Information Governance Services

University Policy on: Records Management

Policy No.
UP07/157
Function
Information Management
Authoring Organisational Unit
Information Governance Services
Date Approved
01/06/2007 Revised 13/10/2010
Next Review Date
04/07/2017
Approving Body
Executive Director Academic Services & Registrar

The University of Western Australia

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University Policy on: Records Management

Overtype “Policy Name” with the name of the policy.  This must convey specifically, accurately and succinctly what the policy addresses eg Award of Honours, Study Leave.

Purpose of the policy and summary of issues it addresses:

The University Policy on Records Management provides the necessary framework to ensure that the University creates, captures and manages its corporate information in a way that complies with relevant legislation and that supports efficiency and effectiveness in the performance of its various functions. This policy supports the Operational Priority of "Management" as articulated in UWA's Strategic Plan and Operational Priority Plan.  It defines the record keeping responsibilities of University staff, specifically regarding the creation, capture, control, security, accessibility and disposal of records, and commits the University to compliance with relevant legislation.

This must be in Normal, Policy style.

Provide a brief summary of the reasons for the policy and issues it addresses.  This section is designed to stand alone.  The aim is to provide the reader with enough information to make a decision about whether or not this is the policy they are looking for.  It must not be longer than 200 words. 

Example 1

This policy defines the nature and purpose of study leave provisions for academic staff and sets out eligibility criteria and other conditions that apply.

Example 2

This policy seeks to rationalise the award of honours across the University by addressing such issues as: entry standards, course content and structure, supervision, assessment, examination, grades, classifications, benchmarking and the maintenance and provision of documentation relating to these matters.  It is based on resolutions of the Academic Board flowing from the 1999 report of the Honours Working Party.

Definitions:

Archival records

Records that are identified through the sentencing process as having permanent value (ie must be retained and/or kept accessible forever).  This may relate to administrative, evidential or research value or a combination of these.  Records that are identified as archival form part of the cultural resources of the State.

Corporate Information System

A system used to manage information which possesses appropriate records management capabilities and is generally used by a number of different areas of the University. Corporate information systems are supported by appropriate migration and preservation strategies as well as a set of authorised policies, assigned responsibilities, delegations of authority, procedures and practices, policy statements, procedures manuals, user guidelines and other documents which are used to authorize and promulgate the policies, procedures and practices.  Corporate Information Systems currently recognized by the University include TRIM, Callista, Alesco and Peoplesoft.

Corporate Record

A corporate record is any record (as defined in section 12.1) created or received by an individual working on behalf of the University (as defined in section 3).

Disposal

Refers to the process of changing the disposition of a record. Disposal can mean preserving a record as an archive or the destruction of a temporary record.  It can also refer to a change in the record’s custody (for example, transferring the record offsite or to Archives).

Disposal Authority

A legal instrument that identifies various categories of records and the minimum length of time that they must retained in order to meet the responsible organisation’s legislative and business requirements.

Electronic or Digital Records

An electronic or digital record is any machine readable information in electronic storage media, including metadata, judged to be a corporate record.

Metadata

Data describing context, content and structure of records and the management of these records through time. Examples of metadata include author, date created, title, approving body, file reference etc.

Organisational Unit

A unit formed by the University to undertake prescribed functions, including Academic Organisational Units as defined by Department of Education Science  and Training (DEST)

Record

Any record of information however recorded and includes –

a) any thing on which there is writing or Braille;

b) a map, plan, diagram or graph;

c) a drawing, pictorial or graphic work, or photograph;

d) any thing on which there are figures marks, perforations, or symbols, having meaning for

persons qualified to interpret them;

e) any thing from which images, sounds, or writings can be reproduced with or without the aid of

anything else; and

f) any thing on which information has been stored or recorded, either mechanically,

magnetically, or electronically

Sentencing

The process of using a current Disposal Authority to allocate a minimum retention period to a record as part of the disposal process.

Structured information

One way to describe information that is created, captured and managed in a formal arrangement or structure.  This includes information entered into a database or corporate information management system such as Callista, Alesco and Peoplesoft.

 

Unstructured information

One way to describe information that is created and used without formal templates or fields.  This can include correspondence, policies, procedures, minutes, agendas, reports, reviews, advice, recommendations and supporting documentation for structured information such as handwritten forms transcribed into another system.

 

University Archives

A section of Information Governance Services which is responsible for facilitating the identification, management, preservation of and access to the University’s archives.  It is also responsible for promoting the use of the University’s archival resources.

University employee

An individual who has been employed by the University for the purpose of conducting University business. This includes contractors and consultants employed on behalf of the University.

UReKA

UReKA is a web-based application designed jointly by ITS and Information Governance Services to assist areas without access to TRIM manage their hardcopy records.

Place your cursor immediately under the definitions heading to get the definitions style.

Policy statement:

The University is committed to records management practices which comply with relevant legislation and that are in line with good professional practice.  It recognises that its records form the organisation's corporate memory and as such facilitate responsible decision-making, effective policy development, accountability and transparency of governance.  The University’s records support efficient and effective business practices and protect the interests of the organisation as well as the rights its staff, students and the wider community.  This policy provides for good records management practices which in turn ensure consistency, continuity, efficiency, effectiveness and productivity in the delivery of the University’s services and the functions that it undertakes.  The records identified as University Archives form part of the cultural resources of the State.

Scope

The following individuals and organisational units are subject to this policy:

· University of Western Australia employees;

· University of Western Australia contractors;

· Convocation, the UWA Graduates Association;

· Organisations performing outsourced services on behalf of the University of Western Australia;

· Regional and offshore campuses and offices of the University of Western Australia; and

· Volunteers performing duties or services for the University of Western Australia.

The University of Western Australia includes unincorporated campus entities (including University committees) where the University is the centre agent or where an entity utilises the University’s ABN. Therefore this policy extends to records kept by Faculties, Schools, Centres, Institutes as well as University controlled entities, but not to areas that have been established as independent legal entities such as associations or companies.

This policy applies to all records created or received by any of the above parties during the course of their business on behalf of the University regardless of physical format, storage location or date created.  For the purposes of this policy, a record is defined as meaning “any record of information however recorded and includes –

a) any thing [including binary coded data that requires combinations of computer hardware and software to be understood] on which there is writing or Braille;

b) a map, plan, diagram or graph;

c) a drawing, pictorial or graphic work, or photograph;

d) any thing on which there are figures marks, perforations, or symbols, having meaning for

persons qualified to interpret them;

e) any thing from which images, sounds, or writings can be reproduced with or without the aid of

anything else; and

f) any thing on which information has been stored or recorded, either mechanically,

magnetically, or electronically.”[1]

UWA Record Keeping Principles

The University and its staff will adhere to the following Record Keeping Principles:

PRINCIPLE ONE - Facilitating the business functions of the University

The University is committed to sound record keeping practices throughout the organisation. This commitment will be manifest in staff induction and training and includes descriptions of staff record keeping responsibilities.  Record keeping practices will be assisted by documented procedures for the management of paper based and electronic records as well as other record formats.

PRINCIPLE TWO - Ensuring Accountability

The University is committed to ensuring that the records retained fairly represent the decision-making trail. This means ensuring that there are adequate work practices and safeguards to create an auditable trail enabling decisions to be recorded and linked to the documents or other source material relating to how a decision was arrived at.

PRINCIPLE THREE - Ensuring Legislative Compliance

The University is committed to ensuring that the necessary means are available for it to meet its statutory record keeping obligations so that:

· there are systems of record keeping in place;

· public access is provided for, commensurate with the University’s legal obligations;

· no records are destroyed unless authorised by an approved Records Disposal Authority (RDA) or General Disposal Authority (GDA);

· there are correct methods for destroying records;

· all officers understand their roles and responsibilities regarding the records disposal process; and

· a service is available to expedite disposal.

PRINCIPLE FOUR - Ensuring continuous improvement

The University is committed to ensuring that its record keeping practices will continue to meet legislative, best practice and user requirements. This means ensuring that regular reviews of University practices will be undertaken.

Record Keeping Roles and Responsibilities

Different levels of University staff have different levels of responsibility in relation to record keeping as outlined below:

1 Vice Chancellor and Registrar (Executive Director, Corporate Services)

The Vice Chancellor through the Registrar is to ensure that an organisational system for the capture and management of records is maintained that is compliant with legislative requirements and best practice standards.

2 Executive Directors, Directors and Managers

All staff responsible for administrative divisions, faculties, schools, centres, institutes or in a managerial role are to ensure University record keeping principles, policies and procedures are known and adhered to in their area of responsibility.

3 Information Governance Services Division

The Information Governance Services division is responsible for the custodianship of the corporate memory of the University. This role includes:

· Developing, maintaining and promulgating policies, procedures and tools that will assist all University staff in ensuring creation, capture, control, security, protection, access and disposal of records by the University.  This includes the development and periodic review of the University’s Record Keeping Plan (RKP);

· ensuring compliance with relevant legislation through the promotion of appropriate records management and archives practices across the University as articulated in the University’s RKP through the provision of comprehensive training for University staff and other promotional activities;

· identifying, collecting, managing, preserving and providing access to the archival resources of the University;

· promoting the use of the University’s archival collection.

4 All University Staff

All individuals and organisations identified in the scope of this policy are responsible for ensuring that records are handled in a manner that complies with this policy and the University’s RKP.  In particular staff must ensure that proper records are created, captured, classified, kept secure, made appropriately accessible and disposed of in accordance with this policy and the supporting procedures.

Custodianship and Ownership of University Records

The University recognises that records created by University staff identified in the scope of this policy during the course of University business are owned by the University and as such form part of the organisation’s corporate assets.  This includes records created by contractors, consultants or volunteers undertaking work on behalf of the University.  Ownership and custody of University records will be articulated as part of any contract entered into by the University and an external party where the external party performs a function or service on behalf of the University.  The contract should provide that the external party will create and manage its records in accordance with University policy for the duration of the contract and, at the termination of the contract, relevant records generated from the work carried out on behalf of the University should be transferred to the University as soon as practicable.

UWA’s Record Keeping Plan (RKP)

The University will continue to implement and adhere to the requirements of its Record Keeping Plan, as stipulated in UWA’s Strategic Plan and Operational Priorities Plan and as required by the State Records Act, 2000. 

The University will submit a statement of compliance with its Record Keeping Plan each year in its Annual Report. This statement will include:

· A statement regarding the organisation's commitment to good and compliant record keeping practices;

· Details of the record keeping training program and key findings from any reviews;

· A brief statement regarding how the record keeping induction addresses employee record keeping roles and responsibilities;

· Annualized University Record keeping Performance Indicators (including a comparison to the previous year);

· A brief statement regarding any significant improvements or developments of record keeping and record keeping systems at the University; and

· should the Annual Report be published after a comprehensive review of the University's record keeping system, then details of key findings and recommendations of the review will also be included.

The RKP will be reviewed and resubmitted to the State Records Commission every five years.

Corporate Information Management Systems

The University has implemented TRIM as the corporate information system responsible for electronic document and records management (EDRM).  TRIM is used for the capture and management of electronic and hardcopy documents (sometimes referred to as “unstructured” information) created, captured and utilised by central administration units and faculties. The Information Governance Services division of the University is responsible for supporting TRIM and for facilitating the management of electronic and hardcopy information in a way that aids business processes and facilitates legislative compliance.  Information Governance Services is also responsible for developing, implementing and promulgating procedures, tools, advice and training that supports the effective use of TRIM. 

The University has implemented a number of other corporate information systems for the management of its records.  Corporate information systems possess records management capabilities and are  supported by migration and preservation strategies, as well as a set of authorised policies, assigned responsibilities, delegations of authority, procedures and practices, policy statements, procedures manuals, user guidelines and other documents which are used to authorize and promulgate the policies, procedures and practices[2][3].

Other corporate information systems that serve to capture and manage “structured” information include Alesco, Peoplesoft and Callista.  Electronic records that are managed outside of these corporate information systems must either integrate with an approved corporate information management system or possess the same records management functionality as corporate information systems.

Schools, Centres, Foundations, Units, Institutes etc that do not have access to TRIM will ensure that they manage their local records in accordance with the University’s Records Management Policy and Principles and the procedures and advice provided for these units by the Information Governance Services division. It is recommended that units without access to TRIM implement UReKA to manage their local records until such time as TRIM becomes available.

Owners of University corporate information systems are responsible for ensuring that their systems are supported by appropriate migration and preservation strategies as well as a set of authorised policies, assigned responsibilities, delegations of authority, procedures and policy statements which support the long term management of the data contained in that system and meet the requirements of the University’s Record Keeping Plan and relevant legislation.

System owners are responsible for ensuring that data is maintained for as long as it is legally required.  To delete, overwrite or render data inaccessible before its retention period has been reached constitutes a breach of legislation. Owners of University corporate information systems must not rely on snap shot backups maintained by ITS or IT service providers to fulfil the requirements for the long term management of the data contained in those systems, as these backups are for the purpose of recovering recent data in the event of a system failure, and therefore do not adequately ensure long term accessibility of information as required by law.

Creation of records

All staff (including consultants and contractors) will create full and accurate records, in the appropriate format, of the University of Western Australia’s business decisions, discussions and transactions to meet all business, administrative, financial, evidential and historical requirements. 

Where central files exist for the capture of information being created and/or received (eg official Student, Staff, Research Administration, General Files etc), all original records will be placed on the central file. The University will not create duplicate filing systems when access to central files is available. This will ensure that resources are not wasted and that confusion between the official file and local files will be avoided.

Staff will ensure that information created and recorded is relevant to the business activities of the University and is written in an appropriately professional style.  Clear distinctions will be made between facts, opinions and assumptions.  Offensive, overly subjective, or inappropriately pejorative comments about individuals will not be recorded in documents.  

Capture and Control of Records

All records created and received by staff (including consultants and contractors) in the course of the University of Western Australia’s business are to be captured regardless of format, with required metadata, into appropriate records management and/or corporate information systems that are managed in accordance with sound record keeping principles. For central administration units, appropriate systems include TRIM, Callista, Peoplesoft and Alesco. For units that do not have access to TRIM (ie non-central administration units), appropriate systems could also include a local record keeping system, such as UReKA or equivalent.  Formal university documents such as reports, policies, procedures and documents submitted through the committee system should be created using a document control template to ensure that all necessary metadata is captured including author, date, version, file number, approving body etc.

Security and Protection of Records

The University recognises that records managed outside of corporate information systems are at greater risk of unauthorised access, loss, intentional or accidental alternation or destruction and for this reason will ensure that all corporate records, including highly sensitive or confidential records, will be managed within the appropriate corporate information system. All records are to be categorised as to their level of sensitivity, adequately secured and protected, and kept in accordance with necessary retrieval, preservation and storage requirements. 

The University also recognises that within the electronic document management environment, an individual’s login identification must be inviolate.  This ensures that audit trails are accurate and that documentation relating to workflow can be used as proof of an action or approval process without recourse to digital signatures.   Therefore, at no time will staff share access codes, passwords, login identifications etc when accessing the University’s EDRMS TRIM. 

Hardcopy records registered in TRIM will at no time be moved off-site without the express authorisation of Information Governance Services.  Staff using records off-site shall apply the appropriate security measures to ensure that the information is not accessed, corrupted, deleted or destroyed by unauthorised individuals.

All organisational units will ensure that measures are taken to avoid possible damage to records by promoting awareness of the University’s Contingency Plan, by developing local back-up regimes for electronic records where central back-ups are not available and by storing physical records in an appropriately secure and safe environment. 

In the event of a disaster affecting records, which could include flooding, fire or infestation, Information Governance Services will be notified as soon as practicably possible.  Information Governance Services will provide assistance in assessing and addressing damage incurred.

Access to Records

Access to the University of Western Australia’s records by staff and contractors will be in accordance with designated access and security classifications.   Access to the University of Western Australia’s records by staff, students, contractors and the general public will be in accordance with the State Records Act 2000, Freedom of Information Act 1992 and the University of Western Australia’s Access Policy.

Disposal of Records

All corporate records, including those managed outside of the University’s corporate information systems, will only be disposed of in accordance with the appropriate current General Disposal Authority (GDA) or Records Disposal Authority (RDA) which has been approved by the State Records Commission.  Disposal actions include destruction, transfer of custody or archiving of records. 

No disposal action can be undertaken on records that are not covered by a current RDA or GDA.  Where disposal coverage does not exist, the relevant records will be appraised according to their evidential, administrative and research value.  Appraisal will be conducted by Information Governance Services in conjunction with the area responsible for creating, capturing and managing the information.  An amendment to an existing GDA or RDA or an adhoc disposal authority will be submitted to the State Records Commission for approval, after which time the appropriate disposal actions can be undertaken. 

Official University files that are registered in TRIM will only be disposed of by Information Governance Services staff. 

University records managed in local record keeping systems may be destroyed by local staff in accordance with an approved Disposal Authority and under the direction of the relevant manager (School Manager, Faculty Manager or equivalent).  Final approval will be sought from the University Archivist prior to any action resulting from the disposal process taking place. Action includes destruction, transfer of custody or archiving of records.

Records documenting the disposal of corporate records will be maintained as University Archives.  All disposal actions undertaken shall be documented and include a description and date range of the records, the Disposal Authority and class used to sentence the records, and formal approval from the University Archivist. 

 

Information Governance Services Education Programme

Information Governance Services will provide appropriate training and advice for staff to enable them to meet their responsibilities as outlined in this policy and in accordance with the compliance requirements of the RKP.  The education programme will include but is not limited to:

· Formal training presentations on all aspects of records management

· TRIM training for individual users of the corporate EDRMS

· The on-line Records Awareness Training (RAT) package which forms part of the process of staff induction as well as being a prerequisite for access to TRIM.

· General Advice Sheets and TRIM Advice Sheets

· Information Governance Services newsletter

· Various adhoc presentations and training as required.

University Archives

By arrangement with the State Records Office WA, the Information Governance Services division is responsible for facilitating the identification and appropriate management of the archival holdings of the University.  The University will ensure that arrangements are in place to provide for the identification, storage and preservation of and public access to these records.  These arrangements will conform to relevant legislation, SRC Standard 7, the organisation’s Public Access policy and the agreement between the University and the State Records Office of WA.

Policy or Procedure?

Policies are statements of the principles1 which govern decision-making.

Procedures are the functional steps used to implement policies.

1 Principles in this context are to be understood as being both broad and detailed.

The policy statement makes clear the intent of the policy.  It must be written in clear, precise and direct language.  Short sentences are preferable.  Any specialist words or acronyms must be defined at the beginning of the statement.  (A guide to writing styles will be available soon.)

If the policy includes procedural elements you will need to identify these as Procedures by including this word above the relevant text.  The procedures style from the styles drop-down list must be applied to the whole of the procedures text, including the word Procedures.  Note: Administrative procedures can be approved by the relevant Director.

Related forms: (Link)

http://www.archives.uwa.edu.au/toolbox/forms

Provide links to any forms associated with the policy (eg Approved Leave form) and/or to information on on-line submission.

Note: Forms are a means through which policy is processed, not made.  Forms must reflect policy and must not be used to create policy.

TRIM File No:

F15975

Insert the appropriate TRIM file number.  All policies must have a TRIM file for storing information relating to policy development and other related information.  Note this is not the policy number.  Apply for a TRIM file number at http:/intranet.uwa.edu.au/page/38742

Contact position:

State the name of the position that is to be contacted for any queries regarding the policy, eg University Secretary.  Note: As this will link through to the University’s Contact Directory, the position name must be given exactly as it appears in that directory.

Director, Information Governance Services

Related Policies or legislation:

Legislation

• State Records Act, 2000;

• State Records (Consequential Provisions) Act, 2000;

• Evidence Act, 1906;

• Freedom of Information Act, 1992;

• Criminal Code, 1913;

• Electronic Transactions Act, 2003;

• Limitation Act, 1935;

• Financial Administration and Audit Act, 1985.

Major Government/Industry Policy, Standards and Codes

• Australian Records Management Standard ISO/AS 15489-2002 Parts 1 and 2;

• Australian Accounting standards;

• State Records Commission Principles and Standards 2002;

• WA Government Policy and Premier’s Instructions;

• Australian Vice Chancellors Committee (AVCC) Guidelines.

• Information Privacy Bill, 2007

• State Records Commission (SRC) Standards and Guidelines

University Policies, Plans, Reports and Procedures

UWA Record Keeping Plan (2004)

Information Statement (under development)

Information Governance Services Advice Sheets

Information Technology Policy Statement (2007)

Information Management Review Report (2007)

University of Western Australia Contingency Plan (2007)

Provide details of, and, if appropriate, web links to, other policies, legislation or committee resolutions that relate to the subject of the policy, if known, eg Statute(s), University General Rule(s).  If unsure what these might be, try one or more of the following:

Conduct a search on TRIM.

Make an enquiry to Archives and Records.

Seek help from staff in the relevant section. 

If related policies are stored in University Policy format on the University Policies site, please provide the relevant policy number(s). 

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if the policy does not already have a University Policy number, apply for one by completing the form at http://intranet.uwa.edu.au/archives/new_university_policy_number (Control and click to follow the link.)

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complete the relevant approval date and any other table boxes at the end of the template that have not yet been completed.

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Appropriate Director emails (rorett@admin.uwa.edu.au) the policy to University Records for storing in TRIM and publishing on the University Policies website.



[1] State Records Act, 2000

[2] SRC Standard 8 Digital Record keeping

[3] SRC Standard 7 Storage of State Archives by State Government Organisations