Requirement E
(e) Ensuring complete, accurate, and appropriately accessible recordkeeping of key actions and decisions
The APS is responsible for information that affects all Australians. Our stewardship of this information is critical to our ability to provide the best advice to government and the highest level of service to the community. Government information is a national resource, and our management of it is fundamental to sustaining public trust in our integrity as an institution.
Ask yourself:
How do I ensure that I can find this information later?
How can I enable others to find this information when they need it?
Do my records show what happened and why?
Strong information management enables the APS to maintain our institutional knowledge through periods of change; meet our accountability obligations for actions and decisions; uphold information access rights for individuals and the community; responsibly handle personal information; and ensure our work is informed by accurate data and relevant background.
Poor information management can have consequences for clients and the community; can compromise an agency’s integrity culture; and can undermine trust and confidence in the APS.
Information stewardship can help us to:
- access key information when we need it;
- show the rationale, evidence, and process behind our decisions and actions;
- share information, build on existing work, and avoid duplication or loss of crucial records;
- reflect on and learn from mistakes;
- keep important records accessible for future public servants;
- provide continuity throughout changes in administration; and
- support transparency and trust in government.
As stewards of the APS, all employees should make and keep records that provide a complete and accurate account of key actions and decisions. Our records should ensure that whoever needs to access the information will understand not only what was done, but also the reasons and context for the action or decision.
For APS employees, demonstrating stewardship can look like:
- documenting decisions and actions in a way that:
- captures context and background information; and
- uses clear and concise language;
- maintaining up-to-date and accurate records using:
- approved recordkeeping systems; and
- meaningful naming conventions;
- classifying and categorising records;
- securing sensitive information;
- following retention and disposal policies;
- providing access to authorised people; and
- regularly reviewing and auditing records;
Additional consideration for leaders
SES and other managers can demonstrate stewardship by:
- ensuring information management systems are functional and used consistently and accurately by teams;
- providing easy access to information management policies and guidance, and supporting this with training on recordkeeping obligations and procedures;
- ensuring information management and reporting requirements are met—and taking responsibility when they are not; and
- personally modelling good recordkeeping practice—including by not relying on others to take notes, document decisions, or create and maintain records.
Agency heads can demonstrate stewardship by:
- fostering a culture of integrity through information transparency and accountability;
- promoting openness, proactive publication, and access to information where appropriate;
- ensuring sufficient resourcing for information system architecture, including maintenance, archiving, and proper disposal; and
- supporting their employees to build information management knowledge and capability.
Further information
- Detailed information and guidance about APS recordkeeping obligations is available from the National Archives of Australia, including:
Case Studies—Stewardship in Practice
Case Study 1
Lin is an EL1 in a large department responsible for community programs. Lin’s team is responsible for grants administration. In addition to external reporting, Lin’s team has responsibility for internal processes and documents to track grant decision-making.
Lin and her team know they must act in accordance with grants guidelines and rules and relevant legislation. Lin has been frustrated by the way information is shared internally and reported publicly about the administration of a certain type of grant. As part of a major project Lin suggests the team put a range of new systems and processes in place to ensure the department reports information on all individual grants no later than 21 days after the grant agreement takes effect.
One of a number of changes relates to guaranteeing all relevant department personnel involved in grants management have up-to-date information. Lin establishes a portal in the grants management system, linked in the back-end to her team’s records in the information management system, to provide visibility of the reports and key data to the whole program area plus enabling and decision-making stakeholders—such as the finance, legal, audit, risk, and governance teams, all relevant SES, and the Executive. The team provides regular emails to these stakeholders containing links to the current reports in the secure portal, rather than sending spreadsheets or word copies of the reports and relevant data via email.
Lin’s team retains version control to edit the records to safeguard their accuracy and timeliness. Her effective use of the various information management systems relating to grants management and recordkeeping saves her team time in quality assuring multiple copies of records sent to different stakeholders between reporting dates.
What happens next?
Lin and her team are recognised in the agency’s end of year excellence awards for leading the review and enhancement of the grant reporting and information management process.
In speaking about the project at the award ceremony, Lin explains that through effective information management, the department can now clearly demonstrate that its processes are lawful, robust, and meet the highest standards of integrity, and enable appropriate scrutiny by the Parliament and the public of the decisions and activities of the agency.
By maintaining records of decisions, and ensuring those records are up to date, accurate, and accessible in the right version to other areas of the department who need to know about them, Lin demonstrates Stewardship of the agency and APS, acting in the public interest and increasing the transparency and accountability of grants administration.
Case Study 2
Anton is an APS 6 Claims Review Manager in the Workplace Claims Agency. Anton is responsible for reviewing determinations in respect of entitlements to workers’ compensation.
Anton is allocated a review of Maryam’s accepted claim for compensation, relating to a psychological illness that Maryam alleges has been aggravated in the course of her employment with her current agency. The agency has sought reconsideration of the claim as it disputes some of the facts and circumstances which are the basis of Maryam’s original claim, and has provided an independent medical examination of Maryam’s current mental health and fitness for duty.
Anton had received information from the agency at the beginning of the review process and filed these documents appropriately in the claims management system. The file also contains the records of the originally accepted claim including the initial diagnosis and treatment plan from Maryam’s GP and psychologist.
Anton later obtains further information from Maryam and her own treating practitioners via email, including a statement regarding the alleged events, the incident report she originally submitted to her agency, and a substantial amount of medical evidence from her own treating practitioners including a specialist psychiatrist that has been treating her since her original claim was accepted—both before and after her attendance at the agency-directed IME.
Anton keeps the more recent information he receives by email in his own mailbox, in a system that makes sense to him, but he has not logged all of it in the agency’s claims management system before he takes a month’s planned leave. Of the records in the system received for the purposes of the review, the majority relates to information received from the agency. Most of Maryam’s additional information is not yet filed.
Consistent with team practice, Anton’s cases are reallocated in his absence to his colleague, Tiana. On the basis of the incomplete information in the claims management system, Tiana makes a redetermination to deny Maryam’s claim, believing that Maryam has not provided sufficient additional evidence to substantiate her claim and rebut the IME.
What happens next?
Maryam complains to the WCA and seeks legal advice about filing an appeal with the Administrative Review Tribunal because she can’t understand why her recent medical evidence was not taken into consideration in Tiana’s reasons for her decision. This causes stress to Maryam and significantly hinders her rehabilitation and return to work.
As part of investigating Maryam’s complaint the WCA’s legal team discovers the remainder of the records in Anton’s inbox that would likely have led to an affirmed decision on the claim. The agency decides to allocate the whole matter to a different review officer to expedite a fresh decision to mitigate against having to defending the matter in the ART.
Anton is counselled by his manager for failing to demonstrate Stewardship by not keeping complete, accurate, and appropriately accessible records relevant to his actions and decisions, or ensuring Tiana could effectively take over his matter to take actions and make decisions of her own.
Case Study 3
Oliver is an EL1 manager for a taskforce set up to deliver an international event being hosted by Australia. One of Oliver’s tasks is to establish the taskforce’s file management process and develop and share a standard operating procedure for creating and storing official records, including naming conventions and file structure.
As the work of the taskforce increases suddenly, Oliver gets distracted by other priority tasks and does not complete his task. While he has set up a basic file management process, he does not communicate to the other taskforce members how and where they need to store their records of actions and decisions taken.
As a result, members of the taskforce go about their duties without saving records into established files, and many records are left in their own email accounts or filed in share drive folders that do not contain meaningful names are not sorted into an orderly system.
The taskforce including Oliver disbands after the successful event, but a few months later a journalist requests access under Freedom of Information to copies of the contracts and briefing materials for the event. There are no members of the taskforce remaining to assist in locating these records or assessing the relevance of their contents for release, and it becomes clear to the FOI team and decision-maker that the requested documents are not contained within the central file holdings Oliver created at the beginning of the taskforce.
What happens next?
To address the FOI request broad searches are required to be undertaken by the IT team which produces thousands of potential documents in scope, including drafts and duplicates of contract related information and large volumes of email correspondence. Many of these documents are not relevant at all to what the journalist is seeking, and some should have been deleted according to agency document disposal rules.
However, the FOI team has no way of working through this volume of documents in a considered way in the legislative timeframe, and the decision-maker feels compelled to refuse access on the grounds that processing the request would unreasonably divert the agency’s resources from their other critical operations. The journalist publishes an article about the agency’s lack of accountability and transparency.
Oliver failed to demonstrate Stewardship during his time in the taskforce by not completing his task—which caused a number of others in the agency to undertake work that would not have been necessary if an effective recordkeeping system had been implemented, and ultimately caused reputational damage to the agency regarding the integrity of its information management.