Disposal in the digital world – case study from ACECQA April 11, 2016

2440483357_9122fb84a0_oRecently we chatted with ACECQA about its efforts to implement regular disposal of records as a business as usual practice. ACECQA has very generously agreed to share its experiences, which may be useful for other NSW public offices.

This case study describes the approach ACECQA has taken to implementing records disposal, including the tools used, as well as the lessons learned from the process and ACECQA’s plans for the future.

We would like to thank the records and information team at ACECQA for taking the time to share their experiences with us.

Who are ACECQA?

The Australian Children’s Education and Care Quality Authority (ACECQA) is a national body established as part of the introduction of a national regulatory system for the provision of children’s education and care (referred to as the National Quality Framework (NQF)). ACECQA began operating in 2012.

The Council of Australian Governments (COAG) reviewed the role of ACECQA in the oversight of the NQF implementation in 2014, and will do so again in 2020.

Although it is a national body, ACECQA is subject to the State Records Act 1998 (NSW).

Recordkeeping at ACECQA

In 2014, ACECQA rolled out an electronic document and records management system (EDRMS). This EDRMS is provided as software as a service.

As a “start up” organisation, the Records and Information Manager assessed ACECQA’s organisational culture as being open to change and interested in adopting new technology. For this reason, ACECQA pushed through significant changes to practices as part of the implementation of the EDRMS.

ACECQA also uses a customer relationship management (CRM) system, which has been in use since 2012 and is now integrated with the EDRMS. Records created in the CRM system prior to the introduction of the EDRMS have subsequently been migrated to the EDRMS.

ACECQA is primarily digital in its recordkeeping. It maintains few paper records, which were created prior to the implementation of the EDRMS, but many of these were digitised as part of a recent office move. There still remains a small number of paper records that are maintained due to their non-standard sizes and difficulties in scanning.

Consolidated retention and disposal authority

There are five general and functional retention and disposal authorities that apply to ACECQA’s records. To facilitate disposal, ACECQA used these authorities to develop a consolidated retention and disposal authority.

The consolidated authority reduces the number of retention periods by combining classes where possible and increasing (“rolling up”) retention periods as required.

The consolidated authority is a tool for disposal. However, it has broader uses and has been used to identify records requiring specific management controls. For example, email messages sent through ACECQA’s CRM are stripped of their formatting. ACECQA has identified this as a risk for records of long term value (identified using the consolidated authority), so has implemented a work around to preserve the formatting of such messages.

Strategy for disposing of records

As a relatively new organisation without legacy records, ACECQA identified the opportunity to establish regular disposal as a business as usual practice. ACECQA hopes that by taking a proactive approach to disposal they will avoid having a backlog of records to dispose of should their functions be given to other organisations or if the organisation ceases to exist.

Sentencing on creation

ACECQA sentences records at creation. When a container is created, it inherits a disposal sentence from the business classification scheme terms used in its title. At creation all containers are also assigned an “owner”, which is the business unit responsible for the records in the container.

A number of the disposal triggers which apply to ACECQA’s records cannot be determined at creation (e.g. “after authorised officer ceases to be active” or “after [plans, frameworks, strategies etc.] superseded or no longer in use”). For this reason, retention periods are set to begin calculating when records become “inactive”, which ACECQA has defined as occurring 12 months after they are last accessed. For some records, this will not be appropriate – these discrepancies will be identified and fixed during the annual review.

Annual review

Each year, during December and January, the Records and Information Manager reviews the sentences applied to all containers which have become inactive. This review involves:

  • checking that the correct sentence has been applied based on the contents of the folder
  • ensuring that the trigger event has occurred.

If the sentence is correct and the trigger event has occurred, the container’s retention period starts counting down.

Annual destruction

Each year, during December and January, ACECQA destroys records which are due for destruction:

  • The Records and Information Manager will compile lists of containers that are due for destruction and forward these to the relevant “owners” (the senior managers of the relevant business units).
  • Senior managers will review the lists and, if they are satisfied that the records are no longer required, will approve the proposed destruction.
  • Two further levels of managers will confirm and approve the proposed destruction.

When records are deleted from the EDRMS, the metadata for the records will be kept. ACECQA has decided to keep all metadata for destroyed records, as the quantities are not unmanageable.

To prevent confusion, the metadata for destroyed records will be “hidden” from general users so that destroyed records do not appear when they search for records in the EDRMS.

ACECQA proposes to retain State archives in its EDRMS for 15 years before arranging transfer to State Records.

Lessons learned so far

The annual review is a drain on the operating capacity of the EDRMS. For this reason, the annual review and destruction activities will occur during December and January when fewer employees are in the office and using the EDRMS.

The process of disposing of records in an EDRMS is reliant on the technology, and it is not always apparent when errors occur. Some records cannot be sentenced and it is not clear why – these records must be set aside until the error can be identified and remedied.

ACECQA is one of the first organisations to use the EDRMS as a service offering. Support is therefore not always available immediately as bugs need to be fixed on a case by case basis.

Future ambitions

ACECQA is planning to workflow the disposal process in the EDRMS. This will require upgrading to the next version of the software.

As ACECQA becomes more familiar with the records disposal processes, a reduction in the levels of approval required before records can be destroyed will be investigated.

Image credit: nutmeg66 – “The only way is up” (CC BY-NC-ND 2.0)
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