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Recordkeeping Advice No. 2

Records Appraisal

Issued: 13 July 2005  

Recordkeeping Advices issued by the State Archivist provide advice on the management of records of State and local government organisations and support or explain recordkeeping requirements set out in formal State records guidelines.

Ian Pearce
State Archivist


Introduction

Appraisal is the process of evaluating an agency's business activities to determine which records need to be created and captured into recordkeeping systems and how long the records need to be kept, to meet business needs, the requirements of organisational accountability and community expectations. This includes determining which records should be kept as part of our community's collective memory and cultural heritage, that is, as State archives.

The process of appraisal is important to ensure:

  • that records are kept for as long as they are required by:
  • the agency for finite, identified periods
  • the Archives Office as State archives
  • that retention and disposal decisions are properly justified and documented

The Australian Standard for Records Management, AS ISO 15489 which has been endorsed in Recordkeeping Advice No. 5 provides an eight step methodology for the design and implementation of a sustainable records system. One of these steps is the identification of recordkeeping requirements that leads to the development of disposal recommendations based on these requirements. 

Identifying recordkeeping requirements

Identifying an agency's recordkeeping requirements is an essential step in the appraisal process and provides the rationale for the creation, maintenance and disposal of records.

There are three main types of recordkeeping requirements:

  • regulatory (or 'accountability' or 'legislative') requirements
  • business (or 'operational') requirements
  • stakeholder (government and public) expectations

Recordkeeping requirements may be stated explicitly in laws, regulations and other instruments of authority, or may be implied by the environment in which an agency operates.

They will refer to specific needs for evidence. For example, a requirement may state the need for:

  • the creation of a record
  • its retention for a specified period
  • its disposal
  • access conditions
  • the content of the record
  • the form it should be in
  • aspects relating to quality, that it is a 'proper' record

In order to identify recordkeeping requirements you should use both documentary sources and interviews. Different types of requirements will generally come from different sources. For example, a regulatory requirement for the creation of evidence will be found in a documentary source, whereas the business need to retain the evidence may come from an interview.

The first stage of identifying recordkeeping requirements is to find relevant internal and external sources, for example, specific regulations or legislation, requirements of internal business units, or external organisations.

Documentary sources may include information on stakeholder interests. Internal business interests may be reflected in policy and procedure material. Interviews are also an effective way to gather information about stakeholders' interests in records, and internal staff also will often know the interests of external stakeholders.

Regulatory requirements

Some regulatory sources may state only that a particular record, such as a register, be kept (i.e. created) and made accessible to certain individuals or groups. Other sources may be explicit about the content of a record. You should bear in mind that the same record or group of records may be required for more than one recordkeeping activity, and that some requirements will be described in more detail than others.

Implicit requirements will be more difficult to ascertain, and will take more time and effort to identify. While it is a time-consuming exercise, carefully checking relevant legislation, formal directives and standards for implicit references to recordkeeping requirements is an essential step in the requirements identification process. It provides a means of acquiring much of the contextual information needed to fully understand an agency's regulatory environment. Of course, this approach can be supplemented by an examination of corporate policies and procedures, and by interviewing personnel who are familiar with the relevant legislation, formal directives and industry standards.

Business requirements

Recordkeeping requirements that support business needs are likely to be identified in an agency's enabling legislation or other instruments of authority, or in the routines that establish and maintain its operations. Agencies that manage funds, for example, will automatically identify a requirement to make and keep evidence of the receipt and expenditure of those funds, as this is a routine part of conducting financial affairs.

A useful way to identify business requirements is to consider the chain of evidence an agency or individual needs to substantiate a sequence of decisions or actions. For example, copies of invoices sent provide evidence of income due in return for goods or services rendered. 

Existing policies, guidelines, work procedure manuals and standard operating procedures may identify when records relating to business functions and activities are created. Interviewing business area experts will assist in determining why these records are created.

Stakeholder requirements

Community expectations expressed by a wide range of external stakeholders can give rise to recordkeeping requirements that may or may not be reflected in business and regulatory requirements. Other government organisations may also be stakeholders with expectations about your agency's records retention and business units within an agency may have different requirements.

Stakeholders may have enforceable or legitimate interests in preserving records for longer than they are required by the agency itself. These may include stakeholders such as business partners, clients and other people affected by the agency's decisions or actions, and others to whom the agency should make its records available to meet accountability requirements, such as auditors, regulatory authorities and investigative bodies or researchers.

When researching recordkeeping requirements, it is important to address the interests of all internal and external stakeholders. These stakeholder interests may represent different types of recordkeeping requirement. For example:

  • a joint venture partner wants access to the agency's records of the venture for 10 years (a business requirement)
  • the business unit responsible for an activity regularly refers to the records for seven years after the event (a business requirement)
  • individual Tasmanians expect the agency to maintain records documenting their rights and entitlements (a community expectation)

Determining how long to retain records

Decisions on how long records should be retained are based on the recordkeeping requirements for the records.

In addition to the regulatory, business and stakeholder requirements the potential research value of the records should also be considered as this is a significant aspect of community stakeholders expectations. Many records created for a specific purpose have a research value unrelated to the reason for their creation.

Records identified for permanent retention are likely to be those which:

  • provide evidence and information about the agency's policies and actions
  • provide evidence and information about the agency's interaction with the client community it serves
  • document the rights and obligations of individuals and agencies
  • contribute to the building of an agency's memory for scientific, cultural or historical purposes
  • contain evidence and information about activities of interest to internal and external stakeholders

Documenting appraisal decisions

To ensure accountability it is essential that the process of identifying recordkeeping requirements is well documented and provides the necessary detail to justify the disposal recommendations submitted to the State Archivist in draft disposal schedules or when making one-off recommendations for the disposal of unscheduled records. The documentation should provide the rationale for each requirement and enable it to be traced back to its source.

Disposal recommendations should contain details of the identified recordkeeping requirements and indicate the source of the requirement including a specific part/section reference for legislation or other regulations.

Examples of recordkeeping requirements might be:

  • policy decision confirmed in interview with Manager A
  • research value - documents significant agency policy and provides unique agency information that may be useful to a researcher in terms of the agency role and processes confirmed in interview with Manager B
  • keep in accordance with Standard X, section Y
  • keep to provide evidence in case of litigation
  • based on Statute M, section N

Stakeholders should also be identified. This may be a particular business unit of the agency (eg audit section), or an external organisation or community group. It is possible that one requirement may have several stakeholders.

Draft disposal schedules submitted to the Archives Office should include details of the appraisal process including the identified recordkeeping requirements and relevant sources and stakeholders. When making recommendations for unscheduled records, the documentation should be held in the agency in preparation for consultation with Archives Office staff.

Acknowledgement

Acknowledgement is made to the National Archives of Australia DIRKS Manual for some of the content in this advice.

For more information

Australian Standard - Records Management - ISO 15489 www.standards.com.au