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RECORD KEEPING

The APS Values set out in the PS Act provide that the APS is openly accountable for its actions, within the framework of ministerial responsibility to the Government, the Parliament, and the Australian public. The maintenance of effective record keeping systems supports this Value, by allowing agencies to demonstrate that due process has been followed in actions and decisions. It also helps agencies achieve business goals by ensuring that necessary corporate information is available and accessible as required. Furthermore, effective record keeping enables employees to meet their specific obligations to Ministers, the Government, and the Parliament.

Record keeping has attracted substantial attention in recent years, both in general reports such as by the ANAO and the APS Commission, and in the context of specific cases of concern such as the Magnetic Resonance Imaging Services case and a Certain Maritime Incident. In part this increased attention is because record keeping in the APS has been affected by greater public scrutiny through administrative law reform and parliamentary oversight over the past few decades, but also due to the greater emphasis on achieving results. Technology has also had a major impact on record keeping practices.

While public administration has generally improved as a result of administrative law reforms, including the Freedom of Information Act 1982 (Cwlth) (the FOI Act)¹³, the risk that these reforms may inhibit record keeping need to be more openly acknowledged and discussed. The Senate’s own approach to questioning public servants seems to be more accepting of the need to keep advice on policy confidential, than has been the approach of the courts at times in interpreting the FOI Act.

In September 2003, the ANAO tabled the second in a series of audits on record keeping.¹⁴ It concluded that, although all agencies audited had taken active steps to improve their record keeping frameworks and practices, their record keeping policies, systems, and procedures were at different stages of development. In particular, it found a significant risk of the non-capture and unauthorised disposal of records because:

• organisations had not paid sufficient attention to the risks associated with record keeping, including those related to outsourced functions, nor had they identified their vital records
• not all records were being entered into formal record keeping systems
• limited controls were in place over electronic records
• formal, long-term sentencing programs for the disposal of records were not in place
• physical records were not being stored in compliance with NAA standards
• contracts with outsourced providers did not include all record keeping elements recommended by the NAA, and minimal monitoring and review activities were being conducted to ensure outsourced providers were meeting record keeping requirements.

The last two State of the Service reports found that there was a growing awareness of modern record keeping requirements among agencies, but that some, particularly smaller agencies, were not well advanced in reviewing arrangements and integrating electronic records into corporate record management systems. They also reported a need for more active and targeted staff training and development strategies.

Partly, in response to the ANAO audits on record keeping, the State of the Service reports, and its own 2002 Survey of State of Recordkeeping in the Commonwealth Government,¹⁵ the NAA released an Exposure Draft of Digital Record Keeping Guidelines in May 2004.¹⁶ These guidelines are designed to provide comprehensive guidance to Australian Government agencies on creating, managing, and preserving digital records. In addition to the guidelines, the NAA also released an Exposure Draft Self-Assessment Checklist.¹⁷ The checklist is a selfassessment tool designed to assist Australian Government agencies to effectively manage digital records. Both of these documents are part of the e-permanence suite of products developed by the NAA and will be revised in 2005.

The following sections draw on information from the 2004 agency and employee surveys. In general, the findings point to increasing attention being paid by agencies to the issue of modernising their record keeping systems. Although there has been improvement in 2003—04, there continues to be evidence that a more strategic approach to records management and training is still required in some agencies.

EVOLUTION OF RECORD KEEPING SYSTEMS

The results of the agency survey show that since the Designing and Implementing Record Keeping Systems Manual was issued in 2000, two-thirds (66%) of agencies had undertaken a review of their record keeping systems using Designing and Implementing Record Keeping Systems (DIRKS).¹⁸ Medium (78%) and large (71%) agencies were more likely than small agencies (54%) to have undertaken a review using the DIRKS methodology.

The agency survey also explored how many steps agencies had taken in reviewing aspects of their record keeping systems.¹⁹ Of the 57 agencies that had undertaken a review using DIRKS, 55 agencies (96%) indicated that they had completed at least the first step–preliminary investigation. However, 15 agencies (26%) had only completed the first step, whilst 18 (32%) had completed three steps. Only three agencies (5%) reported that they had completed all eight steps including a post implementation review: Defence, AGD, and PSR.

Agencies were also asked to report whether they had undertaken a review of their record keeping systems in 2003—04. Over half (56%) of agencies had undertaken a review of their record keeping systems in 2003—04, down from 63% in 2002—03. Medium (70%) and large (62%) agencies were more likely than small agencies (44%) to have undertaken a review in 2003—04.

One in five agencies (20%) planned to undertake a review of their record keeping systems in 2004—05. Of the 18 agencies that had planned a review in 2003—04; half (50%) had completed this review, a further 22% continued to have a review planned for 2004—05, whilst 28% did not complete the review and did not have a review planned for 2004—05.

Agencies that had undertaken a review of their record keeping systems in 2003—04 were then asked further questions about the types of record they had reviewed, and whether they used DIRKS. Table 3.5 shows that agencies were more likely to have reviewed paper-based (98%) than electronic (80%) records. However, only 51% of agencies used DIRKS to conduct the review, with large agencies (62%) most likely to have used DIRKS.

Table 3.5: Record keeping systems reviews in 2003—04

Source: Agency survey

Note: Reported percentages are based on the number of agencies who had undertaken a review of record keeping systems in 2003—04.

Modernising record keeping systems still remains a challenge for many agencies. This was particularly evident in small agencies. The ongoing challenge for other agencies is to continue to implement the DIRKS methodology in reviews of record keeping systems.

RECORD KEEPING CAPABILITY

The employee survey results show that most employees believed their agency places a priority on effective record keeping, with the majority (85%) of employees having agreed that their agency considers good record keeping practices to be very important. This result was similar to that obtained in the 2003 survey. Employees from medium (88%) and large (85%) agencies were somewhat more likely to have agreed than those from small agencies (77%). Agency-specific results available for the 22 large agencies showed considerable variation (64% to 96%) in the proportion of employees who agreed that their agency considers good record keeping practices to be very important. The three agencies with the highest level of agreement were CRS, Centrelink, and Customs (all at least 90% agreement).

The 2004 employee survey showed that there was an increase in the proportion of employees who agreed that they received appropriate training and/or had access to information that enabled them to meet their record keeping responsibilities (69% in 2003—04 compared to 64% in 2002—03). Nevertheless, this proportion in 2003—04 (69%) remains substantially lower than the proportion of employees who agreed that their agency considers good record keeping practices to be very important (85%). This disparity was also reflected in some of the comments provided by employee survey respondents. For example:

Record keeping is generally given a high priority but training is poor.

No training in regards to good record keeping practices.

In five years here, have never been given training in this requirement, or told what is needed.

Employees working in medium (72%) and large (68%) agencies were more likely than those in small agencies (61%) to agree that they received appropriate training and/or had access to information that enabled them to meet their record keeping responsibilities. Agency-specific results available for the 22 large agencies also showed large variation in the level of agreement (49% to 82%). The two agencies with the highest level of agreement were CRS and Centrelink (both at least 80%).

A minority (13%) of employees in 2003—04 indicated that they had not received appropriate training and/or had access to necessary information. This was lower than last year’s result (18%). The greatest improvement occurred at the EL and SES levels. The proportion of SES employees who disagreed that they had received appropriate training and/or had access to necessary information was 13% (down from 25% in 2002—03), whilst 17% of EL employees disagreed (down from 28% in 2002—03). The proportion of APS 1—6 employees who disagreed was slightly lower in 2003—04 (12%) when compared to 2002—03 (15%).

Agency results were also indicative of a positive trend. The majority (86%) of agencies had at least one measure in place to ensure senior managers were aware of their record keeping responsibilities, whilst a further eight per cent of agencies were developing at least one measure. In addition, 98% of agencies had at least one measure in place to ensure employees other than senior managers were aware of (and able to fulfil) their record keeping responsibilities.

The most common measures used by agencies to ensure senior managers were aware of their record keeping responsibilities were: self-nominating formal in-house training in record keeping procedures (48%), attendance at seminars/training provided by NAA (47%), and compliance assessments (such as audits) (37%).²⁰ Figure 3.6 shows that in 2003—04 there were substantial increases in the proportion of agencies using self-nominating formal in-house training in record keeping procedures, and attendance at seminars/training provided by the NAA.

There was, however, a decrease in the proportion of agencies including record keeping issues in general training for senior employees.

Figure 3.6: Measures used by agencies to ensure senior managers are aware of record keeping responsibilities 2002—03 and 2003—04

Source: Agency survey

The increase in the proportion of agencies in 2003—04 using seminars and/or training provided by the NAA could be a result of the launch in June 2003 of the NAA’s training package, Keep the Knowledge–Make a Record! This package was distributed to numerous agencies in 2003—04, and has increased the awareness in agencies of the availability of NAA training materials.

The most common measures used by agencies to ensure employees other than senior managers were aware of (and able to fulfil) their record keeping responsibilities were: circulars/operating instructions (80%), information on the intranet (77%), self-nominating formal in-house training in record keeping procedures (52%), information in Chief Executive’s Instructions (51%), and attendance at seminars/training provided by NAA (46%).²¹

13 The FOI Act provides a mechanism for the public to access information about the operations of departments and government authorities.

14 ANAO, Recordkeeping in Large Commonwealth Organisations, Performance Audit Report No. 7, September 2003, <http://www.anao.gov.au>

15 See <http://www.naa.gov.au>

16 NAA, Digital Record keeping: Guidelines for Creating, Managing and Preserving Digital Records, May 2004, <http://www.naa.gov.au>

17 NAA, Digital Record keeping Self-Assessment Checklist, May 2004, <http://www.naa.gov.au>

18 The DIRKS methodology, articulated in the Australian Standard for Records Management AS ISO 15489 and promulgated by the NAA, is one of the management tools available to assist agencies in establishing a record keeping infrastructure.

19 Agencies may have reported the number of steps completed for one particular function of their record keeping system, rather than the number of steps they had completed for all record keeping systems. For example, an agency may have completed all eight steps for their personnel record keeping system, but only two for their policy record keeping system. However, their response to this question is that they have completed eight steps in reviewing their record keeping systems.

20 Agencies were asked to report all measures in place to ensure senior managers are aware of their record keeping responsibilities.

21 Agencies were asked to report all measures in place to ensure employees other than senior managers were aware of (and able to fulfil) their record keeping responsibilities.