Defending your defensible process

The source records disposal authorisation has been out for almost a month now! Wow how time flies (not records, records shouldn’t fly).

In the old digitisation disposal policy (DDP), one of the requirements was that you had to have your own DDP too. We’ve taken that bit out, but it’s been replaced by a requirement for you to have a defensible process.

How do you do one of those? We’re glad you asked.

While all the advice is on the website, we thought we’d pull it all together and expand on it a little to give you some more clarification around what needs to be in it and how it might work… and where to find all the info you need on the website.

In a nutshell, you need to document that you have applied a considered approach to the selection, digitisation, ongoing management, and disposal of records.

Your agency’s defensible process needs to work for your agency. You can use all or some elements from your previous DDP or another agency’s process if it suits your needs – just make sure it does work for you.

You can document your defensible process in one overarching document or you may feel that in your agency it works best incorporated into topic-specific documents, e.g. as part of your strategic recordkeeping plan, a separate digitisation procedure, a quality assurance checklist to be used when digitising.

Make sure you understand your legal requirements and responsibilities, and the requirements of the disposal authorisation, when developing your defensible process – it must be auditable or usable to prove that you can or have met all relevant conditions and requirements.

Process/procedure for exclusion of records

You can digitise whatever records you want, but if you’re going to destroy the originals afterwards you need to ensure no records excluded from the disposal authorisation are destroyed.

The process or procedure you used to ensure only eligible records are selected for disposal after digitisation must be included in your defensible process.

You can find the list of exclusions to source records disposal authorisation in the scope notes of the record class (in case you don’t know it’s 2074 in the GRDS). These exclusions include:

It’s also a good idea to check the Electronic Transactions (Queensland) Act 2001 (see Schedule 1 for exclusions) and acts administered by your agency. These might identify documents that require a physical signature and therefore may not be eligible for disposal after digitisation.

The other thing to think about is the likelihood of records being required for legal proceedings. If they are, check if there is a preference for paper or electronic forms of evidence that might apply, as you might also want to exclude these records too.  This will depend on the rules and procedures under which the relevant judicial or review body operates. Check out the advice on records required for legal proceedings or right-to-information requests for more details.

While they may not meet the exclusion criteria above, there are some records that may be less suitable for digitisation based on their original format, e.g. audio tapes, big maps and plans. You can find more information about different record formats and their suitability for digitisation on the digitise records web page.

Processes to ensure a complete, clear and accurate digitised record

A digitised record needs to be adequate for use in the same way as the original physical record, meaning it needs to be a complete, clear, and accurate version of the source record. So you need to be able to demonstrate that the digitised version is all of these things.

How you do this is up to your agency as you know how you want or need to use the record.  You also need to base this on the type of record being digitised and the information it contains. If it’s just text, then it’s a lot easier to capture all that information but if it’s a detailed map or plan, your process needs to detail how you ensure all the little lines and notes on your map or plan are captured.

Think about any technical specifications you may need to use. If you do need to use specific settings, even if it’s just for certain record types, make sure they are documented in your process.

Tech specs are optional, but quality assurance checks are a must. These are needed to ensure the digitised version is an accurate reproduction of the source record. Your defensible process will need to include details of your quality assurance checks and procedures. Our advice on digitising records includes quality checking, so have a look at that to determine what you need to do in your agency.

Procedures for appropriate ongoing management of digitised record

The usual recordkeeping rules apply – all records need to be accessible and useable for the minimum required retention period, and this applies to the digitised records too.

And digitised records need to be held somewhere, right? One of the requirements of the source records disposal authorisation is that the digitised records are held in a trusted system.

All of this means you need to document whatever process you have in place to ensure:

  • Digital continuity – that is, the records remain accessible for the required retention period despite any technological changes and system upgrades and all those kind of things. Check out sections 1 and 2 of the preserve records web page for information on preserving digital records and digital storage media.
  • Trusted systems – the records are managed in a trusted system that is managed securely and captures recordkeeping and event history metadata. To document this in your defensible process, include a list of trusted systems that will hold the digitised records.

Procedures for appropriate destruction of source records

All records need to be destroyed securely. This goes for the source records too.

Make sure your defensible process includes details of how the source records will be destroyed. You should also include information about when the destruction will occur. For example, destruction only occurs after a certain period to allow for quality assurance checks and just-in-case time to ensure source records are not destroyed prematurely.

This information also needs to demonstrate that the destruction of the source records is appropriate to their security level and that they can’t be reconstructed afterwards – just like normal destruction processes.

Head over to the how to destroy records web page for information on appropriate methods for destroying physical records.

Authorisation to dispose of source records

Last but not least, you also need to document that the source records were destroyed lawfully (under authorisation 2074 in the GRDS) and that you have internal endorsement to destroy them – same as all other records.

And like all other records, you need to make sure:

  • the authorisation is valid
  • you meet all the requirements
  • destruction is endorsed by your CEO or authorised delegate
  • the destruction is documented.

You know the drill… but in case you need a refresher head to the how to destroy records web page for all the details.

What about the old DDP?

Like we said in the beginning, the old Digitisation Disposal Policy used to require you to have your own DDP. If you’ve already got a digitisation disposal policy (as per the old requirements) or digitisation procedures or anything else, it can have a place at the party too as part of your defensible process. Just check if anything needs tweaking or updating slightly, or if you need to add anything to it.

Examples

We don’t have an example of a defensible process from Queensland to show you, but there are certainly some out there on that thing called the internet. They might not meet all of the requirements we have, but they might just be enough to make you go ‘Oh, I get it’.

And since we don’t have an example for Queensland, do you know anyone who has created a good one? Or have you already got one? Care to share to help out your fellow record keepers?

Let us know if you have a defensible process you want to share, or even if you have any questions about anything source records.

As always, you can contact us via email, the contact us form on the website, twitter, and here on the blogs. Don’t forget you can always talk to other recordkeepers on CORIM the forum and make sure you sign up for QSA Client News to stay up to date.

 

Featured image: Major Gen Stanke visits the Australian Comforts Fund and YMCA Rest Centre, Magnetic Island, c 1942 – 1945, DID 23890

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