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Last updated: : 31 August 2007

Note for file: A report on recordkeeping in the Australian Public Service

Chapter 2. Focusing on the right records

Not all records should be kept indefinitely

While the number of records generated within the APS is growing exponentially, only a small number of highly significant records will ever be considered to be records to be retained by the National Archives. These would include things such as the records of Cabinet deliberations and Ministerial decisions, legal documents, major reports and significant policy papers.

Every agency can use the following to dispose of records:

• normal administrative practice (NAP) which can be used for many low-value records (such as short-term and transitory records like background notes, office messages, meeting requests and low-value emails)
• general disposal authorities, such as the Administrative Functions Disposal Authority (AFDA), that cover functions and records common to every Commonwealth agency
• records disposal authorities issued to individual agencies covering their agency specific records.

Agencies are permitted to dispose of short-term or transitory records (such as background notes, office messages, meeting requests, and drafts of reports and briefs which do not reflect significant policy changes) as part of normal administrative practice. Destruction under normal administrative practice (NAP) usually occurs because the records are duplicated, unimportant or for short-term use only and cover both paper and electronic records. The National Archive’s more detailed advice on normal administrative practice (NAP) can be found at <http://www.naa.gov.au>.

Many records have to be retained by agencies for defined periods because of their ongoing business need. These may include financial and personnel records or records relating to travel and entitlements. General disposal authorities and records disposal authorities are used to document how long these records should be kept and to authorise their disposal.

Records of administrative functions commonly performed by most agencies are authorised by the National Archives for disposal under the Administrative Functions Disposal Authority (AFDA).

The retention or destruction of other useful or important records (such as policy, strategy, government advice) is determined by records authorities approved by the National Archives. These authorities also document and identify the records that need to be kept indefinitely as national archives.

Records that should be corporately managed

No APS agency can corporately manage every Commonwealth record, especially with the exponential increases in electronic communications. No agency ever tried to do this even when all records were in hard copy.

Corporate management means active management by the agency’s official corporate recordkeeping systems. Official systems typically have higher levels of records management functionality (e.g. paper file creation systems/corporate electronic document management systems) than devolved storage systems controlled by individuals (e.g. diaries, notebooks, personal email folders and hard drives, CDs, DVDs, flash drives).

If an employee, for example, prints off an important email and places it on a file issued by the agency’s file registry, which has recorded that file as being in that person’s custody, the record is being corporately managed. Similarly, if the employee transferred the email into an agency’s digital recordkeeping system such as an Electronic Document Management System (EDMS), it is also being corporately managed.

A record is not being corporately managed if it is being kept on a computer hard drive, personal email folder or even the agency’s email system.

The difference between a corporately managed record and one being managed personally by an APS employee is most apparent when the APS employee leaves the agency. Records committed to corporate storage systems are not lost to the agency when an employee leaves, whereas records kept on informal systems are likely to be lost unless they are transferred into the agency’s corporate recordkeeping system/s before the employee leaves.

There appears to be an ill-informed assumption that if employees can find their own emails/documents when they need them, then that is sufficient. This is not consistent with the APS Values (see Chapter 3) or good administrative practice.

Not all emails need to be retained. The same rules that apply to paper records apply to emails, and judgements need to be made about their content, scarcity and context. Since email has largely taken the place of what previously may have been informal telephone conversations or corridor meetings, the great majority of emails will not have great value to the Commonwealth.

However, emails that relate to the business of an agency are Commonwealth records and need to be kept according to the business needs which should be articulated in policies and procedures of each agency. Given the largely informal nature of email, it is important that APS employees judge the value or importance of an email, and transfer it as quickly as possible where necessary to the corporate recordkeeping system.

Personal emails that do not relate to Commonwealth business are not Commonwealth records and should not be kept.

The use of personal notebooks should be limited to making initial or contemporaneous personal notes of meetings, for later transcription into a more formal record if required. Even if they are not considered useful or important records, personal notes taken in the course of APS employment are still Commonwealth records, and therefore potentially subject to disclosure under the Freedom of Information Act 1982.

In some agencies, and the Management Advisory Committee considers this best practice, departing employees are required to certify that they have transferred all records relating to their official duties from personal recordkeeping systems to corporate recordkeeping systems. This requires departing employees to ensure that any important or useful records kept on email, diaries or personal folders are available for the purposes of the Commonwealth. Other Commonwealth records that are not useful, whether they are held on corporate or personal systems, should be appropriately disposed of in accordance with the Archives Act (see the section on ‘Disposing of low-value Commonwealth records’ below).

Approach to corporate management of records

The proposed approach to corporate management of records is similar to how agencies manage any other valuable asset, from stationery to computers, and cabcharge vouchers to Commonwealth vehicles.

Agencies focus their corporate attention on what is valuable and high risk, and we trust the professionalism of APS employees to responsibly assume custody of the rest, subject to appropriate guidance and direction.

By adopting such an approach, agencies can focus their limited resources on those records they must manage and will also be able to define their corporate recordkeeping assets in qualitative, as well as quantitative, terms.

This approach is entirely consistent with advice provided by the National Archives:

Not all records are kept indefinitely. There are pragmatic reasons for this, and community attitudes to recordkeeping also play a part.

The Commonwealth creates vast quantities of records every year, and there is strong pressure to economise in the areas of records storage, maintenance and servicing. Most records are in formats that deteriorate over time or require constant vigilance to keep accessible. Attempting to preserve them all indefinitely would be prohibitively expensive and futile under current technological and resource constraints.

Just as important is the prevailing view, within the community, that not all records need to be retained; that it is acceptable or desirable to dispose of records when they are no longer required. This view is reflected in standard business practice and at all levels of public administration in Australia. The Government’s funding for the management of Commonwealth records is premised on the assumption that only a very small proportion of all records created will be retained indefinitely.

In this environment the Archives operates on the general principle that Commonwealth records should not be retained longer than reasonably required.³

Judgement and commonsense are required to determine, on objective grounds, whether a particular Commonwealth record is useful or important, and should be filed in a corporate recordkeeping system so that it is readily available to the whole agency.

The value of a record is not dictated by its format, but rather its content (e.g. whether it is trivial or important) its scarcity (e.g. whether it is unique, or one of many copies), and its context or the considerations that gave rise to its creation (e.g. if it is to meet a legal obligation, the context alone suggests it is a high-value record, as it is evidence of that obligation being met).

Integrating recordkeeping systems with the disposal framework is important in ensuring records that do not need to be retained can be readily identified. The National Archives’ Administrative Functions Disposal Authority (AFDA) lists functions and activities common to all APS agencies, and outlines the basis on which records relating to these activities should be retained, and those which could be disposed of after a period. It allows, for example, the disposal of an agency’s principal accounting records (such as journals and ledgers) seven years after the last action.

Ensuring that these classifications (even at their highest level) are used in the creation and classification of files can significantly streamline the process of disposal.

Better practice example

The following flow chart, based on a model developed by the Department of Education, Science and Training (DEST), asks the simple question: Is the record of value? In other words, is the record useful or important, or is there an ongoing business need for it to be retained? This might include, for example, financial records required under the Financial Management and Accountability Act 1997.

Figure 2: Based on DEST Management Instructions for Corporate Administrative Records describing the difference between records of short-term and lasting value⁴

 

More details are in the complete DEST case study at <http://www.apsc.gov.au/mac>. This diagram is underpinned by DEST policies and procedures.

Disposing of low-value Commonwealth records

It is up to agencies to determine appropriate internal policies relating to keeping and disposing of low-value records. A recordkeeping policy provides an agency with the practical guidance it needs to achieve the strategic objectives documented in its information management framework.

In establishing such policies, agencies must consider the extent to which low-value records use up valuable space on Commonwealth IT systems, having regard to the obligation to use Commonwealth IT systems in the most efficient, effective and ethical manner.⁵

Good administrative practice dictates that APS employees should be able to dispose of low-value records as soon as their usefulness expires, and dispose of them as simply and efficiently as possible. Disposal of some material within this category in accordance with each agency’s own policies and procedures is allowed by the Archives Act 1983 as a disposal under a ‘normal administrative practice’.⁶

Continuing to keep low-value records in an agency impinges on efficiency and effectiveness and unnecessarily complicates the task of finding the more valuable or useful records. Unmanaged low-value records will grow rapidly in number, and it is not practical or desirable to manage them in the way we must manage more valuable records.

Only a relatively small percentage of emails (including ‘email threads’), unsolicited correspondence, drafts, paper notes and SMS text messages received in the course of APS employment will have lasting value, and will therefore need to be kept in an agency’s corporate recordkeeping system so they are readily available for the purposes of a Commonwealth institution.

Examples of documents that could be expected to be disposed of under normal administrative practice include:

• conversational, personal or other unimportant emails which record no significant information, action or decision
• most draft documents and working papers which do not record a significant change of policy/direction
• informal notes/notepads/diaries, where any significant information has been properly transferred to the agency’s corporate recordkeeping systems
• superfluous copies of any Commonwealth record.

The National Archives has developed further guidance on what can be disposed of under normal administrative practice, available at <http://www.naa.gov.au>.

Low-value records of the type described above, unless and until disposed of under normal administrative practice, are still Commonwealth records. This means that APS employees need sensible direction on the extent to which they can keep records on non-corporate, individual systems. Such directions could include, for example:

• limits on the amount of records stored on individual APS employees’ non-corporate computer drives
• limits on how long such records are kept.

Records of short-term value can be disposed of via record disposal authorities approved by the National Archives (see more detail in Chapter 5).

 

3 National Archives of Australia 2003, Why aren’t all records retained?, <http://www.naa.gov.au/recordkeeping/disposal/why_keep/records.html>

4 Department of Education, Science and Training 2005, Management Instructions, Corporate Administrative Records.

5 Section 44 of the Financial Management and Accountability Act 1997.

6 Section 24(2)(c) of the Archives Act 1983 allows for the destruction or disposal of Commonwealth records ‘in accordance with a normal administrative practice, other than a practice of a department … of which the Archives has notified … that it disapproves’.

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