Unpacking Policy Requirement 6 – Agencies must dispose of records in a planned and authorised way

Today’s blog post is about what you keep and what you don’t.

Previously, we wanted agencies to do two things: keep records for as long needed AND not dispose of anything without authorisation. While you still need to do these two things, our focus needs to shift. Agencies are producing more records than ever before, and the challenge is what to do with all of them.

The Records Governance Policy was written with this in mind. We wanted you to think about the how, not just the what. Like other parts of the Records Governance Policy, Policy Requirement 6 is about having a plan. It’s about systematic not piecemeal, recordkeeping.

And just like the other Policy Requirements, the key thing to takeaway from Policy Requirement 6 is that it’s about disposal that is in line with the Public Records Act 2002 and disposal authorities – but making sure it works for your agency. Not every agency is going to have the same needs – is your agency struggling with storage costs? Is your agency concerned with records that are high-risk if not disposed of? If so, you need to build your records disposal governance around your priorities and your legal responsibilities. How do you build your records disposal governance? Well you need to:

Use the disposal authorities issued by the State Archivist that provide proper coverage of the specific records you create and keep

You can find disposal authorities such as Retention and Disposal Schedules on the ForGov website. You may need to use more than one disposal authority to ensure you have full coverage of your records.

If you need more information on how to use Retention and Disposal Schedules including how you can load a schedule into a recordkeeping application, check out our advice on using a retention and disposal schedule.

What happens if you’ve got records that don’t fall within any Retention and Disposal Schedule? If they’re not permanent records and you don’t have any use for them, you can apply to the State Archivist for permission to dispose of them. Talk to us to find out how.

Don’t forget that even if something is covered by a Retention and Disposal Schedule, you still need endorsement from your CEO (or their delegate) to destroy a record.

You can work out the details of how you’ll seek this endorsement in your disposal plan.

Develop and implement a disposal plan, which details disposal decisions and actions for the agency

Plan, policy, process, pineapple – we don’t care what you call it, just what it does.

Your disposal plan is where you document how you’re going to go about your disposal.

It needs to cover:

  • How internal endorsement is sought and given for disposal
    • Think about who is or should be the delegated officer (if there is one). How will you bring requests to their attention? How will you deal with urgent matters? Do you have records that would be suitable for a standing endorsement to dispose (e.g. standing approval for timesheets to be disposed of after seven years)?
  • What disposal methods you’ll use
    • Think about issues of risk and security. Some records pose more risk if improperly disposed of than others. How will you make sure people use the right method for specific types of records?
    • Want to know more about the most secure disposal methods for all types of records? Have a look at our advice on How to destroy records.
  • How frequently you’ll dispose of records
    • Will you dispose of records on a regular basis or when you encounter storage issues? Will you treat low and high-risk records differently? How will you identify what records to dispose of when? Will you do it at creation or later? Will it be an automatic, computer-driven process or manual?
    • Need help matching records to disposal authorities? Find out how long to keep records (sentence records).

There are no right and wrong answers to the above questions. What you need to do is think about what answers (and therefore what plan) is right for you and your business needs. If storage isn’t an issue, maybe you’ll choose only to dispose of records that pose a risk if not disposed of. If storage is an issue, maybe you’ll dispose of records every year, or every quarter, or every month.

Along with your plan, you need to determine how you’ll implement it – what resources or tools do you need to support your plan.

The last thing you need to have in your disposal plan is how you’re going to document the disposal of records.

Formally document the disposal of records

When you dispose of records, you need to keep a record of the disposal. There’s no specific list of what information about the disposal you should keep but you should think about what information you need to know:

  • what was disposed of (e.g. metadata such as a description of the records, date/s of creation, creator/s, etc), and
  • how well your disposal processes are working (e.g. what disposal authority applied, who endorsed the disposal and when, what methods were used and by who).

You should note that there are mandatory metadata elements that relate to disposal. For more information, have a look at the Queensland recordkeeping metadata standard and guideline and our advice on applying metadata to records.

There you have it – the three elements of Policy Requirement 6!

We know this one can be a bit overwhelming. It’s no easy task to account for every type of record and decide when and how you’re going to dispose of them. The important thing is that you make a strategic decision about it rather than having a slapdash or reactive approach. Strategy and structure that works for your agency and your needs, that’s what the Records Governance Policy is about.

Keep an eye out for disposal related happenings. We’re being busy bees at the moment and changes are coming. We know that disposal isn’t the easiest and we want to change that. We are currently reimagining how the value of records is identified and how disposal is authorised. We want to ensure all Queensland public records are appropriately valued but without the current pain, risks and effort currently experienced. So, watch this space.

And…that’s all folks!

Thanks for coming along for our series on the Records Governance Policy requirements. We hope it helped you to understand the goals of the Policy and makes implementation easier.

If you have suggestions for future blog posts or there’s something about the Records Governance Policy you’d still like answered or have an opinion on something else entirely, get in touch! Leave a comment below, contact us by email, telephone, blog, Twitter– we want to hear from you!

Government Recordkeeping

 

Picture from Unsplash

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