As a Commonwealth agency, DFAT has an obligation to maintain good records of its business activities for legal purposes. Our records are vital assets that support our operations, enabling us to access the information we require and to preserve our corporate memory. They enable us to meet our accountability and compliance requirements. Sound recordkeeping practices are essential for DFAT to be a well-managed organisation.
The Strategic Plan for DFAT Records Management 2008 – 2011, extended to July 2013, provides the vision for the department's records management program. It sets the requirements for adequate and appropriate recordkeeping of business activities and decision making within DFAT.
This document supports the Strategic Plan and articulates the policy which will be adopted within DFAT for managing these requirements. It supersedes all previous recordkeeping policies.
This revised policy establishes a framework for the creation, capture, management and use of full and accurate records in all formats. It endorses the principles of digital continuity for electronic records to ensure that information is complete, available and useable for as long as it is needed and addresses the transition from paper to digital format as the preferred format for records in DFAT.
A Records Management Manual supports this policy and provides a single reference source for detailed instructions, procedures and guidance on the management of specific types of records and use of DFAT's Electronic Document and Records Management System, the EDRMS. The manual is located on the DFAT intranet so that it is accessible by all staff and will be regularly updated.
Compliance with this policy is mandatory for all staff. All officers working for the department have a responsibility to follow this policy and to maintain sound recordkeeping practices in their day to day work.
Department of Foreign Affairs and Trade
9 August 2012
Table of Contents
- Policy Statement
- Review Date
- Definition of a Record
- Digital Continuity and Digital Transition
- Ownership of Records
- Access to DFAT Records
- Disposal, Deletion or Destruction of Records
- Legislation & Standards
- Monitoring and Review
- Authorised Recordkeeping Systems
- Roles and Responsibilities
- 15.1. Appendix A: Glossary of Terms
- 15.2. Appendix B: Summary of Recordkeeping Legislation
- 15.3. Appendix C: Legislation Administered by DFAT
The purpose of this Records Management Policy is to provide direction for the creation, maintenance, storage and disposal of corporate records within the Department of Foreign Affairs and Trade (DFAT).
This policy, together with the Strategic Plan for DFAT Records Management 2008 – 2011, extended to 2013, and the Records Management Manual, will ensure that full and accurate records of DFAT's business activities are available and accessible for as long as required for operational, accountability and compliance purposes. The detailed Records Management Manual which supports this policy is intended to ensure that there are no gaps in DFAT's records during its period of application, specifically as the department completes the transition from a paper-based to a predominantly electronic recordkeeping system.
This policy replaces the DFAT Recordkeeping Policy dated July 2009.
2. Policy Statement
DFAT's records are its corporate memory and a vital asset for ongoing accountability. Good recordkeeping is critical to corporate governance, provides essential evidence of business activities and transactions, and demonstrates accountability and transparency in DFAT's decision-making processes.
DFAT is committed to implementing and maintaining best practice recordkeeping policy, practice and procedure.
DFAT recognises it's legislative and regulatory requirements as a Commonwealth agency under the Archives Act 1983. It is committed to meeting the practices set out in the International and Australian Standard for Records Management, AS ISO 15489 and the Principles and Functional Requirements for Records in Electronic Environments, ISO 16175.
All staff within DFAT, including locally engaged staff (LES) and contractors, are responsible for recordkeeping. All staff must, therefore, be aware of their obligations under this policy and take reasonable action to ensure ongoing compliance. Non-compliance with the recordkeeping policy may result in action, ranging from counselling to formal disciplinary proceedings.
Records created in DFAT must be full and accurate, as defined in the Australian Standards, AS ISO 15489 - 2009. They must:
- enable current and future DFAT staff to take appropriate action, and make well-founded decisions in their day to day operations
- enable an authorised person to examine the conduct of DFAT business
- protect the financial, legal and other rights of DFAT
- protect people affected by DFAT's actions and decisions.
This policy has been approved by the Secretary, DFAT and is the authority for recordkeeping within DFAT. It shall remain valid until such time as amended, revoked or otherwise superseded by the direct authority of the Secretary.
4. Review Date
This policy is due for review in 2013 in line with the release of the next Strategic Plan for DFAT Records Management 2013 – 2017.
This policy applies to all records from the time of creation or capture and covers:
- all DFAT staff, regardless of employment type
- all aspects of DFAT's business operations
- all types and formats of records created to support business activities
- all business applications used to create records
- organisations and businesses, including their employees, to which DFAT has outsourced its functions or activities, and therefore associated recordkeeping responsibilities.
It does not relate to records created by any other agencies, except where they form part of a DFAT business transaction.
6. Definition of a Record
Records are evidence of business conducted by an organisation. Any reference to a record in this policy refers to records in any format as defined in the Archives Act 1983. DFAT staff are responsible for keeping a record of any significant business transaction conducted as part of their duties for the department.
A significant business transaction might include documenting actions, events, conversations or other transactions where they provide evidence of formal advice or directions, or significant decisions. Records can be in any format. This includes but is not limited to:
- electronic documents – e.g. Word, Excel, Power Point
- hard copy documents
- paper or electronic files – e.g. EDRMS containers
- photographs – e.g. official photographs documenting business activities
- videos – e.g. video conferencing, teleconferencing
- data in business systems – e.g. PeopleSoft, SAP
- web content – e.g. public websites, intranet
- models, plans and architectural drawings
- electronic messaging – e.g. Email, SMS (short messaging services), instant messaging
- social media – e.g. twitter, Facebook, blogs
Social media is a relatively new form of communication for the department; staff who use these tools for their work should be aware that content published in this media may constitute a record as defined in this policy.
7. Digital Continuity and Digital Transition
In line with the Government's new Digital Transition Policy, DFAT is transitioning away from a predominantly paper-based records management system to digital recordkeeping. This means the majority of DFAT's records will be created, stored and managed digitally, and where possible paper records will be scanned to reduce the number of paper files. Digital formats are preferred over paper formats when reviewing processes or undertaking new initiatives or change.
Digital continuity plans will ensure that information is complete, available and useable by those who need it for as long as they need it. It also ensures that information is not kept for longer than it is needed.
8. Ownership of Records
All records, irrespective of format, (i.e. physical or electronic) created or received by all DFAT staff, in the course of their duties on behalf of DFAT, are the property of the Department and subject to its overall control. The only exception is if there is in place a contract or a legally binding agreement that states otherwise.
9. Access to DFAT Records
Under provisions of the Archives Act 1983, Freedom of Information 1982 and Privacy Act 1988, records created in DFAT can be released to the public on request, if they meet certain criteria. Failure to maintain or locate reliable records when requested, may lead to legal action or public embarrassment for DFAT.
Reforms to the Archives Act 1983 have resulted in the bringing forward the 'open access' period to most records from 30 years to 20 years, which began on 1 January 2011 and will be phased in over a ten year period.
Reforms to the Freedom of Information 1982 promotes a pro-disclosure culture across government ensuring the public's right to access records held by government agencies. It has simplified and narrowed the range of exemptions from access.
The Privacy Act 1988 governs the collection, use and disclosure of information about individuals to ensure that the information collected directly relates to an agency's functions. Under the Privacy Act, members of the public have the right to access records about themselves that are less than 30 years old.
Discovery Orders and Subpoenas
DFAT is regularly served with subpoenas or orders for the discovery of documents requiring the production of documents/records by a specified date.
Senate Continuing Order - The Department's Indexed List of Files (Harradine Report)In accordance with Senate Continuing Order, DFAT provides an indexed list of titles for files created in the head office of the department every six months. The list is published on the department's website.
10. Disposal, Deletion or Destruction of Records
It is an offence to dispose of, delete or destroy any Commonwealth record without authorisation from the National Archives of Australia (NAA). Under the Archives Act, 1983 and the Crimes Act, 1914, DFAT records cannot be disposed of other than in accordance with the approved NAA disposal authorities. The disposal authorities relevant to DFAT are the Administrative Functions Disposal Authority (AFDA) and the Departmental Agency Functions Disposal Authority (DAFDA). The Assistant Secretary, ICT Services Branch (ISB) and delegated staff in COR, are authorised by NAA to carry out disposal, deletion or destruction of records for DFAT.
Records created and received as part of DFAT's business that are of short term value and are not covered under a Records Authority can be considered for destruction using NAA's Normal Administrative Practice (NAP) provisions. These records can be disposed of by the creator,using the appropriate method, without seeking formal authorisation. Specific guidance on application of the NAP can be found in the Records Management pages on the DFAT Intranet.
11. Legislation & Standards
Certain federal government legislation provides direction on the management of federal government records; this legislation includes but is not limited to:
- Archives Act 1983
- Crimes Act 1914
- Electronic Transactions Act 1999
- Evidence Act 1995
- Financial Management and Accountability Act 1997
- Freedom of Information Act 1982
- Privacy Act 1988
- Public Service Act 1999.
- Australian Information Commissioner Act 2010
DFAT is also committed to ensuring that its recordkeeping and business systems comply with existing established standards and major reports into recordkeeping in the Commonwealth such as:
- Australian Standard for Records Management - AS ISO 15489 – 2009
- Australian Standard for Managing Records in an Electronic Environment – ISO 16175
- Australian Government's Digital Transition Policy
- NAA Digital Continuity Plan
- Various Policies and Guidelines published by NAA
- Protective Security Policy Framework
Additionally, DFAT is responsible for administering a range of legislation that may include specific recordkeeping requirements. A list of this legislation can be found at Appendix C.
12. Monitoring and Review
This Policy requires recordkeeping practices and processes to be a significant feature of all business processes and systems and it is the responsibility of all staff, regardless of level, to contribute to sound recordkeeping practices. In order to ensure that the policy is effective, DFAT will monitor recordkeeping practices in a variety of ways to ensure the compliance of all departmental activities.
Corporate Records Section (COR) is the line area directly responsible for monitoring compliance with the departmental recordkeeping framework and high-level assessment of the department's compliance with NAA benchmarks. This includes:
- monitoring the capture and creation of records into the official recordkeeping system –EDRMS, in particular identifying areas that may not be fully or correctly creating and/or capturing records into the recordkeeping system
- utilising NAA's "Check-Up" tool to identify areas of non-compliance and areas that need improvement; results will be used as a benchmark for future compliance activities
- annually facilitating an external records management audit as directed by the DFAT Audit and Risk Committee.
Each area of the department, including overseas posts, must periodically undertake a self-assessment of their compliance with DFAT's records management policies and reports the results to the DFAT Departmental Executive.
In addition to each officer's individual recordkeeping responsibilities, managers must ensure that their team is aware of their recordkeeping responsibilities as part of their daily functions. Managers should require all staff, including LES, to include an aspect of recordkeeping in their performance agreements.
The Internal Audit area, when conducting audits of DFAT activities, will assess the records relating to the audit subject and report any adverse recordkeeping findings in the final report to the Audit and Risk Committee.
13. Authorised Recordkeeping Systems
The EDRMS is the primary recordkeeping system for DFAT for the management of both physical and electronic records.
In addition, to comply with this Policy and NAA requirements, any DFAT business system that captures records must be capable of managing the following processes as a minimum:
- be capable of collecting all information required for the activity – it should be fit for purpose
- be capable of capturing content, structure and context of the record
- provide adequate and compliant storage of records
- provide protection of record integrity and authenticity
- ensure the security of records
- be readily accessible to all staff who need to use the records contained within the system, for as long as the record is needed
- undertake the disposal of records in accordance with approved disposal authorities
- ensure the recoverability of records in the event of a disaster
- ensure the availability of records in a useable format through technology changes and migration.
14. Roles and Responsibilities
This section defines the duties and responsibilities of all DFAT staff with respect to recordkeeping.
The Secretary is responsible for:
- authorising and promulgating this policy
- promoting compliance with this policy
- supporting and fostering a culture of good recordkeeping in the department
- nominating the Executive in charge of recordkeeping.
14.2 SES and non-SES managers, HOMs, HOPs and Regional Directors
SES and non-SES managers, HOMs, HOPs and Regional Directorsare responsible for:
- supporting and fostering a culture of good recordkeeping in DFAT
- ensuring that officers under their management are aware of their responsibility to maintain accurate records of business
- implementing measures to monitor compliance and to address inadequacies in recordkeeping practices.
14.3 CIO, Information Management and Technology Division (IMD)
The Chief Information Officeris responsible for:
- ensuring that recordkeeping policy and practices adopted by the department comply with DFAT's obligations and responsibilities as a Commonwealth Government agency
- ensuring that the technology used to support the systems that capture and keep records electronically are reliable, available and accessible to DFAT staff when required
- implementing standards for business information systems that comply with NAA's Standards and Guidelines for electronic recordkeeping, where warranted
- incorporating electronic recordkeeping requirements (as outlined in Clause 13) into operational and maintenance plans
- providing assurance that back-up and recovery strategies adequately meet electronic recordkeeping storage requirements
- the development and implementation, over time, of a comprehensive information management framework which incorporates records management.
14.4 Assistant Secretary, ICT Services Branch (ISB)
The Assistant Secretary ISB is responsible for:
- ensuring this policy is reviewed and is up to date
- ensuring that all DFAT staff are regularly reminded of their recordkeeping responsibilities
- in consultation with CIO, authorising each approved recordkeeping support system
- ensuring DFAT adheres to appropriate record retention and disposal requirements
- ensuring that TRIM EDRMS is available, reliable and accessible to staff when required
- supporting the implementation of TRIM EDRMS upgrades and enhancements, in compliance with DFAT's ICT Change and Release Management processes
- ensuring new and existing business support systems comply with this policy and NAA's electronic recordkeeping requirements.
14.5 Corporate Records Section
COR is responsible for:
- developing and implementing strategies to support this policy
- supporting and fostering a culture of good recordkeeping in DFAT
- creating and maintaining recordkeeping procedures with which compliance will be mandatory under this policy
- delivering recordkeeping and EDRMS training, support and advice to all staff
- maintaining, monitoring and reviewing the departmental recordkeeping system
- providing support to EDRMS users through effective service desk support arrangements
- promoting the effective use of the EDRMS
- liaising with IT Support Staff to ensure the EDRMS is available, reliable and accessible to staff when required
- liaising with IT Support Staff for the implementation of TRIM (EDRMS) upgrades and enhancements.
- ensuring that records are kept and accessible for as long as required by DFAT staff, government and the public
- monitoring and measuring compliance of recordkeeping support systems with this policy
- authorising, under delegation, the disposal/destruction of records
14.6 All DFAT Staff
All DFAT staff must:
- fully understand the recordkeeping obligations and responsibilities relating to their position
- adhere to DFAT's policy, procedures and standards in maintaining records as required by their daily tasks
- create and capture records in the appropriate recordkeeping system for specific business activities as outlined in this policy
- attend mandatory records management and EDRMS training
- ensure that they do not destroy records without the correct authorisation, except through the appropriate application of NAP
- be accountable for their actions and decision-making to the general public, Commonwealth Government and to DFAT's Stakeholders.
15.1 Appendix A: Glossary of Terms
A listing and explanation of significant terms used in the Records Management Policy is located below.
|Accountability||Based on the principle that individuals, organisations and the community are required to be accountable to others for their actions. Organisations and their employees must be able to account to appropriate regulatory authorities, shareholders or members, and to the public. This is required to meet statutory obligations, audit requirements, relevant standards, codes of practice, and community expectations.|
|Action Officer||Staff who conduct business on behalf of DFAT and record that business activity in either a paper or electronic format.|
|Activity (Business Activity)||An umbrella term covering all the functions, processes, activities and transactions of an organisation and its employees.|
This includes the following DFAT staff,
|Approved Recordkeeping System||A system that stores DFAT's Corporate information and complies with AS ISO 15489 – 2009 and ISO 16175|
|COR||Corporate Records Section.|
|Commonwealth Record||Any official record of the activities of a Commonwealth Government department or agency.|
Evidence (records that are written or otherwise recorded on any media) of the functions and activities performed by a Commonwealth government department or agency in the performance of their operations, or conduct of affairs.
The definition of record in the Archives Act 1983 is:
…a record means a document, or an object, in any form (including electronic form) that is, or has been kept by reason of:
|Digital continuity||Ensures information/records are complete, available and useable by those who need it. It also ensures that information/records are not kept for longer than needed.|
|Digital record||A record that is communicated and maintained in a digital format. Same as an electronic record.|
|Digital transition||The transition from paper and other physical formats to digital formats.|
|Document||A record of a business transaction on paper.|
|EDRMS||Electronic Document & Records Management System|
|Electronic Document||A document that is communicated and maintained in an electronic format.|
|Electronic Record||A record that is communicated and maintained in an electronic format. Same as a digital record.|
|File Number||A number attached to each file that serves as a unique identifier.|
|Function||The largest unit of business activity in an organisation or jurisdiction.|
|NAA||National Archives of Australia|
|Naming Conventions||Standards relating to the structure of the 'free text' part when naming files (including punctuation, capitalisation, use of acronyms ), and applied within the context of records management.|
|NAP||Normal Administrative Practice – NAA's disposal authority which gives approval for the destruction of information which falls into certain categories eg; ephemeral or short-term value, duplicates, error documents or non-business records|
|Record||See Corporate Record.|
|Records management||The discipline and organisational function of managing records to meet operational business needs, accountability requirements and community expectations.|
|Records Manager||The person responsible for managing official Commonwealth records in DFAT using the recordkeeping System. Responsibilities include all processes from creation to disposal of official records and ensuring compliance with legal and administrative requirements.|
|Scanning||The process of capturing an electronic image of a document for storage in an electronic document system.|
|Storage||The function of storing records for future retrieval and use.|
|Thesaurus (term)||A (keyword) thesaurus provides control and consistency over the vocabulary used for titling and indexing of records.|
|TRIM||TRIM is the records management software used by EDRMS.|
|Transaction||The smallest unit of business activity. Uses of records are themselves transactions.|
15.2 Appendix B: Summary of Recordkeeping LegislationMino
|Acts and Standards||Description|
|Archives Act 1983||
The Archives Act 1983 officially established the National Archives of Australia. The Act empowers the Archives to preserve the archival resources of the Commonwealth (those records designated 'national archives') and defines their role in supporting and governing the creation and management of these records. The Act establishes the framework in which agencies must create, capture and manage their records including:
|Electronic Transaction Act 1999||The Electronic Transactions Act 1999 provides a regulatory framework that enables business and the community to use electronic communications in their dealings with government. The primary objective of the Act is to remove impediments that might prevent a person from using electronic communication to satisfy obligations under Commonwealth law. Broadly, the Act provides that electronic communications and electronic forms of documents may be used to satisfy requirements or permissions, under Commonwealth laws, for a person to:
The Act provides for exemptions and it identifies conditions that must be met in order to maintain the integrity and accessibility of information.
|Evidence Act 1995||
The Evidence Act 1995 recognises the role of modern technologies in business and government. It abolishes the 'original document' rule and ensures that faxes, telexes and electronic communications may be admitted into evidence in all federal courts.
The Act contains a new definition of a 'document'. A document is defined as:
'anything on which there is writing, anything on which there are marks, figures, symbols or perforations having a meaning for persons qualified to interpret them or anything from which sounds, images or writings can be reproduced with or without the aid of anything else.'
If the document in question is an 'article or thing on or in which information is stored in such a way that it cannot be used by the court unless a device is used to retrieve, produce or collate it', it is permissible to tender 'a document that was or purports to have been produced by use of the device'.
To be admissible the record must be:
|Freedom of Information Act 1982||
The Freedom of Information Act 1982 provides that a person has a legally enforceable right to obtain access to a document of an agency or an official document of a Minister unless that document falls within one of the exemptions set out in the Act. Generally, exempt documents are those which must be kept confidential to protect essential public interests, personal or business information.
Under changes to the FOI Act 1982, agencies are required to publish agency plans as well as other specific categories of information.
|Privacy Act 1988||
The Privacy Act 1988 makes provision to protect the privacy of individuals and prevent the misuse of personal information about members of the public. It governs the collection, use and disclosure of information about individuals by Australian Government agencies to ensure that it is only used for purposes that relate directly to the functions or role of the agency. It specifies that the information agencies keep must be secure, accurate, relevant, complete, and not misleading. The Act also gives people a right to see records about themselves.Records over 30 years old are exempt from the Privacy Act. Access to these records is controlled through that Act.
Australian Information Commissioner Act 2010
The Australian Information Commissioner Act 2010 established the Office of the Australian Information Commissioner (OAIC). The OAIC has three sets of functions:
The OAIC aims to facilitate public access to government information and encourages agencies to proactively publish information.
|Australian Standard For Records Management - AS ISO 15489 – 2009||
The Australian Standard For Records Management - AS ISO 15489 – 2009 provides strategies and operational guidelines for the implementation of records management practices and procedures in any organisation. The Standards are designed to help organisations create, capture and manage full and accurate records to meet their business needs and legal requirements as well as to satisfy other stakeholder expectations. They apply to records in any format or media, created or received by any public or private organisation during the course of its activities.
|ISO 16175 Principles and Functional Requirements for Records in Electronic Office Environments||ISO 16175 provides internationally agreed principles and functional requirements for software used to create digital information in office environments. NAA has endorsed the use of ISO 16175 for use by Australian Government agencies|
Appendix C: Legislation Administered by DFAT
- Anti-Personnel Mines Convention Act 1998
- Australian Centre for International Agricultural Research Act 1982
- Australian Development Assistance Agency (Repeal) Act 1977
- Australian Passports Act 2005
- Australian Passports (Application of Fees) Act 2005
- Australian Trade Commission Act 1985
- Australian Trade Commission (Transitional Provisions and Consequential Amendments) Act 1985
- Autonomous Sanctions Act 2011
- Charter of the United Nations Act 1945
- Chemical Weapons (Prohibition) Act 1994
- Comprehensive Nuclear Test-Ban Treaty Act 1998
- Consular Fees Act 1955
- Consular Privileges and Immunities Act 1972
- Diplomatic and Consular Missions Act 1978
- Diplomatic Privileges and Immunities Act 1967
- Export Expansion Grants Act 1978
- Export Finance and Insurance Corporation Act 1991
- Export Finance and Insurance Corporation (Transitional Provisions and Consequential Amendments) Act 1991
- Export Market Development Grants Act 1997
- Export Market Development Grants (Repeal and Consequential Provisions) Act 1997
- Foreign Passports (Law Enforcement and Security) Act 2005
- Intelligence Services Act 2001, except to the extent administered by the Prime Minister, Attorney-General and the Minister for Defence
- International Development Association Act 1960
- International Fund for Agricultural Development Act 1977
- International Organizations (Privileges and Immunities) Act 1963
- Nauru Independence Act 1967
- Nuclear Non-Proliferation (Safeguards) Act 1987
- Nuclear Safeguards (Producers of Uranium Ore Concentrates) Charge Act 1993
- Overseas Missions (Privileges and Immunities) Act 1995
- Papua New Guinea (Application of Laws) Act 1973
- em>Papua New Guinea Independence Act 1975
- Papua New Guinea (Staffing Assistance) Act 1973, except to the extent administered by the Minister for Finance and Deregulation
- Registration of Deaths Abroad Act 1984
- Security Treaty (Australia, New Zealand and the United States of America) Act 1952
- South Pacific Nuclear Free Zone Treaty Act 1986
- Trade Representatives Act 1933
- Treaty of Peace (Germany) Act 1919
- United Nations Educational, Scientific and Cultural Organization Act 1947
- United States Naval Communications Station Agreement Acts
- US Free Trade Agreement Implementation Act 2004