FOI 21/22-0034
Overview
Purpose
The purpose of this policy is to establish a framework for the creation and management of records
within the organisation. NDIA is committed to establishing and maintaining recordkeeping
practices that meet its business needs, accountability requirements and stakeholder expectations.
Principles
NDIA’s Recordkeeping Policy exists in the context of the following principles, which are designed
to promote best practice in recordkeeping:
Accurate:
records will correctly reflect what was communicated, decided or done.
Adequate:
records will be adequate for the purposes for which they are kept.
Audited:
recordkeeping systems, procedures and practices will be audited to ensure
compliance with regulatory requirements.
Authentic:
records will be what they purport to be.
Complete:
a record will contain not only the content, but also the structural and
contextual information necessary to document a transaction. It should be
possible to understand a record in the context of the organisational processes
that produced it and of other, linked records.
Compliant:
recordkeeping and management of those records will comply with legal and
administrative requirements.
Comprehensive: records will document the whole of the business of the organisation.
Inviolate:
records will be securely maintained to prevent unauthorised access,
destruction, alteration or removal.
Made:
records will be made automatically by business systems or intentionally by staff,
to document and facilitate the conduct of business.
Reliable:
recordkeeping systems, procedures and practices will work reliably to ensure
that records are credible and authoritative.
Retained:
records will be retained for as long as they are needed.
Routine:
recordkeeping systems will be used when transacting business.
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Systematic:
records will be made, maintained and managed systematically.
Useable:
records will be identifiable, retrievable, accessible and available when needed.
1.
Introduction
Under the Public Service Act 1999, the Australian Public Service (APS) is “openly accountable for its
actions, within the framework of ministerial responsibility to the Government, the Parliament and
the Australian Public”1. Heads of organisations are obliged to take reasonable steps to ensure that
they understand and operate within the Government's accountability framework, under directions
issued by the Public Service Commissioner, pursuant to the Public Service Act 1999. The Public
Service Commissioner suggests that organisations can “Demonstrate that due process has been
followed in [their] actions and decisions through the existence and maintenance of good
recordkeeping systems”.
2.
Definition of a Record
Records are evidence of business conducted by an organisation.
NDIA’s records comprise both structured information, such as is captured in major business
systems, and unstructured information, such as is created using office applications Microsoft Word,
Excel and Outlook and is captured in the corporate recordkeeping system. Records can be in any
form; however, NDIA primarily manages two types of records: physical and digital. Any reference
within this policy to “a record” or “records” refers to both physical and digital records.
A physical record is any2
“…document (including any written or printed) or object (including a sound recording, coded
storage device, magnetic tape or disc, microform, photograph, film, map, plan or model or a
painting or other pictorial or graphic work) that is, or has been, kept by reason of any information
or matter that it contains or can be obtained from it or by reason of its connection with any event,
person, circumstance or thing.”
digital records are3
“Records created, communicated and maintained by means of computer technology. They may be
“born digital” (created using computer technology), or they may have been converted into digital
form from their original format (e.g. a scanned rendition of a paper document).”
NDIA creates digital records in a variety of ways and may store them in many systems including
databases and business information systems, shared folders, email applications and hard drives.
1 APS Managing Official information, [Online],: http://www.apsc.gov.au/aps-employment-policy-and-advice/aps-values-and-code-of-conduct/aps-
values-and-code-of-conduct-in-practice/managing-official-information accessed 3 September 2013
2 Source: Archives Act 1983 Section 3 Interpretation http://www.austlii.edu.au/au/legis/cth/consol act/aa198398/s3.html accessed 4 September
2013
3 Source: Adapted from National Archives of Australia – Glossary [Online] Available: http://www.naa gov.au/records-
management/publications/glossary.aspx#gloss-digitalrecord accessed 4 September 2013
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The following list of digital records is not exhaustive, but highlights the range of digital records
covered by this policy:
electronic messages from communication systems such as email, windows messaging, SMS
(Short Messaging Services), electronic document exchange (electronic fax), voice mail, and
multimedia communications (e.g. Microsoft Office Communicator, video conferencing and
teleconferencing);
those created using office applications such as word-processed documents, spread sheets,
presentations and desktop published documents;
records generated by business information systems such as databases, human resources
systems, financial systems, workflow systems, client management systems, systems developed in-
house and content management systems; and
records in online and web-based environments such as intranets, extranets, public
websites and those created through online transactions.
3.
Scope
This policy applies to all NDIA staff members and contract personnel; to all officers including those
in National, State and Regional offices and remote locations; and those outsourced functions and
statutory organisations falling under NDIA’s responsibility.
It applies to all aspects of NDIA’s business; all records created during business transactions; and all
business applications and ICT systems used to create, store and manage records including email,
database applications and websites.
This policy provides the overarching framework for any other corporate recordkeeping policies,
instructions, practices or procedures which are provided on NDIA’s intranet site.
Any external service provider, program office or client of NDIA that creates, holds, manages or
maintains NDIA records on behalf of the department, when entering into a new agreement or
contract with NDIA, must comply with this policy.
4.
Legislation & Standards
NDIA is committed to complying with legislation and standards related to recordkeeping, access
rights and the production of records including, but not limited to, the fol owing:
National Disability Insurance Scheme Act 2013
Public Governance, Performance and Accountability Act 2013
National Archives of Australia - Administrative Functions Disposal Authority (2010)
Archives Act 1983
Archives Amendment Act 2008 disposal
Audit Act 1901
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6.
Disposal or Destruction of Records
NDIA’s records are regarded as Commonwealth records and can only be disposed of in accordance
with the various provisions of the Archives Act 1983, including normal administrative practice
(NAP). Staff members should take care not to unintentionally dispose of a Commonwealth record
outside of these provisions. Inappropriate and unlawful disposal is an offence under the Archives
Act 1983, and a breach of the APS Code of Conduct4.
7.
Responsibilities
The Chief Executive Officer has nominated the Branch Manager, Business Services Innovation
Branch, as the senior officer responsible for recordkeeping policy and standards in NDIA.
The Chief Executive Officer is authorised to grant special access to Commonwealth records in
accordance with s56(2) of the Archives Act 1983 for NDIA.
NDIA as an organisation is responsible for:
setting up sound recordkeeping systems, based on identified recordkeeping requirements
and including such elements as written policy and guidelines and training of users;
making sure proper and accurate records are created, maintained, kept and documented
within these systems;
ensuring that the records remain useable and are not prematurely destroyed; and
ensuring that public access to records is given when legitimately required and, conversely,
that records are not inappropriately accessed.
NDIA staff members, including contractors and consultants, are to ensure that appropriate records
are created and captured for all the business functions, activities and transactions they are
involved with. Staff members are required to appropriately classify and store information as set
out in the Recordkeeping Procedures5. Emails received in the course of business are records and
should be managed appropriately6.
4 Source: http://www.apsc.gov.au/aps-employment-policy-and-advice/aps-values-and-code-of-conduct/aps-values-
and-code-of-conduct-in-practice/managing-official-information Accessed 3 September 2013
5 Source: FaHCSIA’s Recordkeeping Procedures
6 Source: FaHCSIA’s Internet Governance Framework.p.8 http://staffnet/waf/it/websites/Documents/Internet-
Governance-Framework.docx and, ICT Security Policy 2012 accessed 4 September 2013
http://staffnet/waf/it/corpsystems/Documents/ICT_security_policy.pdf accessed 4 September 2013
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Staff members should not store official records and emails in personal locations and in systems
that do not have recordkeeping functionality. Where an appropriate record does not exist (such
as following a phone conversation or meeting) a record shall be created and lodged in a
recordkeeping system. Staff members are required to comply with disposal procedures, follow
work area procedures and use records to meet the organisation’s recordkeeping obligations.
The Cross Portfolio & Information Branch has responsibility for managing the NDIA’s records and
provides recordkeeping services to NDIA. NDIA’s Records Manager has the delegation to approve
the appropriate disposal of NDIA records.
Responsibilities are shown in the NDIA’s Recordkeeping Responsibilities Matrix at the end of this
document.
Ethical Behaviour in Practice
As NDIA employees we are bound by NDIA Values and the APS Values and Code of Conduct to act
ethically in relation to all things that we do in connection with our employment.
Ethical behaviour encompasses the concepts of honesty, integrity, transparency, probity, diligence,
fairness, trust, respect and consistency. Ethical behaviour identifies and avoids conflicts of
interest and improper use of our position or role as APS and NDIA employees.
Ethical behaviour ensures that NDIA business is conducted fairly, reasonably and with integrity.
In all aspects of NDIA business, we need to ensure that we:
recognise and avoid perceived or actual conflicts of interests;
seek appropriate advice when dealing with probity issues;
are accountable for, and can demonstrate accountability in our use of NDIA assets and
property;
comply with privacy laws and principles in the handling and release of personal
information;
do not accept inappropriate gifts or hospitality;
comply with legislative requirements and NDIA policy, procedures and instructions;
treat everyone with respect and courtesy;
do not release official information without approval;
take action immediately when we observe unethical behaviour;
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Bibliography
The following references were used in the preparation of this document:
National Archives of Australia, Developing a Recordkeeping Policy
(http://www.naa.gov.au/records-management/strategic-information/information-
governance/key-documents/policy.aspx )
National Archives of Australia, Digital Records
(http://www.naa.gov.au/records-management/agency/digital/index.aspx )
DSS ICT Security Policy
Commonwealth Information Security Manual - 2009 accessed 3 September 2013
Commonwealth Protective Security Manual - 2000
Australian Standard for Records Management AS ISO 15489 - 2002
Public Service and Merit Protection Commission, Values in the APS
(http://www.apsc.gov.au/merit/the-merit-protection-commissioner-role) accessed 3
September 2013
Council of Australasian Archives and Records Authorities, Policy Statement 7, Principles on
Full and Accurate Records (http://www.caara.org.au/index.php/policy-
statements/principles-on-full-and-accurate-records/ ) accessed 3 September 2013
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Table of Contents
1.
Definitions ................................................................................................................................................................. 4
2.
Introduction............................................................................................................................................................... 5
2.1
Purpose .......................................................................................................................................................... 5
2.2
Policy Statement ............................................................................................................................................ 5
2.3
Risk considerations ........................................................................................................................................ 6
2.4
Scope ............................................................................................................................................................. 7
3.
NAP Exceptions – do not delete ............................................................................................................................. 7
4.
Agency Publications and Promotional Material.................................................................................................... 8
5.
Metadata about records ........................................................................................................................................... 8
6.
Roles and Responsibilities ..................................................................................................................................... 9
7.
Communication and Training ............................................................................................................................... 10
8.
Monitoring and Review .......................................................................................................................................... 10
9.
Resources ............................................................................................................................................................... 10
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2.
Introduction
The National Disability Insurance Scheme (NDIS) is the Australian Government's policy to address the
rights and entitlements of eligible vulnerable Australian citizens with disability in accordance with Australia's
obligations under the United Nations (UN) Convention on the Rights of Persons with Disabilities.
The National Disability Insurance Agency (NDIA) is the independent Commonwealth entity responsible for
implementing the NDIS to improve life for Australians with disability, their families and carers. The NDIA is
accountable to the Australian Government through the Minister for Social Services and the Council of
Australian Governments (COAG) Standing Council on Disability Reform. The NDIA operates under the
National Disability Insurance Scheme Act 2013 (NDIS Act) and receives funds contributed by the Australian
Government, states and territories. The NDIA is committed to establishing and maintaining information
management practices that meet its business needs, accountability requirements and stakeholder
expectations..
Normal administrative practice (NAP) relates to low level information without ongoing business value that
can be routinely destroy information that is
not needed as documented evidence of the NDIA’s business
decision making processes, that are not assets and are therefore not needed to form part of its corporate or
operations business recordkeeping systems.
Records1 are evidence of business activity and information assets and are enablers of business providing a
factual knowledge base both current and strategic.2
2.1
Purpose
The purpose of this policy is to clarify responsibilities and to advise NDIA staff, contractors and consultants,
Partners and contractors what information can be routinely destroyed in the normal course of business. It
is to provide guidelines to assist the NDIA with an appropriate tool to remove or destroy transitory or
ephemeral information considered to have no ongoing business or government value, or reduplicated
information such as ‘copies of copies’ and unsolicited advertising material. This policy NAP is a
process by
which certain documents and information (electronic, paper and other formats) can be removed or
destroyed without reference to authorised National Archives of Australia’s (NAA) Records Authorities.
Section 24 of the
Archives Act 1983, provides that Commonwealth agency records can be destroyed:
As required by a specific law;
With the permission of the National Archives of Australia using a Records Authority; or
In accordance with a normal administrative practice (NAP).
The benefits of complaince with this policy include more efficient work practices and the management of
retained information as a business asset.
2.2
Policy Statement
NAP relates to the National Disability Insurance Agency’s (NDIA’s) certain low value and short-term
information where there is a low level of risk.
The NDIA recognises its regulatory requirements as a Commonwealth agency, inclusive of Partner
obligations under the Archives Act 1983 related to legal destruction and retention of government
information and records. Use of a normal administrative practice for destroying information is permitted
under the
Archives Act 1983 section 24(2)(c)3.
1 Archives Act : Record means a document, or an object, in any form (including any electronic form) that is, or has been, kept by reason of: (a) any
information or matter that it contains or that can be obtained from it; or (b) its connection with any event, person, circumstance or thing.
3 Archives Act 1983 S.24 Disposal, destruction etc. of Commonweatlh records
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NAP covers records4 that do not document business decisions and where the risk to the agency
associated with their destruction is low.
This policy applies to NDIA employees, contractors, consultants, Partners and staff related to information
that can be routinely destroyed when not needed to provide evidence of business decisions. It is important
to follow the process set out in this statement as original documents may need to be provided as evidence
in court or tribunal proceedings and are therefore their absence is high risk.
This Policy is to be read in conjunction with NDIA’s strategic framework including the NDIA Information and
Records Management Policy, the National Disability Insurance Scheme (NDIS) Records Authority and the
Commonwealth General and Administrative Records Authorities5.
2.3
Risk considerations
Deciding if a record can be destroyed using NAP can only be done with a cultural understanding of the
NDIA business the NDIS. If you do not have an understanding of the business context in which the
documents and records were created, you are not in a position to decide if the documents have (or do not
have) ongoing value and whether NAP can be applied.
Business areas should identify and advise staff of the kinds of records associated with their business
activities to which NAP for destruction can apply.
The responsibility of using NAP to delete documentation (information contained in software and systems, or
on paper) lies with each staff member, Partner or contractor using this policy as an avenue for destruction.
It is the responsibility of each staff member, Partner or contractor to utilise NAP within its intended
boundaries.
Destruction beyond the limitations of NAP constitutes unlawful destruction of records.
2.3.1 Delete with confidence
Non-business information such as personal unofficial emails, spam, unsolicited junk mail like 'hot
offers', non-business related material.
Duplicates of information that has already been saved into authorised recordkeeping systems or
another business information system.
External publications, catalogues and offers.
Reference copies (not master copies) of newsletters, procedures, guidelines, manuals, policies.
2.3.2 Needs consideration
Low-risk emails such as system reminders and alerts, discussion lists and RSS feeds, duplicate
emails kept for reference purposes, parts of an email thread where the full thread is saved into the
HPRM or authorised business information systems, 'for your information' communications, email
bounce backs.
Invitations, diaries and calendars (with the exception of SES)
Duplicate copies of NDIA’s publications and promotional material.
o
Note: the business area responsible for the publication has responsibilities to keep master
copies.
Drafts, rough or routine calculations and working papers.
Business information held in shared work spaces such as shared drives and business systems.
4 NAA Glossary: A record is all information created, sent and received in the course of carrying out the business of your agency. Records have many
formats, including paper and electronic. Records provide proof of what happened, when it happened and who made decisions. Not all records are of
equal importance or need to be kept.
Adapted from: Archives Act 1983, Part I, Section 3; Standards Australia, AS-ISO 15489, Part 1, Clause
3.15.Accesssed 23 September 2014
5 NAA: Authorities covering common business activities accessed 9 February 2017
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Documents prepared with the involvement of senior staff; these are often important and may not be
appropriate for destruction using NAP.
2.3.3 Do not delete
Valuable business information that is required:
for accountability purposes
for the ongoing efficient administration of agency business
to protect rights and entitlements of individuals, groups, or the Government, or
because of its cultural or historical value, or to meet community expectations.
2.4
Scope
This policy applies to all NDIA staff, Partners, and contractors who are working with NDIS Commonwealth
Government information, all aspects of NDIA’s business and all information, records and data regardless of
format, created during business transactions.
This policy applies to information in all formats including documents, email, voice messages, audio-visual
materials and data in business systems (e.g. websites, Outlook, social media applications, databases) that
will not be required as evidence of business activity.
Any information in hard copy or digital format, such as printed out or reduplicated material ‘copies of
copies’, or low value drafts, must be destroyed in a protected method in line with the NDIA’s ICT
Information Security Policy. For example, drafts and printed copies of NDIA/NDIS information must only be
disposed of by shredding and/or placing in security bins. The ICT Security Advisor (ITSA) can provide
specific advice regarding the sanitisation and/or disposal of IT equipment used for NDIS information such
as scanning equipment, portable storage devices.
3.
NAP Exceptions – do not delete
The following information
cannot be destroyed under NAP:
Policy drafts and working papers
Report drafts and working papers
Review drafts and working papers
Research working papers
Standards and guidelines working papers
Working papers for the development of whole-of-government procedures
Working papers for records transfers and sentencing
System logs which are used to show a history of access or change to data (e.g. system access logs,
internet access logs, system change logs and audit trails etc.)
Records documenting the migration of records between electronic systems and from one electronic
medium to another. Includes strategies for the migration and quality assurance checks to confirm
accuracy of the migration process
Information that is likely to be required as evidence in current or future legal proceedings
Information that is required to be kept by law (including by a records authority or disposal freeze)
Information that is required to be kept under an agency policy, procedure or guideline
Information that is a draft of a Cabinet or ministerial submission
Information that is a draft of an agreement or other legal document
Information that is needed to document a significant issue
Information that is needed to clarify, support or give context to an existing record
Information that is needed to show how a decision was made
Information that is needed to show when or where an event happened
Information that is needed because it indicates who made the decision or gave the advice
Information that is needed because it contains information on the rights, privileges or obligations of
government, organisations or private individuals
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Information that is a draft or working paper that contains decisions, reasons, actions and/or
significant or substantial information where this information is not contained in later documents or
the document remains not finished.
Records that are linked to community expectations providing rights and entitlements for participants.
Records that are needed because they contain information on the obligations of government,
organisations such as partners, service providers.
Information related to the rights and entitlements of people with disabilities, their carers and family
members and other private individuals.
Information that is a draft or working paper that contains decisions, reasons, actions and/or
significant or substantial information where this information is not contained in later documents, or
entered in the NDIA’s business and records management systems, or the document remains
unfinalised.
Information that provides support to the ongoing efficient administration of NDIA’s business.
Records considered as having cultural, social or known historical value.
Physical paperwork that is scanned or reimaged. See the NAA’s General Records Authority 31
(GRA31)6 .
Diaries and meeting attendance used to record important matters that may be required as evidence
belonging to staff holding high or high profile positions, for example the
o
Board
o
Chief Executive Officer
o
SES Band
o
State/Regional Manager
o
Contractor / Consultant meetings and presentations
o
Meetings and appointments between Planners, Partners, Local Area Coordinators related to
appointments with potential participants.
Drafts, calculations and working papers, e.g. drafts that contain significant or substantial changes or
annotations, and document business activities.
Information and records held in shared work spaces such as shared drives and business systems
(that should be transferred to a business system, after evaluation against applicable Records
Authorities.
Items registered in the NDIA’s business and records management systems which can only be
removed by the System Administrator with approval from the Information and Records Advisory
Unit.
Documents prepared with the involvement of senior staff and associated versions showing the
decision making processes; these are often important it may not be appropriate for destruction
using NAP.
Where a NAP exception applies, or if there is any uncertainty concerning whether the record should be kept
keep the record and place it in the NDIA’s business and records management systems. If you are unsure
about any of these contact the Information and Records Advisory Team before destroying the information.
4.
Agency Publications and Promotional Material
Place one copy in the appropriate and approved NDIA records management system and lodge one copy
with the National Library of Australia in accordance with the legal deposit requirements in National Archives
of Australia AFDA Express – Publication.
5.
Metadata about records
Metadata associated with deleted records will be retained in the NDIA records management systems and
retained as a National Archive Information Management (under class 1490 of the AFDA).
6 General Records Authority (GRA31)
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Encourages the incorporation of NAP policy directives into business unit work
procedures; and
Ensures that the NDIA NAP policy is incorporated into the development of the
NDIA’s recordkeeping systems, including business and IT systems;
Monitors compliance with the NAP policy.
7. Communication and Training
All staff will be provided with training on aspects of the NAP policy. Training will be relevant to roles and
positions, current, and provided on annual basis. Training will be tailored so that it is meaningful to different
workgroups managing Commonwealth and NDIS information and in the NDIA.
8. Monitoring and Review
The DCEO, will review this policy every three (3) years, or earlier if required.
Staff with responsibilities for NDIA information and records management will monitor the compliance
with the NAP policy.
Supervisors and managers will monitor their respective staff and contractors to ensure the NAP
policy is implemented correctly.
Contract managers will monitor compliance of contractors and outsourced service providers with the
NAP Policy.
Compliance with this policy will be monitored by the information and records management unit with
the support of workplace supervisors. Levels of compliance will be reported at least annually to
senior management.
9. Resources
NAA: Destroying records as a normal administrative practice.
The following flowchart illustrates the analysis required when deciding if you can destroy information using
a NAP.7 Please refer to an appropriate Records Authority or request assistance from the Information and
Records Management team.
Authorised Records Authorities are instruments that have been previously well-defined in accordance with
appropriate legislation with adequate requirements for retention of information. Alternatively contact the
NDIA Information Manager for assistance.
7 NAA: flowchart accessed on line 24 May 2017
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