A-Z Policy Listing

RECORDS MANAGEMENT POLICY

Date first approved:

26 September 2006

Date of effect:

26 September 2006

Date last amended:
(refer to Version Control Table)

10 August 2018

Date of Next Review:

1 April 2023

First Approved by:

University Council

Custodian title & e-mail address:

Senior Manager, Records Management

Records Management Support Portal

Records Management Helpdesk: extension 5059

Author:

Senior Manager, Records Management

Governance and Legal Division

Responsible Division & Unit:

Records Management Unit

Governance and Legal Division

Supporting documents, procedures & forms:

Business Continuity Management Policy

Collection Development Policy

Cyber Security Policy

Privacy Policy

Records Management Framework & Resources

Records Management Security Workgroups

Records Management Support Portal

UOW Records Disposal Register

Relevant Legislation &

External Documents:

State Records Act 1998 (NSW)

State Records Regulation 2015
Privacy and Personal Information Protection Act 1998

Health Records and Information Privacy Act 2002 (NSW)

Government Information (Public Access) Act 2009 (NSW)

Independent Commission Against Corruption Act 1988 (NSW)

Public Interest Disclosures Act 1994 (NSW)

University of Wollongong By Law (2005)

Standard 12 on Records Management

General Authorities in their current issue as published by the State Archives and Records Authority of New South Wales as relevant to UOW records:

Audience:

Public

Contents

1 Purpose of Policy

    1. The University of Wollongong (UOW) is required to comply with the State Records Act 1998 (NSW) as well as regulations, standards, policies and guidelines issued under it. Good records management supports compliance requirements under legislative frameworks, meets UOW business needs as well as the interests of its stakeholders.

    2. UOW demonstrates compliance with the State Records Act 1998 (NSW) and other legislative requirements, implementing and continuously improving good records management practices across all areas and functions of UOW, through its Records Management Framework.

    3. The purpose of this Policy is to outline responsibilities and compliance controls regarding records management, with the objectives of:

    a. ensuring compliance with the State Records Act 1998 (NSW);

    b. contributing to the development and continuous improvement of efficient and effective records management at UOW;

    c. ensuring that full and accurate records are created, captured and managed for all UOW business activities and business transactions;

    d. ensuring that records are appropriately made available to eligible stakeholders; and

    e. ensuring that disposal of records is undertaken in a controlled and compliant manner.

2 Definitions

Word/Term

Definition

Appraisal

A crucial records management process of evaluating business activities to determine which records need to be captured and how long records need to be kept to meet business needs, organisational accountability requirements and to ensure compliance.

Authenticity of Records

An authentic record has:

Reliability – Sufficient and appropriate metadata (descriptive information) is associated with a record

Integrity - Records are complete and protected against unauthorised access within a system

Usability – Authorised users can locate, access and use records across time and in changing technological environments

Business Activity

Any action that contributes towards UOW’s decision-making process or service delivery, including all UOW’s functions, processes, activities and transactions.

Capture

See ‘Records Capture’

Classification of Records

Records are classified according to the business functions and activities, which generate the records. This functional approach to classification means that classification can be used for a range of records management purposes, including appraisal and disposal, storage and security requirements, and setting user permissions, as well as providing a basis for titling and indexing.

Controlled Entities

The controlled entities of the University of Wollongong are UOW Global Enterprises Group of Companies and UOW Pulse Limited.

Disposal

See ‘Records Disposal’

Duplicate Records

More than one copy of the same record.

Ephemeral records

Records of little value that only need to be kept for a short period of time. Records that are ephemeral have no continuing value and, generally, are only needed for a few hours or a few days.

Facilitative records

Records of little value and of a routine instructional nature that are used to further some activity. Most records that are facilitative have no continuing value and – generally - are only needed for a few hours or a few days. They are not required to be kept for ongoing business or accountability purposes.

General Authority (GA)

A formal instrument approved and published by the Board of the State Archives and Records Authority of NSW that:

Identifies records that are required to be kept indefinitely (“as State Archives”)

Defines mandatory minimum retention periods for each record class

Provides instructions for the disposal of records after mandatory minimum retention periods have been met

Imaging

Imaging is the representation or reproduction of an object's form; especially a visual representation, i.e. the formation of an image. Imaging is used to create electronic copies of physical records, often hard copies that are scanned.

Managing Records

Any action relating to the life cycle of a record, including creation, capture, storage, indexing, retrieval, transfer, preservation, and disposal.

Metadata

A set of data that describes and gives information about other data. This information is used to describe the context and structure of records and their management through time. Metadata help to facilitate identification, findability, retention and disposal of records. A record without metadata is impossible to prove as authentic and is therefore incomplete.

Migration

The transfer of records from one hardware or software configuration to another or from one generation of technology to another. Migration is at times necessary for digital records due to technological obsolescence or media degradation.

Nominated Senior Officer (NSO)

The NSO has overall responsibility for UOW’s Records Management Framework, Records Management Systems and Records Management Compliance. The NSO at UOW is the Chief Administrative Officer or Nominee.

Record(s)

Any documents or other sources of information compiled, recorded or stored in written form or on film, or by electronic process, or in any other manner or by any other means. They are a part of and result from business activities and transactions and provide evidence of those activities. Records may include, but are not limited to, any staff member’s paper based records, emails, or electronic documents stored at UOW or on UOW equipment that:

    • correctly reflects what was done, communicated or decided, and that can be trusted as a true representation of the transactions or events which it documents

    • is authentic, i.e. usable, reliable and of integrity

    • is complete and protected against unauthorised access, alteration, deletion or loss

    • is understandable, complete, retrievable and available through time

    • Personal and / or private documents that are not part of official UOW business are not considered to be records under this policy.

Records Capture

Processes involved in the capture of records include

Registration

Classification

Indexing

These processes happen within the RMS and support users in finding, controlling and managing records.

Records Disposal

A range of processes associated with implementing appraisal decisions. They include permanently removing records from UOW’s control through an approved process, such as archiving, deleting or destruction or the transfer of custody or ownership of records.

Records Management Framework

This policy, together with the processes, people and systems required to manage records in accordance with the State Records Act 1998 (NSW).

Records Management Unit (RMU)

Unit of the Governance and Legal Division responsible for maintaining and supporting Records Management at UOW.

Retention Period

The minimum periods of time the University is required to keep records under the State Records Act 1998 (NSW), which are outlined in “General Authorities”.

Retention Review Committee (RRC)

A committee formally constituted by the Chief Administrative Officer, UOW’s Nominated Senior Officer for Records Management with particular responsibility for advice and recommendations regarding the retention of University records outside the scope of the mandated requirements under the State Records Act 1998 (NSW) and delegated legislation.

State Archives

For the purpose of this policy, this is a classification relating to records that are required to be kept indefinitely as NSW state records in accordance with the relevant General Authority and the State Records Act 1998 (NSW).

Units

All UOW Faculties, Divisions, Departments and Units

UOW Archives

A unit within the UOW Library that manages, preserves and provides access to physical and digital archival materials relating to:

    • the corporate and social history of UOW

    • materials of historical significance to the Illawarra region

    • materials of relevance to our teaching and research

3 Application & Scope

  • 1. This Policy applies to all records that are part of and relate to business activities that are created during business activities at UOW. They include, but are not limited to, student records, research records, staff records, legal records, governance records, records in relation to buildings and maintenance as well as financial records.
  • 2. This Policy applies to all business activities of UOW, including such records of business activities of UOW’s Controlled Entities, conducted both within and outside of Australia where such records fall within the control of UOW.
  • 3. This Policy applies to the creation, capture, location, access, use, management, storage, retrieval and disposal of records by all UOW staff.
  • 4. This Policy replaces all previous Records Management Policies and takes precedence over local Records Management policies, guidelines and practices.

4 Policy Principles

  • 1. UOW is required to establish a Records Management Program that complies with the requirements of the State Records Act 1998 (NSW) and associated regulations, standards, policies and guidelines. UOW’s program is known as the Records Management Framework.
  • 2. The Records Management Framework must be implemented in all Units across UOW to support the University’s compliance obligations. Business activities may be subject to internal / external monitoring and auditing to ensure ongoing compliance.
  • 3. Records management requirements should be embedded within policies, procedures and processes across all areas of the University.

5 Ownership, custody and control of UOW Records

General

  • 1. All records created by staff, or received by staff, in the course of UOW’s operations and activities, are owned by UOW unless otherwise specified under contract. Regardless of the ownership of records, any record created, accessed and or stored by UOW must be managed pursuant to this Policy.

    2. Control of records identified to be kept indefinitely (“as State Archives”) under the General Authorities issued under the State Records Act 1998 (NSW) will eventually transfer into the custody of the State Archives and Records Authority of NSW.

    3. The custody of physical “State Archive” records will remain with the University Archives, within the UOW Library, in line with the distributed management agreement with the State Archives and Records Authority of NSW and the UOW Collection Development Policy. UOW will retain both custody and control of any other historical records assessed as having continuing value.

Business Systems and Databases

    4. As a general rule, all UOW records must be stored and classified within the RMS for UOW to fulfil its obligations under the State Records Act 1998 (NSW) and related UOW policy documents. This is because a dedicated RMS provides efficient and effective management of records and because other business systems and databases are typically not designed to facilitate the classification and compliant disposal of records.

    5. Where records are stored and classified in business systems other than the RMS such storage must be approved by the NSO or nominee.

    6. The system owner must ensure the system satisfies NSW State Records requirements and the Business Continuity Management Policy through appropriate backup and disaster recovery practices.

    7. Before Units implement new or upgrade existing business systems, records management requirements must be considered and documented at the business requirements gathering stage. RMU must be consulted and be given the opportunity to provide input into those requirements.

    8. RMU will review any new business system to gather the level of its records management capability as well as the new system’s ability to interact with the RMS.

    9. RMU must be notified of existing databases / business systems that capture records that are not held in the RMS. Units using databases / business systems that store records need to consult with RMU to ensure they meet NSW State Records requirements.

    10. Where records are scheduled for system migration, RMU must be involved in this process to ensure that the outcomes of the migration will be compliant with NSW State Records requirements.

6 Creation and Capture of Records

Records Creation and Capture

  • 1. Records that are not facilitative or ephemeral should be created at commencement of a business activity or transaction and checked-in to the RMS or as soon as practicable. This will ensure a full, authentic and accurate record is captured and maintained within the RMS. Examples include, but are not limited to:

        • is written, received or used in the course of UOW business dealings;

        • approves or authorises UOW actions;

        • signifies a policy change or development;

        • commits UOW to an arrangement or business deal;

        • contains advice or provides guidance for people inside or outside UOW;

        • requires an action by UOW;

        • if an email, is likely to be reviewed or audited.

    2. Records are classified using metadata in order to describe records, people and business activities in a suitable amount of detail to ensure:

    a. better information accessibility and improved security;

    b. consistent and improved records management; and

    c. greater accountability in business operations.

      Metadata requirements and naming convention for UOW records are managed by the RMU and published on the RMU intranet page. RMS users are responsible to ensure that records have sufficient metadata assigned and comply with appropriate naming conventions when records are checked-in to RMS.

    3. To preserve the integrity of UOW’s records, no additions or alterations should be made to an existing record. If additions or alterations are required, a subsequent record should be created and added using consistent metadata and naming conventions.

    4. Where records are not checked-in to the RMS on creation they need to be stored by the responsible Unit in accordance with the requirements outlined in this policy until they are checked-in to RMS.

    5. Physical records need to be stored securely and in appropriate environmental conditions to avoid damage and deterioration (Refer Section 7 of this Policy)

Records not requiring Retention

    6. The State Records Act 1998 (NSW) and the State Records Regulation 2015 (NSW) set out the types of records created as part of normal administrative practice (NAP). Certain types of records created under NAP are not required to be retained. Records created in accordance with NAP that do not need to be retained include:

    a. facilitative or ephemeral records including appointment diaries, calendars, 'with compliments' slips, personal emails and emails in personal or shared drives, emails that have been captured in the RMS;

    b. working papers (papers, background notes and reference materials that are used to prepare or complete other records) that are primarily facilitative where the retention of the final version of the record is sufficient to meet record-keeping requirements and that are not required to be retained in order to account for policies, decisions, reasons and actions or not required to function as evidence. For example: calculations, rough notes, statistics and figures;

    c. drafts that are of a routine nature, not intended for further use or reference – whether in paper or electronic form – including reports, correspondence, addresses, speeches and planning documents that contain minor edits for grammar and spelling and do not contain significant or substantial changes or annotations;

    d. copies of material retained for reference purposes only; and

    e. published or promotional material. For example: promotional material received by the University or external publications to which the University has no input (e.g. newspaper or journal articles).

    7. More detailed information and advice about retention of records is available through RMU. If in doubt staff members are encouraged to refer to the Records Management unit resources on the intranet or contact the Records Management Support Portal.

Imaging

    8. Imaging, involves the creation of electronic copies of records (for example by scanning hard copy document).

    9. Where records have been imaged, in most circumstances, provided authentic, complete and accessible copies of the records are made; the imaged documents are kept in accordance with this policy, and the source materials are not excluded under General Authority 45, the original records can be disposed of.

    10. Business Units are encouraged to consult with RMU to ensure imaging and disposal of original records is done in a compliant manner.

Duplication

    11. Duplication of records should be avoided where possible.

    12. Records should be created and stored only once and should be shared between appropriate parties in a secure and controlled manner.

    13. Where records are shared and different business units hold duplicate records, the responsibility for maintaining the record lies with the faculty, division or business unit that owns the business transaction associated with those records, e.g. staff records are the responsibility of the Human Resources Division and student administrative records are the responsibility of the Student Services Division.

Creation and Capture of Emails

    14. Email correspondence is an official record if it documents a business activity of UOW. The record must be stored within the RMS including all previous threads and relevant attachments to ensure it is a full and accurate record.

    15. Storing emails within email folders on a UOW computer or on a shared drive does not satisfy the requirements of the State Records Act.

7 Physical Storage and Security

  • 1. Physical records must be stored in a suitable and secure area. Suitability for record keeping means the area at a minimum should be ventilated, free of mould and free of any form of pest.
  • 2. Records should be kept off the floor to avoid inundation by water. Access should only be provided to authorised staff.
  • 3. Where records are stored in an area used by an individual employee they should be made available to authorised users at all times.
  • 4. Confidential records must be kept in a secure work area, for example in a locked filing cabinet within a work area that has access controls on entrances.
  • 5. Physical records identified as State or UOW historical archives should be stored with the UOW Archives or stored in other secure areas in consultation with RMU and the UOW Archivist.
  • 6. Physical records stored off-site, away from UOW campuses must be stored in appropriate suitable and secure conditions in bespoke record-keeping facilities, preferably that have been assessed by RMU.
  • 7. Off–site storage in any other location, e.g. with self-storage providers, is not permitted due to heightened risks of damage, deterioration, unauthorised access or loss of records.
  • 8. RMU is happy to provide assistance and advice in regard to the appropriate storage and security of physical records.

8 Access to Records

Security Classification

  • 1. To ensure compliance with privacy obligations and to maintain the appropriate level of security for UOW information, an access level is assigned to records when they are checked-in to the RMS.
  • 2. The access level is assigned to approved work groups that are linked to UOW Divisions, Faculties and Business Units.
  • 3. Users are assigned to appropriate work groups as approved by the areas appropriate officer under the Delegations of Authority Policy.
  • 4. A list of available workgroups and a list of approvers for those work groups can be obtained from the Records Management Security Workgroups page on the intranet.

Access to Records by UOW staff

    5. In accordance with the UOW Privacy Policy, Staff should only access records for which they have a legitimate business need in the capacity of their employment and for which they have approved access.

    6. Access to electronic records kept in RMS relating to a work group that a staff member does not belong to requires authorisation from the relevant workgroup approver as outlined on the Records Management Intranet Site. The same principle applies for physical records.

    7. Members of the Senior Executive, the Legal Services Unit and the Records Management Unit are considered authorised users where access to specific records across the University’s operations is required for the purpose of their roles.

Access to Records by external parties

    8. Access to records that are not made publically available by the University is not to be provided to parties external to UOW unless authorised by the Manager, Information Compliance and permissible under a UOW policy document or where required by law.

    9. Where a request to access a UOW record is made that is not covered by a UOW delegation, policy document or legal instrument, the staff member should contact the Manager, Information Compliance in the Legal Services Unit.

    10. Provision of original physical records should be avoided where possible and copies provided.

Access to Records via Subpoena or Warrant

    11. Requests for access to records via subpoena or legal warrant is to be managed by the Legal Services Unit within the Governance and Legal Division.

    12. If a subpoena or legal warrant addressed to UOW is received by a Faculty or Unit, it should immediately be referred to the Legal Services Unit.

    13. No information should be supplied in reply to the subpoena or legal warrant without the approval of Legal Services Unit.

    14. Any information or record under request via subpoena or legal warrant must not be destroyed until the Legal Services Unit has approved to do so.

Access to Records via the Government Information (Public Access) Act 2009 (NSW) (GIPA Act)

    15. Access to records via application under GIPA legislation is managed by UOW’s Manager Information Compliance, Legal Services Unit, Governance and Legal Division.

    16. Any requests for information under the GIPA legislation should be directed to the Manager, Information Compliance in the Legal Services Unit, Governance and Legal Division.

9 Disposal of Records

Retention

  • 1. Records must be retained for the minimum legal retention periods as specified in the relevant General Authority issued under the State Records Act 1998 (NSW).
  • 2. Any additional retention requirements specified or implied in other legislation must also be satisfied.
  • 3. Longer than legally required retention periods may apply to some records based on UOW business needs. Such additional retention periods will be approved the Nominated Senior Officer (the Chief Administrative Officer) on the recommendation of the Retention Review Committee.

Archival Records

    4. Decisions relating to the permanent retention of records as “State Archives” will be based on an appraisal of the records in line with relevant General Authorities issued under the State Records Act 1998 (NSW).

    5. Decisions relating to the permanent retention of other records as UOW historical archives will be based on an appraisal of the records in line with the Collection Development Policy and other relevant policies and guidelines together with an assessment of their continuing value to UOW.

    6. Decisions pertaining to State Archives records should be directed to RMU.

    7. Decisions pertaining to UOW Historical Archives should be directed to the UOW Archivist.

Disposal

    8. UOW Records will be disposed of according to the State Records Act 1998 (NSW) and as outlined in the relevant General Authorities and any additional UOW retention periods.

    9. RMU is responsible for the disposal of records or referral of records to the UOW Archives.

    10. No records must be disposed of without completion of a UOW Records Disposal Register and approval by the Nominated Senior Officer or nominee.

    11. Records documenting disposal activities must be retained by RMU within the RMS.

    12. Any records related to current litigation or formal access requests must be retained, regardless of any retention schedule or approved disposal process. The relevant unit must notify RMU as soon as it is aware that records may be or are required, and the records will be removed from any disposal process. Those records may only be returned to a disposal process with approval of the Nominated Senior Officer or nominee.

    13. Where, for a particular record, the responsible unit cannot be identified, has been merged or has otherwise ceased to exist, the current member of the Senior Executive under whose portfolio the business function now falls will be considered to be the appropriate delegate for the purposes of disposal authorisation. Where this cannot be determined, the role will default to the Nominated Senior Officer (or nominee).

    14. Disposal of all records, electronic and physical, must be undertaken in a controlled and secure manner in accordance with the General Authorities published by NSW State Archives and Records.

10 Roles & Responsibilities

Nominated Senior Officer (NSO)

  • 1. The Nominated Senior Officer for Records Management at UOW is the Chief Administrative Officer. The Nominated Senior Officer (or nominee) is responsible for:

    a. UOW’s compliant records management in accordance with the State Records Act 1998 (NSW)

    b. Implementing and supporting a culture of strong records management compliance throughout UOW; and

    c. Approving retention periods longer than the legislative retention period upon recommendation of the Retention Review Committee

Executive Dean of Faculty / Director of Division

    2. The Executive Dean of Faculty / Director of Division / is responsible for:

    a. Compliant records management for their respective areas in accordance with the State Records Act 1998 (NSW);

    b. Implementing and supporting a culture of strong records management compliance;

    c. Promoting active cooperation of staff with RMU; and

    d. Providing approval of record disposal via the UOW Records Disposal Register.

    e. Ensuring any business systems in their portfolios are compliant with records management requirements and that RMU is consulted in the development of new systems to ensure records management compliance through integration or interaction with RMS.

Records Management Unit (RMU)

    3. The Records Management Unit (RMU) is responsible for the coordination and maintenance of UOW’s Records Management Framework, including:

    a. management and support of UOW’s RMS;

    b. development, review and communication of records management policies and associated procedures and standards;

    c. provision of records management training and education programs;

    d. provision of advice on records management practices and issues (including off-site storage assessment and business systems records compliance review) as part of an advisory service to Units across UOW;

    e. provision of advice and execution of record disposal activities in accordance with General Authorities issued under the State Records Act 1998 (NSW); and

    f. monitor the performance of Business Units against records management policies, and processes.

Faculties and Schools, Divisions and Units

    4. Each unit is responsible for:

    a. ensuring that they have implemented the requirements of the Records Management Framework across their Units;

    b. consulting with RMU in regards to records management requirements before implementing new business systems;

    c. complying with this policy;

    d. ensuring the sustainability of their records management practices, and

    e. managing their records from creation to disposal in cooperation with RMU.

    5. The following Records Management Contact roles should be appropriately delegated:

    a. A Primary Records Management Contact (“RM Champion”) is a Faculty or Unit representative and is the point of contact for RMU in relation to Faculty-wide or Unit-wide records management activities and issues.

    b. The Secondary Records Contact is a “super user” with broader RMS access. This staff member is the main contact for internal staff and is a contact point with RMU for specific unit level activities.

    6. Local Records Contacts are staff members assigned responsibility at a Business Unit level for day-to-day records management activities, such as record creation.

    a. RMU must be informed when Record Management Contacts change. Training for new Records Contacts and refresher sessions can be organised through RMU.

    b. Where a restructure occurs, RMU should be consulted as soon as practical to plan and facilitate the transition of records between Business Units, as well as liaise regarding the transfer of relevant historical records to the UOW Archives as required.

UOW Staff

    7. All UOW staff have a responsibility to be aware of and comply with the Records Management Framework and their responsibilities under it. This includes attending training or completing online training as required by UOW.

    8. Staff are responsible for ensuring that records supporting and documenting their business activities are created, captured and accessed in accordance with the provisions of this Policy.

    9. Staff must also be aware of and comply with data protection principles, privacy, and confidentiality requirements specified in relevant legislation and the University Code of Conduct.

11 Version Control and Change History

Version Control

Date Effective

Approved By

Amendment

1

26 September 2006

Administrative Committee

Entire policy redrafted to improve structure and ensure that compliance controls were explicitly outlined.

2

6 May 2009

Vice-Principal (Administration)

Migrated to UOW Policy Template as per Policy Directory Refresh.

3

18 February 2010

Vice-Principal (Administration)

Policy reviewed and minor editorial corrections made. Policy Custodian changed. New Review Date identified.

4

22 July 2012

Administrative Committee

Complete redraft to provide clarity in UOW Records Management Program requirements.

5

4 November 2013

Chief Administrative Officer

Updated to reflect title change from University Librarian to Director, Library Services.

6

15 September 2015

Vice-Chancellor

Scheduled Review: updated nomenclature, minor clarifications.

7

18 August 2017

Council

Consequential amendment as a result of the rescission of the University Archives Policy and its replacement by the Collection Development Policy.

8

10 August 2018

University Council

Scheduled Major Review including updated definitions

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