does not include network file shares (NFS) as the assumption is made that (a) NFS content will be migrated to SharePoint and the NFS made read only, and (b) all new content that would previously have been stored on the NFS is instead saved either to OneDrive for Business (for ‘personal’ or working documents) or SharePoint only.

Creating a plan to manage records retention across Office 365

In previous posts I have recommended that organisations implementing Office 365 have the following:

  • A basic architecture design model for SharePoint sites, including SharePoint sites linked with Office 365 Groups (and Teams in MS Teams).
  • A plan for creating and applying retention policies across the ecosystem.

Because SharePoint is the most likely location for records to be stored (aside from Exchange mailboxes and OneDrive accounts), there should be at least one retention policy for every SharePoint site (or group of sites), as well as policies for specific document libraries if the retention for the content in those libraries may be different from the retention on the overall site.

For example, a ‘Management’ site may contain a range of general content as well as specific content that needs to be retained for longer. 

  • The site can be covered by a single implicit retention policy of (say) 7 years. This policy will delete content in the background, based on date created or data modified. 
  • The document library where specific types of records with longer or different retention requirements are stored may have one or more explicit label-based policies applied to those libraries. This content will be retained while the rest of the site content is deleted via the first policy.

Structure of a retention plan for records in Office 365

A basic plan for creating and applying retention policies might look something like the following:

  • User mailboxes – one ‘general’ (implicit) retention policy for all mailboxes (say, 7 years after creation) and another more specific retention policy for specific mailboxes that require longer retention.
  • SharePoint sites – multiple (implicit) retention policies targeting one or more sites.
  • SharePoint libraries – multiple (explicit) label-based retention policies that are applied manually. These policies will usually a retention policy that is longer than any implicit retention policy as any implicit site policy will prevent the deletion of content before it reaches the end of that retention period.
  • Office 365 Groups (includes the associated mailbox and SharePoint site) – one ‘general’ (implicit) retention policy. See also below.
  • Teams channel chat – one ‘general’ (implicit) retention policy. Note that this content is stored in a special folder of the Office 365 Group mailbox.
  • 1:1 chat – one ‘general’ (implicit) retention policy. This content is stored in a special folder of the participant mailboxes.
  • OneDrive documents – one ‘general’ (implicit) retention policy for all ODfB accounts, plus the configuration of retention after the account is inactive.

At a high level, the retention policy plan might look something like the following – ‘implicit’ policies are shown in yellow, SharePoint document libraries may be subject to ‘explicit’, label-based policies. The ‘+7 years’ for OneDrive relates to inactive accounts, a setting set in the OneDrive Admin portal.

O365WheretheRecordsare2

Regarding Microsoft Office 365 Groups, Microsoft notes the following on this page about managing retention in Office 365:

To retain content for a Microsoft 365 group, you need to use the Microsoft 365 groups location. Even though an Microsoft 365 group has an Exchange mailbox, a retention policy that includes the entire Exchange location won’t include content in Microsoft 365 group mailboxes. A retention policy applied to an Microsoft 365 group includes both the group mailbox and site. A retention policy applied to an Microsoft 365 group protects the resources created by an Microsoft 365 group, which would include Microsoft Teams.

The actual plan should contain more detail and included as part of other recordkeeping documentation (perhaps stored on a ‘Records Management’ SharePoint site). The plan should include details about (a) where the policies have been applied and (b) the expected outcomes or actions for the policies, including automatic deletion or disposition review (for document libraries).

Keep in mind that, unless the organisation decides to acquire this option, there is no default backup for content in Office 365 – once a record had been deleted, it is gone forever and there may be no record of this beyond 90 days.

Posted in Electronic records, Exchange Online, Governance, Information Management, Microsoft Teams, Office 365, Office 365 Groups, Products and applications, Records management, Retention and disposal, SharePoint Online

Setting up SharePoint Online to manage records (as part of Office 365) – Part 1/3

This is the first of three posts that describe the main elements involved in setting up SharePoint Online to manage records.

This post focuses on the recordkeeping related elements in the Office 365 and Compliance admin portals:

  • Office 365 Admin – Licences, Roles and AD Groups (including Office 365 Groups)
  • Compliance Admin – Retention labels and policies (and some more options)

The second post focuses on SharePoint Online Admin centre configuration.

The third and last post focuses on SharePoint site collection provisioning and configuration to manage records

Office 365 admin center

O365AdminPortalUsersRolesGroups

The main elements that impact on the management of records in Office 365 are Users (for licences), Roles and Groups, as can be seen in the screenshot.

Users – licencing and applications

Organisations that acquire Office 365 will generally have the relevant licences required (a) to set up and administer SharePoint Online, and (b) for users to use it (and OneDrive for Business).

This post assumes that organisations will have at least an E3 licence which includes SharePoint for end users, visible as an app when they log on to https://office.com, along with all other applications included in the licence, for example Exchange/Outlook, OneDrive for Business, MS Teams and so on. End users with access to these items will also be able to download and use the equivalent mobile device apps.

Roles

The three key roles that impact on the management of records in SharePoint are as follows:

Global Admin (GA)

Global Admins:

  • Are responsible for managing the entire Office 365 environment. This includes creating new Groups (Security Groups, Distribution Lists and Office 365 Groups).
  • Are responsible for assigning key roles, including the SharePoint Administrator and Compliance Administrator (and other roles).
  • May have responsibility for, and/or the skills and knowledge required to set up and administer SharePoint Online and create new sites for the organisation.
  • May also be able to create and publish retention policies in the Compliance admin portal.

Note – Organisations that outsource the administration of Office 365 should always have at least one GA account to access the tenant if ever required. If they don’t have a log on, they should have or acquire a very good understanding of the access and privileges afforded to the outsourced company. 

SharePoint Administrator (SP Admin)

The SP Admin role will usually be a ‘system’ role that is responsible for managing the SharePoint environment, including OneDrive for Business. As noted above, a GA with the right skills can also manage the SharePoint environment. 

Generally speaking, SharePoint Administrators will focus on the technical and configuration aspects of SharePoint. They are not usually responsible for confirugint SharePoint to manage records, managing records, or creating and publishing retention policies. This role usually falls to either the GA or Compliance Administrator.

Compliance Administrator

The Compliance Admin role is responsible, among other things, for the creation and publishing of retention labels and policies in the Compliance Admin portal. A GA can perform this role (along with all other roles) if required.

Compliance Admins will usually be responsible for disposition reviews linked with retention labels, and be involved in eDiscovery cases.

The Compliance Admin can search and view the audit logs for all activity across Office 365 and can carry out broad content searches with the ability to export the content of those searches. As this role is relatively powerful, it should be limited to key senior individuals in the organisation.

Office 365 and Security Groups

Office 365 Groups are Azure/Exchange objects just like Security Groups and Distribution Lists. Accordingly, there should be controls around their creation, including naming conventions.

As every Office 365 Group has an associated SharePoint site, organisations should consider restricting the ability for end users to create Office 365 Groups, and only allowing Global Admins and members of a Security Group to do this. Neither SharePoint Admins or Compliance Admins would normally create AD Groups.

If the ability to create Office 365 Groups is not restricted, an Office 365 Group will be created with an associated SharePoint site whenever:

  • A new Team is created in MS Teams.
  • A new Group is created from Outlook.
  • A new Yammer Group/Community is created.

External sharing

The ability to share content externally from SharePoint and OneDrive for Business is controlled from the Office 365 Admin portal. This is a global setting that can be disabled by the Global Admins if required.

It is assumed, for the purpose of this post, that that setting is enabled to allow external sharing.

Note that enabling external sharing at the global level does not enable it globally for all SharePoint sites; sites must be individually modified to allow it.

Compliance Admin

The Compliance admin portal can be accessed by the GAs and also the Compliance Admins (and some other roles). It is where retention labels and policies are created (in line with the corporate file plan/BCS) and published, and disposition reviews are undertaken, so records managers need access.

Other options in this section that relate to the management of records include the audit logs, content search and eDiscovery.

Retention policies

Retention policies may be applied to all the key workloads in Office 365 where records are stored:

  • Exchange Online
  • SharePoint Online
  • OneDrive for Business
  • MS Teams
  • Office 365 Groups

Retention labels published as retention policies are visible to and can be applied by end-users. Generally these are more likely to be applied at the document library level rather than to individual records, or in mailboxes or OneDrive for Business.

Retention policies that are not based on labels may be applied to all, or parts of, the four workloads listed above. For example, they may be applied to all, or a sub-set of Exchange mailboxes or OneDrive for Business accounts, or SharePoint sites. Retention policies may also be applied to individual or team chats in MS Teams.

Organisations seeking to use retention policies in Office 365 should understand how these work, have a plan for their implementation, and keep track of what has been applied where.

  • Retention policies for all mailboxes or all ODfB accounts may replace previous on-premise backup options for those workloads. It is unlikely that end-users will (or will want to) apply retention labels published as policies to individual emails or folders in mailboxes or OneDrive.
  • SharePoint sites are likely to have either or a combination of explicit and implicit/invisible retention policies. Implicit, single period retention policies may be more suitable for entire smaller, short-lived SharePoint sites. Explicit retention policies may be more suitable for the diverse range of content on more complex and long-lasting sites. Some sites may be created and populated around the need to keep a particular type of record for a long period of time – for example, employee records.

Audit logs

The Office 365 audit logs are found in the Compliance admin portal. For an E3 licence, the content in the logs is stored for 90 days.

As audit logs are an important element in keeping records, organisations may need to consider ways to retain this content for a longer period.

Note – SharePoint document libraries record the name of anyone who edited a document (and also previous versions), but they don’t record the name of anyone who simply viewed it. SharePoint lists also include audit trails, making it possible to track changes in individual rows of a list.

Content searches and eDiscovery

The Compliance admin portal provides two similar options to search for content across Office 365. Both the Content Search and eDiscovery options provide the ability to establish a ‘case’ that can be run more than once.

The eDiscovery option provides the added ability to put content on Legal Hold. Advanced eDiscovery is available with a higher licence.

Next

Click on the links below to read the next two posts:

  • SharePoint Online Admin centre configuration.
  • SharePoint site collection provisioning and configuration to manage records.
Posted in Compliance, Electronic records, Exchange Online, Information Management, Microsoft Teams, Office 365 Groups, Products and applications, Records management, Retention and disposal, SharePoint Online

Understanding and applying retention policies to content in MS Teams

This post highlights the need to understand how retention works in MS Teams, why it may be related to how long you keep emails (including for backup purposes), and why you need to consider all the elements that make up an Office 365 Group when considering how – and how long – to retain content in MS Teams.

Overview of retention in MS Teams

If you are unfamiliar with how retention works with MS Teams, these two related sites provide very useful detail.

overview_of_security_and_compliance_in_microsoft_teams_image1
Image from the first link above – Security Compliance Overview

The quote below from the second link is relevant to this post:

‘Teams chats are stored in a hidden SubstrateHolds folder in the mailbox of each user in the chat, and Teams channel messages are stored in a hidden SubstratesHolds folder in the group mailbox for a team. Teams uses an Azure-powered chat service that also stores this data, and by default this service stores the data forever. With a Teams retention policy, when you delete data, the data is permanently deleted from both the Exchange mailboxes and the underlying chat service.’

and

‘Teams chats and channel messages aren’t affected by retention policies applied to user or group mailboxes in the Exchange email or Office 365 groups locations. Even though Teams chats and channel messages are stored in Exchange, they’re only affected by retention policies applied to the Teams locations.’

In summary:

  • One-to-one chat in MS Teams is stored in a hidden folder of the mailbox of each user in the chat. Documents shared in those chats are stored in the OneDrive for Business of the person who shared it.
  • Group chat in Team channels is stored in a hidden folder of the mailbox of the associated Office 365 Group – and also in an Azure chat service. Documents are stored in the Office 365 Group’s SharePoint site (other SharePoint site libraries may also be linked in a channel).

Another quote from the same post:

‘In many cases, organizations consider private chat data as more of a liability than channel messages, which are typically more project-related conversations.’

Teams content is kept in mailboxes, retention may be similar

Typically, in the on-premise past, organisations will have backed up their Exchange mailboxes (and possibly also enabled journaling, to capture emails), for disaster recovery, ‘archiving’ and investigations. Unless a decision is made to invest in cloud back-ups, Office 365 retention policies may also be applied to Exchange mailboxes, effectively replacing the need to back them up. Retention policies applied to Exchange mailboxes don’t affect the teams chat folder.

Organisations should probably apply the same retention period to both emails and Teams chats as they do to email mailbox backups now. That is, if mailboxes are typically kept for 7 – 10 years after the person leaves the organisation, then keep the Teams chats for the same period.

Note that, even if a poster deletes an item (if that option is enabled), it will still be retained if there is a retention policy.

Suggestions for retention in MS Teams

As there can be different retention requirements, depending on the subject matter, here are some suggestions for retention:

  • One-to-one chat is like email, you will never know everything that is being said or sent. So a single retention policy that mirrors email would be appropriate.
  • Teams chat is more likely to be about the subject of the Team, which is based on an Office 365 Group, its own mailbox, and has a SharePoint site. In this case, you could consider a retention policy applied to all Office 365 Groups or specific Groups – for example ‘Project Groups’, then ensure that the retention policy or policies cover all aspects of the Office 365 Group (mailbox, team chat, SharePoint).
  • If all the records relating to a particular subject matter (including email, chat and documents) must be retained for 25 years, then you need to understand all the options.

It underscores the need to plan carefully for retention management for all the key workloads in Office 365.

Posted in Compliance, Exchange Online, Governance, Information Management, Office 365, Office 365 Groups, OneDrive for Business, Records management, Retention and disposal, SharePoint Online

Managing the outcomes of records retention in Office 365

The retention of records in Exchange Online (EXO), SharePoint Online (SPO), OneDrive for Business (ODfB) and Office 365 (O365) groups can be achieved through the application of retention labels published in the O365 Security and Compliance admin portal.

This post describes:

  • How retention labels work (in summary), including the ‘per record’ rather than the container/aggregation retention model.
  • What happens to content in Office 365 when a retention period expires.
  • The options and actions that may influence the way retention labels/policies are configured, where and how they are applied, and the outcomes required.

The post highlights the need for information and records managers to be involved in all aspects of governance, site architecture and design, and decisions around specific settings and configuration, as well as being assigned specific roles, when Office 365 is implemented.

A quick summary of how O365 retention labels work

Records retention policies in O365 are based on ‘retention labels’ that are created in the O365 Security and Compliance admin portal under the ‘Classifications’ section. Multiple labels can be applied to a single policy.

  • Click this link to read Microsoft’s detailed guidance on retention labels.
  • Click this link to read Microsoft’s detailed guidance on retention policies.

Retention outcomes

Each retention label defines one of three potential outcomes at the end of the retention period, if retention is enabled, ‘keep forever’ is not selected, and the label is not used to classify the content as a record*:

  • The content will be automatically deleted. If the content is in SharePoint, it will first be sent to the Recycle Bin, from which it can be recovered within 90 days.
    • This option may be suitable for certain types of low value records.
  • A disposition review will be triggered to notify specific people. As with the previous point, SharePoint content will be sent to the Recycle Bin if a decision is made to delete it.
    • This option will require additional, human-intervention actions, as described below, if standard records management disposal review processes are followed.
  • Nothing.

Triggers

The date when the above action will occur is based on one of four triggers:

  • Date created
  • Date last modified
  • When labelled applied
  • A event. The ‘out of the box’ (OOTB) event types are:
    • Employee activity. (Processes related to hiring, performance and termination of an employee)
    • Expiration or termination of contracts and agreements.
    • Product lifetime. (Processes relating to last manufacturing date of products).
    • A new event can also be added.
    • See this post for Microsoft guidance on event-driven retention.

An additional alternative option is available: ‘Don’t retain the content, just delete it if it’s older than n days/months/years.’ This is similar to the automatic deletion option above and may be suitable for certain types of records. 

Declaring content as records

* The option to classify or ‘declare’ content as a record is not discussed further as relates to the way records are managed in the US. Microsoft’s guidance on labels notes that: ‘At a high level, records management means that: (a) Important content is classified as a record by users. (b) A record can’t be modified or deleted. (c) Records are finally disposed of after their stated lifetime is past.’ The standard on records management, ISO 15489, defines a record as ‘evidence of business activities, often (but not exclusively) in the form of a document or object, in any form’. This means that anything can be a record. The record may continue to be modified throughout its life. 

When do retention labels become active?

Retention labels become active only when they are published. As part of the publishing process, a decision must be made if the label will apply to all (a single option) or selected parts of the O365 ecosystem:

  • The Exchange Online (EXO) mailboxes of all or specific recipients, or excluding specific recipients.
  • All or specific SharePoint Online (SPO) sites, or excluding specific sites.
  • All or specific OneDrive for Business (ODfB) accounts, or excluding specific accounts.
  • All or specific O365 Groups, or excluding specific groups. Note that content in Microsoft Teams (MS Teams) is included in the O365 Groups options that include both the SharePoint content and email/Teams chat content.

Auto-applying retention labels

Both the retention label and policy sections include the ability to auto-apply a retention policy if certain conditions are met.

  • Sensitive information types. These are the same types that appear in the Data Loss Prevention (DLP) section, for example ‘Financial data’ or ‘Privacy data’.
  • Specific keywords.
  • Content types and metadata (E5 licences only). See this post by Joanne Klein for a description of these options.

The ability of the first two options to accurately identify content and apply a retention policy should be investigated before they are relied on.

When do retention policies start working

According to Microsoft’s guidance Overview of Retention Labels:

If you publish retention labels to SharePoint or OneDrive, it can take one day for those retention labels to appear for end users. In addition, if you publish retention labels to Exchange, it can take 7 days for those retention labels to appear for end users, and the mailbox needs to contain at least 10 MB of data.

  • In EXO, the default MRM policy needs to be removed before the new policy applies.
  • In ODfB, the policy is available to be manually applied on folders or documents. It does not automatically apply to content.
  • In SPO, the policy can be applied to document libraries or documents. To avoid removing the ability for users to legitimately need to delete documents in an active library it is recommended to apply the policy after the document library has ceased to be active.
  • Content in Office 365 Groups is covered by either the EXO (for email/teams chat content) or the SPO policy (applied to libraries).

Retention labels apply to individual records within aggregations

Records labels can be applied to aggregations of records (an entire email mailbox or folder, a SharePoint library or list, an ODfB account, O365 Groups) or individual records. However, the disposal process targets individual records (e.g., individual emails, single documents in SharePoint libraries, individual list items). 

That is, even when all the individual records are disposed of, the parent aggregation remains in place without any indication that the records previously stored in it (sometimes known as a ‘stub’) have been destroyed. 

This outcome has implications for the way the outcome of a retention label is set. It requires a choice between (a) delete automatically without review or (b) review before delete.

The latter option is made complicated by the requirement to review individual documents, including potentially in the original container (document library in SPO) and export metadata relating to those records if a record of the deletion is to be retained.

What happens when records reach the end of their retention period

As noted above, the outcome at the end of the retention period (trigger date + n days/months/years) will depend on the settings on the label.

  • Where the label was applied (EXO mailbox, SPO library or list, ODfB folder or document, O365 Group)
  • Whether the records would be deleted automatically or be subject to a disposition review.

If the records are to be deleted automatically:

  • SPO and ODfB records will be sent to the site/ODfB Recycle Bin for 90 days
  • EXO emails will be moved to a ‘Cleanup’ area for 14 days, before permanent deletion.
  • Aside from the audit logs (which by default only go back 90 days), no other record will be kept of the destroyed records.

If the records are subject to a disposition review, an email is sent to the person nominated. When that person clicks on the link in the email they are taken directly to the ‘Dispositions’ sub-section of the Records Management section of the O365 Security and Compliance centre.

It is arguable that retention policies with disposition review should not be applied to ODfB content as this will require the reviewer to review all the content that has been labelled by a user in their ODfB account.

  • For more information about this subject see this Microsoft page ‘Overview of disposition reviews‘. Microsoft note, on that page ‘To get access to the Disposition page, reviewers must be members of the Disposition Management role and the View-Only Audit Logs role. We recommend creating a new role group called Disposition Reviewers, adding these two roles to that role group, and then adding members to the role group.’

The dispositions dashboard shows the number of records that are pending disposition against each retention policy label:

O365_RM_DispositionsDashboard

Pending disposition tab

When the reviewer clicks on one of the retention policies listed, the following view opens for records ‘Pending disposition’:

O365_Dispositions_Pending

An important point to note here is that records are listed individually, not in logical aggregations or collections. It is possible however to use the Search option on the left to filter by author (emails) or SharePoint site and/or site library. It is also possible to export the details (which does not include any unique metadata applied to documents in SharePoint libraries).

All the records displayed may then be selected and a ‘Finalise decision’ dialogue box appears with the following options:

  • Dispose of the records.
  • Extend the retention.
  • Re-label the records.

Disposed items tab

The Dispositions dashboard includes a ‘Disposed items’ tab.

Microsoft note that this tab ‘… shows dispositions [that] were approved for deletion during a disposition review and are now in the process of being permanently deleted. Items that had a different retention label applied or their retention period extended as part of a review won’t appear here.’

Importantly, once records are permanently deleted, they no longer appear in the ‘Disposed Items’ tab. This means that no record will be kept of the records that were destroyed.

Shortcomings of the O365 dispositions/disposal model for records stored in SPO

Only individual records appear, not all the items in a document library

If the retention outcome is based on the ‘created’ or ‘last modified’ date, individual records in SPO document libraries will start to appear as soon as they reach the retention end date. The reviewer may need (or want) to view the original library, which they can identify from the link is in the dispositions review pane.

Retention policies prevent deletion

As a retention label prevents the deletion of content by users, and this may put them off using SharePoint, it is recommended that retention in SPO document libraries be based on when the label was applied NOT when it was created or last modified. This will help to ensure that all documents appear in the disposition review area at the same time.

Event based triggers may not be suitable for disposition review

If the retention outcome is based on an event, or is auto applied and a disposition review is required, those records will appear randomly when the event is triggered. It could be difficult for records managers to decide the disposal outcome in this way without referring back to the library.

The dispositions review pane does not display the original metadata

The  dispositions review pane displays only very basic metadata from the original library. Again, the reviewer may need to view the original library, export the metadata and store that in a secure location. Note that the exported metadata includes the URL of each original record including the library name.

The document library remains even when all contained records are destroyed

If the reviewer chooses to dispose of the records listed, only the content of the library (the individual documents stored in it) is deleted, not the actual library itself. No record (e.g., a ‘stub’ of the deleted item) is kept in the library of the deleted content.

The ‘Disposed items’ tab only shows records being destroyed

The ‘Disposed items’ tab only shows records in the process of being destroyed. It does not keep a record of what was destroyed. Records managers will need to retain the metadata of what was destroyed, when, based on what disposal authority, and with whose approval.

Dispositions really only provides a ‘heads up’ for further action

The Dispositions process may be instead used as a form of ‘heads up’ that records are starting to be due for disposal in a document library. This would allow the records managers (who should be Site Collection administrators) to review the library, export the complete set of metadata, and decide if the entire library can be deleted since it is no longer required.

Conclusions

Retention labels in O365 are an effective way of managing the retention and disposal of records in that environment, subject to the following points.

Email

Emails will likely continue to be managed as complete aggregations of records – the mailbox. Users cannot be expected to create logical groupings and apply individual retention labels to those records.

Organisational records policies may mandate specific timeframes for the retention of email (e.g., 1 year), while HR/IT security policies may mandate that whole mailboxes are retained for a period of time after employees leave. It is important to understand the difference between these two models

Options to automatically transfer emails to SharePoint document libraries via rules may be possible using Flow but these rely on individual users to set up.

Consideration should instead be given to using O365 Group mailboxes, rather than individual personal mailboxes, for specific work related matters. For example, ‘Customer Complaints’, or ‘XYZ Project’.

OneDrive for Business Accounts

ODfB accounts may be covered by two forms of retention:

  • Retention labels that apply to all ODfB accounts while the account is active. These must be manually applied by users.
  • A separate retention period set for ODfB accounts after a user leaves the organisation.

If there is a requirement to prevent the deletion of content by a user from their ODfB account, the better way to achieve this is using an eDiscovery case with Legal Hold applied.

SharePoint Online

As most records will be stored in SharePoint document libraries (including Office 365 Group-based SP libraries), multiple retention labels will be required to address different types of content or retention requirements.

Careful consideration should be given to whether records can be deleted automatically at the end of the retention period or should be subject to disposition review, noting that the automatic deletion provides no opportunity to capture the metadata of the records.

The ‘auto-apply’ or event-based retention option should be used sparingly to avoid a trickle of records for disposal – unless there is enough trust that these can be accurately marked and deleted without review.

Shortcomings in the disposition review process support the following decisions for SharePoint Online content:

  • The number of retention labels should be minimised to avoid a very long drop-down menu when a label is applied. If current record retention or disposal authorities contain a lot of classes, some of these could potential be combined into a single class (e.g., ‘Company Records – 7 years’), while the site name and document library name should provide some context to the content to ‘map’ back to the original classes.
  • Retention labels should be applied when document libraries (or lists) become inactive as this will avoid conflict with users who want to delete content and also ensure that documents are ready for disposition review at the same time.
  • Retention labels applied to SPO document libraries should include the disposition review option unless a ‘delete only’ label is considered suitable for certain document libraries that clearly contain working documents or Redundant, Outdated and Trivial (ROT) content.
  • Records managers should review the content of all or most original SPO document libraries, and export the metadata of those libraries for storage in a separate location (such as an ‘archives’ site), or in the original library with the retention label changed to ‘Never Delete’. The original document library can then be deleted.
Posted in Compliance, Electronic records, Exchange Online, Governance, Information Management, Products and applications, Records management, Retention and disposal

Records retention in Exchange Online

Retention policies created as labels in the classification section of  the Office 365 (O365) Security & Compliance admin centre can be applied to content in Exchange Online (EXO) mailboxes.

It may not be possible to apply more than one Office 365 retention policy to EXO mailboxes because, unless the mailbox is dedicated to a specific subject (for example, ‘Customer Complaints’), or using a dedicated Office 365 Group’s mailbox:

  • Emails generally contain content about multiple subjects.
  • The way the content is categorised in mailboxes , including through the use of rules and/or folders, varies between users.
  • The retention and disposal of records relies largely on the ability to assign retention policies to categories or groups of records, not individual records.
  • Organisational policies may require all user emails to be kept (‘archived’) for a period of time after they leave the organisation.

Unless emails are moved to a different storage location such as SharePoint, it may be necessary to continue apply a single, but shorter, O365 retention policy to mailboxes.

Exchange Messaging Records Management (MRM) policies

Until Office 365 retention policies appeared as an option, MRM policies applied in EXO were likely based on an organisational business requirement to keep the mailboxes (and other content) of departed users for potential legal or compliance reasons.

MRM policies in EXO are found under the ‘Compliance Management’ section of the EXO admin portal.

EXO_Compliance_RetentionMenu.JPG

When this section is opened, the following message may appear:

EXO_Retention_Message

The default MRM policy has the following options. These may be modified, or additional retention tags created, as required.

EXO_Default_MRMPolicySettingsA.JPG

If the default MRM policies have not been changed (by the Exchange administrator), the default policy/ies will apply. This means that users can use the ‘Assign Policy’ option on folders and emails to decide how long they should be kept.

Emails that are deleted before a backup is made may not be retained.

Some organisations may decide to retain all emails and the mailboxes of departed users ‘forever’. They can do this by removing all the options except ‘Never Delete’.

How O365 Retention Policies are applied to Exchange

Retention labels created in Office 365 can be used to manage the retention of emails, including (to some degree) emails that have content that meets certain pre-defined conditions.

Retention labels are created in the Office 365 Security and Compliance admin portal under the ‘Classifications’ section. This section has three options:

  • Labels. This section is used to create both ‘Sensitivity’ and ‘Retention’ labels. There is also an ‘Auto-apply’ option in the Retention section.
  • Label policies. This section partially duplicates the options in the previous option (except the ‘Create’ option), and lists the labels that have been published.
  • Sensitive info types.

Auto-apply, as its name suggests, auto-applies an existing label based on certain conditions. The conditions are as follows:

  • Apply label to content that contains sensitive info. The sensitive info types are pre-defined options for (a) Financial data (e.g., credit card numbers), (b) Medical and Health (e.g., predefined health records), (c) Privacy (e.g., personal and sensitive information. There is also the option to create a Custom setting.
  • Apply label to content that contains specific words or phrases, or properties. This option works by looking for specific words or phrases.

New labels must be published before they appear or apply anywhere in Office 365.

During the publish process, policies must specify where (in the ‘Locations’ section) the policy is to be applied.

The default option is ‘All locations. Includes content in Exchange email, Office 365 groups, OneDrive and SharePoint documents.’ Alternatively, the policy may be set to specific locations including

  • The Exchange mailboxes of all or specific recipients, or excluding specific recipients.
  • All or specific SharePoint sites, or exluding specific sites.
  • All or specific OneDrive accounts, or excluding specific accounts.
  • All or specific Office 365 Groups, or excluding specific groups.

Note that content in Microsoft Teams is included in the Office 365 Groups options which includes both the SharePoint content and email/Teams chat content.

Mixing MRM and O365 retention policies – maybe not a good idea

If the default MRM policies are not removed, any O365 retention policy that is applied to EXO will appear in the list of retention tags under the default MRM policy, as can be seen in the screenshot below which shows three options in addition to the original MRM policies: ‘Temporary records – 7 days’, ‘Financial Records’, and ‘Company records – 7 years’. If nothing is changed in the environment, these policies can be applied by users to folders and emails. 

O365_MRM_ExchangeRetentionoptions

If the organisation has decided to remove all retention tags except ‘Never Delete’ and a new O365 retention policy is applied to EXO, the ‘Never Delete’ option will prevail and the O365 policy will not work.

Accordingly, careful consideration needs to be given to the creation of O365 retention policies that may be applied to EXO records.

Should user mailboxes be kept ‘forever’?

Many IT departments keep user mailboxes of departed staff (and most other content on the network) for a long time, usually on backups, ‘just in case’ they may be required for legal or compliance requirements, including investigations into misconduct.

Recent personal experience with subpoenas for mailboxes of departed staff indicates that 10 years is likely to be the maximum retention requirement for these types of records. There may be a case to keep certain individual mailboxes for much longer, which the O365 policy allows for.

 

What happens when emails reach the end of their O365 retention policy period?

O365 retention policies define how long records are to be retained before they are either deleted or ready for review (via the Records Management – Dispositions section of the O365 Security and Compliance admin portal).

The following options define what happens when retention is enabled:

  • Retain the content (a) for a specific period (n days/months/years) or (b) forever. Option (b) is the same as the MRM policy ‘Never Delete’.
    • Action to be taken at the end of the period (except ‘forever’): (a) Delete the content automatically, (b) Trigger a disposition review (i.e., notify specific people), or (c) Do nothing, leave the content as is.
  • Don’t retain the content, just delete it if it’s older than n days/months/years.
  • Retain or delete the content based on: (a) When it was created, (b) When it was last modified, (c) When the label was applied, (d) based on an event.

The three actions above define the options for records managers:

  • Allow the emails to be deleted automatically. This is possibly the easiest and most efficient option but it will result in the deletion of any emails when they reach the end of the retention period – if they are kept in Exchange. Importantly, if a specific period of time (e.g., 7 years) is set for email retention, this could start to delete the emails of users who are still with the organisation after that period expires. This fact may affect the retention period that is set. 
  • Trigger a disposition review – see below. This option would be onerous to implement; it would take a lot of effort to review the individual emails of a departed user as part of a disposition review. It would, however, allow for selective review by using the ‘filter’ option in the Dispositions area.
  • Do nothing. This option may be useful for specific types of records, but not emails.

Disposition Reviews

Emails that are subject to a disposition review will appear in the Records Management – Dispositions section of the O365 Security and Compliance centre. Note that the ‘Type’ must be changed from ‘Documents’ to ‘Emails’ to see the emails that are due for disposal. As noted above, while it is possible to filter by user to review the emails, this process could be quite onerous.

O365_EXO_DispositionsA.JPG

Summary

The nature of email makes it almost impossible to categorise them into categories that map to different retention and disposal policies.

Most mailboxes will be subject to a single retention policy.

Office 365 retention policies can and probably should replace the default EXO MRM policies that govern the retention of emails.

Retaining emails in the mailboxes they are stored in ‘forever’ is not a practical retention model. 10 years is a reasonable maximum period, but exceptions may be required.

If O365 retention policies replace EXO MRM policies, records managers need to specify (a) how long emails need to be kept for and (b) whether they can simply be deleted when they reach the end of the retention period or need to be reviewed before deletion.

References

‘Overview of Retention Policies’ https://docs.microsoft.com/en-au/office365/securitycompliance/retention-policies (accessed 9 August 2019)

‘Set up an archive and deletion policy for mailboxes in your Office 365 organization’
https://docs.microsoft.com/en-au/office365/securitycompliance/set-up-an-archive-and-deletion-policy-for-mailboxes (accessed 6 August 2019)