Idaho

E-mail messages that are “informal communications between an employee and her supervisor, unrelated to personnel administration” are not public records under the open records law. “Rather, it is their relation to legitimate public interest that makes them a public record.” Cowles Publishing Corp. v. Kootenai Co. Board of County Commissioners, 144 Idaho 259, 159 P.3d 896 (2007).

Electronic messages are legally treated the same as other records (paper documents, etc) in terms of retention and back-up.