[EX2016][TA] Data archiving and the Exchange 2016 transport architecture RRS feed

  • Question

  • Hi,

    I'm a long time Outlook (addin) and Exchange (transport agent) developer and I'm still looking over / exploring the new architecture of 2016 and I have some concerns perhaps someone (perhaps from MS?) can advise on….

    So looking at the new transport system architecture esp. within the categorizer I’m a little concerned that it will be easy for organisations (esp. those who rely on out-of-the-box Exchange 2016 journaling) to be in breach (by accident) of their data retention / archiving laws.

    Unless you're grabbing email with a protocol / SMTP agent or have installed and prioritized a routing agent to be the very first agent in the chain then there’s a chance that messages archived may:

    • Not be seen in original format - This is a requirement by law in many countries but if content conversion has occurred before an agent gets a look at the message then what the agent is seeing is possibly not the original message.
    •  May not be seen with the original recipient (or sender) details - Again, a requirement by law in many countries but if recipient resolution has taken place before an agent sees the message than the original sender and recipient list has possibly been changed (also … with bifurcation some messages may have been split so when looking for a message you could if not vigilant, find only part of the original recipient list).
    • Will not include all emails as some emails will have been removed by the new malware agent.

    So this may not seem like much but if a law requires that a message must archived in "original format" with original sender (searchable i.e. as an index) and recipient values then I’m thinking some organisations won’t be compliant ??

    It would be nice to see Microsoft provide an agent interface specifically for this i.e. a read-only look at all messages before any agents have had a chance to modify them – failing that, I think admins should be aware of that it may take work to be compliant with their data retention laws.

    Thoughts ?

    Scott Quinn | C# developer & messaging specialist (for hire). Contact me at http://au.linkedin.com/in/scottquinn

    • Edited by Scott Quinn Friday, January 8, 2016 5:10 AM typo
    Friday, January 8, 2016 5:09 AM

All replies

  • Hi Scott,

    You raise some very interesting questions, thanks!

    As a German software developer we are bound by the (relatively) strict German archiving laws/regulations.

    Those request (among other things) exactly the points you made, e.g. that emails have to be stored in the original format.

    The method used in many cases relies on journaling. Journaling, however, deploys after the categorizer and thus will only archive e-mails that may have already been modified by the Exchange Server. If I'm not mistaken, RFC822 is the original format, but that's not the format the e-mail will be in after the Exchange Server is done with it (that's TNEF or MSG).

    We've heard from many customers that their old archiving software will not comply with the new German regulations.

    This is why, when developing our e-mail archiving solution, we decided to realize our archive based on an Exchange Server transport agent.

    There's just one question left, one we don't have an answer to: How does one create an e-email archive conforming to strict archiving laws when using Office 365 or Exchange Online?

    Any ideas?

    Best regards,
    Harald Binkle

    Exchange Server Toolbox | SmartPOP2Exchange | SpamAssassin
    JAM Software GmbH
    Am Wissenschaftspark.26 * 54296 Trier * Germany

    Wednesday, January 13, 2016 3:17 PM