UNSW Recordkeeping Policy

• Preamble
• Definitions
• Policy Statement
• Implementation
• Evaluation
• Acknowledgement

1. Preamble

A good recordkeeping program enables the University to account for decisions and actions by providing essential evidence in the form of records. Sound recordkeeping practices are a fundamental basis for accountable and efficient business, effective service delivery and the preservation of the collective memory of the University. The University is concerned with all aspects of its recordkeeping independent of the technological medium.

This policy seeks to ensure that the University’s business is adequately documented through the generation and capture of records, that those records are managed in accordance with best practice and that they are disposed of in an orderly and accountable way. It provides the context for the development of strategy, policy, systems and procedures on recordkeeping at UNSW.

The policy meets the requirements of the State Records Act (1998) and codifies best practice for UNSW.

The policy will be supported by codes of best practice and operational guidelines. A range of training, bulk records storage and consultancy services offered by the Policy Management Unit will provide further guidance and assistance to staff at the practical level.

The University is required to keep records and is aware of the associated benefits of good recordkeeping practices, including:

• support for policy formulation and managerial decision-making;
• meeting legislative and regulatory requirements;
• protection of the rights of members of the University and the interests of the University;
• better performance of business activities in the University;
• protection and support for the University when involved in litigation, including the better management of risks associated with the existence or lack of evidence in University activity;
• support for consistency, continuity and productivity in management and administration;
• documentation of University activities, development and achievements; and
• support for research and development activities.

The University is also aware of poor recordkeeping practices including:

• failure of employees or systems to make records in the first place;
• making records that are inadequate to meet accountability and other University requirements;
• failure to capture records into recordkeeping systems so that they are subject to arbitrary destruction or cannot be found when required;
• failure to identify and retrieve the authoritative version of a record where multiple versions exist;
• failure to maintain records during the time necessary to meet specific accountability requirements;
• failure to assign responsibility for different aspects of recordkeeping at appropriate levels in the organisation;
• penalties under the State Records Act, 1998

2 Definitions

For the purpose of this policy the following definition on recordkeeping taken from Australian Standard AS4390, Records Management, issued February 1996, applies:

"Recordkeeping is the making and maintaining of complete, accurate and reliable evidence of business transactions in the form of recorded information. It is a critical function that is performed through the collective action of employees and systems throughout all organisations."

3 Policy Statement

UNSW must have a recordkeeping program which establishes recordkeeping policies, standards, guidelines and procedures. The framework in which the recordkeeping program exists is defined by the Standard on Records Management Programs.

The records management program should:

• be identifiable from all other existing programs
• be supported by corporate policy
• be planned
• ensure formal responsibility for all aspects of the records management program is appropriately assigned
• be positioned at the most effective level within the organisational structure of the University
• ensure that records management operations and systems are organised according to the needs and structure of the public office, the nature of its business and the prevailing technological and regulatory environments
• be staffed by personnel with appropriate skills
• be implemented throughout the organisation
• be audited regularly

Outcomes to be achieved through the implementation of the records management program include:

• better management of the risks associated with the existence or lack of evidence of organisational activity
• recordkeeping infrastructures which help minimise the risk of mismanagement or corruption
• organisational compliance with the requirements of the State Records Act and enhanced validity and integrity of university records
• support for the objectives of UNSW archival policies and procedures
• minimum performance standards for recordkeeping at UNSW
• the provision of records management services directly to units of the University and assistance for units to manage their records on a devolved basis
• education for staff at all levels about recordkeeping practices and responsibilities
• the retention of information as records where required and the disposal of duplicate or unnecessary material from recordkeeping systems
• improved access to records and improved decision making
• better performance of business activities throughout the University
• better organisational accountability

3.1 Recordkeeping Program

UNSW will establish a recordkeeping program to ensure that University records are adequately created, managed and archived in the course of business and in accordance with the Standard on Full and Accurate Records.

The program will comply with University and other relevant standards (eg AS4390), legislative and recordkeeping requirements and other University policies.

3.2 Responsibilities

The Vice-Chancellor has a duty to ensure that the University complies with the requirements of the State Records Act 1998 and any regulations with respect to State records for which the University is responsible.

Formal responsibility for the records management program will be delegated to an appropriate senior manager who will perform the role of Corporate Records Manager. The role of the Corporate Records Manager is to:

• establish records management policies for the organisation as a whole
• establish corporate standards for recordkeeping and records management
• measure performance of business units and workgroups against those standards
• provide consulting services to business units
• develop corporate electronic records management strategies
• work with other managers of information resources to develop a coherent information architecture across the organisation, and
• work with other accountability stakeholders, including auditors, FOI officers and executive management, to ensure that recordkeeping systems support organisational and public accountability

Recordkeeping is not the province of archivists, records managers or systems administrators alone, but is an essential role of all employees. Users and stakeholders of the recordkeeping system must be aware of legal constraints as well as the need to comply with other UNSW policies and guidelines affecting recordkeeping, particularly those concerning misconduct and maladministration. Responsibility for the effectiveness of the program rests with nominated individuals at all levels in the University and UNSW staff must be aware of their recordkeeping responsibilities within the program and related best practice guidelines.

Maintaining awareness and knowledge of UNSW policies and guidelines is the responsibility of all UNSW staff members. Policies and Guidelines are available on the University website at http://www.policy.unsw.edu.au/

3.3 Electronic Records

Electronic records are records which are communicated and maintained by means of electronic equipment and as such are a part of the recordkeeping program at UNSW. These records are subject to a separate policy on electronic recordkeeping. Best practice guidelines on the management of electronic records including email will be issued periodically.

3.4 Archival Records

The State Records Authority is entitled to the control of records no longer in use for official purposes. The Authority takes control by taking records into its possession or custody or by entering into an agreement, understanding or other arrangement for custody of those records. The University will seek to establish an agreement/understanding with the Authority for the University's archives.

The University will seek accreditation from the Authority for repositories and other facilities provided by the University for the care, management and servicing of State archives and other State records.

Procedures for the transfer of records to the University Archives will be developed.

Records of a continuing value to the University and which have been determined to have administrative, fiscal, legal, evidential or historic value to the University will be retained in the University Archives.

3.5 Policy Management

An integral part of the recordkeeping program at UNSW will be the development of systems to create, capture, codify and disseminate University policy to the University community. Guidelines on the creation and promulgation of policy and version control will be developed.

3.6 Standards, Legislation and Regulations

The recordkeeping program at UNSW is subject to the State Records Act 1998 and the full range of laws applying to the University. These include industrial, occupational health and safety, financial and company, copyright, breach of confidence, defamation, privacy, contempt of court, harassment, vilification and anti-discrimination legislation, the creation of contractual obligations, and criminal laws.

Some laws and agreements require the University to give access to records or the information contained therein to parties outside the UNSW community. These include telecommunications legislation, freedom of information legislation, Evidence Act, other legal rules (eg concerning subpoenas), agreements with external internet suppliers that govern the transmission of e-mail and publication by electronic means.

The electronic recordkeeping system operating on UNSW computers and related telecommunications systems are protected by criminal law provisions in computer crime laws and telecommunications interception laws.

4.Implementation

4.1 Planning

The records management program will have a short-term operational plan and long-term strategic plan. The program should be reflected in the University’s corporate plan as a result area.

4.2 Guidelines

The University will develop best practice guidelines for the management of records in administrative units, faculty and school offices. Guidelines on retention of records, creation and capture of records, and access protocols will be developed.

The University will follow the Guidelines on Normal Administrative Practice prepared by the State Records Authority for the disposal of those records which can be destroyed through normal administrative practice. Where the approval of the State Records Office is required for the destruction of records, the University will seek its approval to either destroy or archive those records, and will comply with Disposal Authorities which may be issued by the State Records Office for the destruction or archiving of records.

4.3 Performance

The Policy Management Unit will monitor the performance of the recordkeeping program.

Regular audits of recordkeeping systems will be carried out to determine compliance with UNSW policies. The coordination of audits will be managed by the Records Administration Section and University Archives, and conducted by system administrators. Annual audits will also be conducted under the auspices of the State Records Office.

4.4 Support

The University recognises the need for ongoing staff development to allow staff to maintain currency with the changing work environment. In keeping with this position, support will be provided to stakeholders in the recordkeeping program and users of the recordkeeping systems through best practice guidelines, additional training and provision of consulting services by the Policy Management Unit.

Support for the development and delivery of recordkeeping systems will be shared by the Registrar’s Division and DIS.

5. Evaluation

The Policy and its implementation will be evaluated regularly. The first review of the policy will take place 12 months from initial implementation.

Stakeholders, including, academic and general University staff, Heads of Budget

Units, Deans and the University Executive will be consulted as part of the evaluation.

Evaluation criteria will include:

• The degree of compliance with the Policy.
• The degree of compliance of the records management program with the State Records Act, 1998.
• The extent to which the recordkeeping program has reduced risk for the University.

The Division of the Registrar and Deputy Principal will actively canvas opinions at intervals and will welcome unsolicited submissions at any time.

For information and assistance contact the Records Manager.

6. Acknowledgement

In developing this Policy the authors have drawn extensively upon the work of the State Records Office. Of significant value were: the State Records Act 1998; Standards on Records Management Programs, Full and Accurate Records, AS4390 Records Management, and the National Records and Archives Competency Standards; and the document Documenting the Future: Policy and Strategies for Electronic Recordkeeping in the New South Wales Public Sector.