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Google true-up: Additional information about records management in Google Vault

To all AITRs:

Google Vault supports agency compliance with the Virginia Public Records Act (VPRA) and can be customized for agency retention policies.


As the April 1 deadline approaches for agencies to decide whether to modify (true-up) Google licenses for the next year, the Virginia Information Technologies Agency (VITA) and the Library of Virginia (LVA) have additional information for you about the optional Google Vault service.


VITA recommends the use of Google Vault as a tool to facilitate agency compliance with certain legal requirements, including the Virginia Freedom of Information Act (FOIA) and the VPRA. Google Vault is a data management tool that lets agency administrators retain, hold, search and export data to support the agency’s records management and e-discovery needs. 


On March 11, LVA sent a message to all agencies expressing concerns regarding agencies’ abilities to comply with the VPRA while using Google Vault. VITA and LVA have worked together over the past month to identify and address many of these concerns. It is correct that the default setting for Google Vault is to retain all emails for an indefinite period of time. This is because VITA sought to avoid unintentional deletion of agency data due to an enterprise-wide default setting. When agencies subscribe to Google Vault and keep this default setting, agencies may subject themselves to the concerns expressed by LVA because the mailboxes would keep every email.


VITA and LVA are working together to develop a standard set of labels with defined retention rules for implementation across the Commonwealth Gmail enterprise by July 1. Labels are a feature within the Gmail mailbox that can be used to categorize and organize emails individually for many purposes including complying with the VPRA. If that implementation cannot be completed by July 1, LVA will make available a guidance document that will assist each agency in requesting the appropriate labels/rules. The request will be made by the agency submitting a support ticket to the VITA Customer Care Center (VCCC) at (866) 637-8482 or vccc@vita.virginia.govAdditional information about the steps needed to customize your Google Vault settings can be found on the messaging G Suite support site.


If you have any questions about Google Vault, please contact your VITA customer account manager. If you have any questions about your agency’s obligations under FOIA, please contact your agency counsel at the Office of the Attorney General or the FOIA Council. For questions regarding compliance with the VPRA, contact your agency’s records management analyst at LVA.