Records Management Policy

July 2009

Foreword

As a Commonwealth agency, DFAT has an obligation to maintain good records of its business activities for legal purposes. Our records are also vital assets that support our operations, enabling us to access the information we require and to preserve our corporate memory. They also 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 provides the vision for the department’s records management program. It sets the requirements for adequate and proper recordkeeping of business activities and decision making within the Department of Foreign Affairs and Trade (DFAT).

This document supports the Strategic Plan and articulates the policy which will be adopted within DFAT for managing these requirements. It provides guidance to staff in making the transition from a fully paper based records system to a predominantly electronic system as the Department’s Electronic Document and Records Management System (EDRMS) is introduced. It supersedes all previous recordkeeping policies.

This policy establishes a framework for the creation and management of DFAT’s records, regardless of format. It will be supported by instructions, procedures and other documents that will detail how specific types of records are to be managed and the operation of their associated recordkeeping system.

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.

Gillian Bird
A/g Secretary
Department of Foreign Affairs and Trade

1. Purpose

The purpose of this Records Management Policy is to provide a framework for the creation, maintenance, storage and disposal of corporate records within Department of Foreign Affairs and Trade (DFAT).

This policy, together with the Strategic Plan for DFAT Records Management 2008 – 2011, the Recordkeeping Procedures, and other supporting documents, 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 procedures which support this policy are intended to ensure that there are no gaps in DFAT’s records during its period of application and, specifically, as the Department makes the transition from a paper-based to a predominantly electronic recordkeeping system.

This policy replaces the DFAT Recordkeeping Policy dated May 2005 (issued under Administrative Circular P0649 of 1 July 2005).

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 best recordkeeping practices and systems to ensure the creation, maintenance and protection of accurate and reliable records. All practices concerning recordkeeping within this organisation are to be in accordance with this policy and its supporting procedures.

DFAT recognises its legislative and regulatory requirements as a Commonwealth agency, and is committed to meeting the practices set out in the International and Australian Standard for Records Management AS ISO 15489 – 2002.

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 to the extent necessary to:

To be full and accurate as per the Australian Standards for Records Management, AS ISO 15489 - 2002, all DFAT’s records should be:

Compliant - Comply with the regulatory and accountability environment in which DFAT operates, including the Archives Act 1983, Freedom of Information Act 1982, Privacy Act 1980 and the Evidence Act 1995. (Refer to Appendix 13.2 for a summary of each Act).

Adequate - Be adequate for the purposes for which the records are kept.

For example, a major initiative requires extensive documentation, while a routine administrative action requires only minimum information.

Complete - Provide sufficient information to explain the relationship between the data elements in the record and the business activity that gave rise to the record. Links between records that document a sequence of events must be maintained. Date, time (where appropriate) and action officer details must always be part of a record.

Comprehensive - Include all activities and transactions that may require documentation.

Meaningful - Enable the user to understand the transaction that gave rise to the record.

Accurate - Accurately reflect an activity or transaction.

Authentic - Records must be credible. It must be possible to prove:

Inviolate - Be maintained in a manner that prevents unauthorised access, alteration or removal. Information in a record must not be deleted, altered or lost. Information added to an existing paper record, must be initialled and dated.

For an electronic record, an audit trail must identify any changes. Information added subsequent to an initial record must not be presented as part of the original record.

Retained - Be retained for the appropriate period of time in accordance with DFAT’s disposal program.

DFAT's Recordkeeping Framework

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3. Authority

This policy complies with Archives Advice 57 “How to develop a Recordkeeping Policy”, developed by the National Archives of Australia, and complies with the Australian National Audit Office (ANAO), Audit Report No. 7 2003-04 “Recordkeeping in Large Commonwealth Organisations”.

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.

All practices and supporting documents concerning recordkeeping within DFAT are to be in accordance with this policy and any procedures issued under its authority. This policy supersedes all previous recordkeeping policies. Any amendments to the policy will be announced through an Administrative Circular and changes incorporated into the contents of the policy.

4. Review date

This policy is due for review in 2011 in line with the release of the next Strategic Plan for DFAT Records Management 2012 – 2015 or as required by the operational impact of introduction of the Electronic Document and Records Management System (EDRMS) and associated procedures.

5. Scope

This policy applies to records created by:

It does not relate to records created by any other agencies, except where these form part of a DFAT business transaction.

All staff, as stated above, must create full and accurate records of all business activities performed on behalf of DFAT.

All staff must be aware of their obligations under this policy and ensure their ongoing compliance. Disciplinary action can result from failure to comply with this policy.

6. Definition of a Record

Records are evidence of business conducted by an organisation. All 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. This includes ensuring that incoming or outgoing correspondence, minutes of meetings, records of conversations and telephone calls, cables, email, and other communications are placed on file.

In deciding what constitutes a significant business transaction, DFAT officers may wish to take into account guidance provided in the Australian Public Service Commission’s Management Advisory Committee (MAC) Report entitled Note for file: A report on recordkeeping in the Australian Public Service. More information is also available in DFAT’s Recordkeeping Procedures and related documents.

Records can be in any format. DFAT deals primarily with two types of records – physical (paper) and electronic. Any reference to “a record” or “records”, within this policy, refers to both physical and electronic records.

This includes, but is not limited to, the following:

See 13.4 Appendix D for a comprehensive list of DFAT document categories.

7. 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.

8. Public Access to DFAT Records

Members of the public have a right under the Archives Act 1983 and Freedom of Information 1982, to access records that DFAT creates in the course of fulfilling its functions (see Appendix C & D for more information). Failure to maintain or locate reliable records may lead to legal action. Below is a list of regulations under which DFAT records can be accessed by the public.

The Archives Act 1983 and the Freedom of Information Act 1982 (FOI Act) are the principal pieces of legislation available to the public to gain access to DFAT records. These Acts provide access in the following way:

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 by a specified date.

Senate Continuing Order No. 6 - The Department's Indexed List of Files

In accordance with Senate Continuing Order No. 6, the Department of Foreign Affairs and Trade provides an indexed list of titles for files created in the Department every six months.

Detailed instructions and guidance on Departmental procedures and obligations in respect of public access for DFAT records is outlined in Section 8.2 of the Recordkeeping Procedures.

9.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). The Assistant Secretary, Information Resources Branch (IRB) and delegated staff in COR, are authorised by the National Archives of Australia 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). 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 obtained from Corporate Records Section.

10. Legislation & Standards

DFAT is committed to complying with legislation related to recordkeeping, including the following:

DFAT is also committed to ensuring that its recordkeeping systems comply with existing established standards and major reports into recordkeeping in the Commonwealth such as:

Additionally, DFAT is responsible for administering a range of legislation with specific recordkeeping requirements including the Australian Trade Commission Act 1985, Charter of the United Nations Act 1945, Comprehensive Nuclear Test-Ban Treaty Act 1998, Consular Fees Act 1955, Diplomatic and Consular Missions Act 1978, Nuclear Non-Proliferation (Safeguards) Act 1987, Passports Act 1938, Security Treaty (Australia, New Zealand and the United States of America) Act 1952, South Pacific Nuclear Free Zone Treaty Act 1986 and Trade Representatives Act 1933. See Appendix C for a complete list.

11. 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:

Each area of the department, including overseas posts, is required to undertake a self-assessment of their compliance with DFAT’s records management policies in February of each year and report the results to DFAT Senior Management in the annual Divisional and Post Evaluation Reporting process.

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 (ARC).

12. Authorised Recordkeeping Systems

TRIM EDRMS is the primary recordkeeping system for DFAT. It manages both physical and electronic records in the one system.

In accordance with AC P0937, Cabinet Documents and drafts should be prepared, managed and stored on C-Net only.

In addition, to comply with DFAT Recordkeeping Policy and NAA requirements, any DFAT business system that captures records must be capable of managing the following processes as a minimum:

DFAT stores some records in business systems other than TRIM, notably separate databases and software applications. A review of the recordkeeping capability of IT systems across the Department will be undertaken following NAA’s release of an upgraded ‘Check Up Tool’ in 2009/10. Further guidance, including a list of compliant systems, will be included in the Recordkeeping Procedures at the completion of the review. In the interim staff should contact Corporate Records Section for guidance on the use of business systems other than TRIM to store electronic records.

13. Roles and Responsibilities

This section defines the duties and responsibilities of all DFAT staff with respect to recordkeeping.

13.1 Secretary

The Secretary shall be responsible for:

13.2 SES and non-SES managers, HOMs, HOPs and Regional Directors

SES and non-SES managers, HOMs, HOPs and Regional Directors shall be responsible for:

13.3 First Assistant Secretary, Diplomatic, Information Management & Services Division (DID)

The First Assistant Secretary DID shall be responsible for:

13.4 Assistant Secretary, ICT Services Branch (ISB)

The Assistant Secretary ISB shall be responsible for:

13.5 Assistant Secretary, Information Resources Branch (IRB)

The Assistant Secretary IRB shall be responsible for:

13.6 Corporate Records Section & EDRMS Project Team

COR & the EDRMS Project Team (for the term of the project) shall be responsible for:

13.7 All DFAT Staff

All DFAT staff must:

14. Appendix

14.1 Appendix A: Glossary of Terms

A listing and explanation of significant terms used in the Records Management Policy and Procedures is located below.

Term Definition
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.
All staff This includes the following DFAT staff,
  • all DFAT staff, including non-ongoing staff
  • all LES, funded by DFAT appropriations
  • all contractors, and
  • all consultants and service providers engaged by DFAT
Approved Recordkeeping System A system that stores DFAT’s Corporate information and complies with ISO 15489 – 2002.
COR Corporate Records Section.
Commonwealth Record Any official record of the activities of a Commonwealth government department or agency.
Corporate Record 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 2008 proposed 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:
  • any information or matter that it contains or that can be obtained from it; or
  • its connection with any event, person, circumstance or thing
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.
File Number A number attached to each file that serves as a unique identifier.
File User DFAT staff registered to access and use the Recordkeeping System.
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 (punctuation, capitalisation etc), and applied within the context of records management.
NAP Normal Administrative Practice
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 Records Keeping 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 DFAT authorised recordkeeping system
Transaction The smallest unit of business activity. Uses of records are themselves transactions.

14.2 Appendix B: Summary of Recordkeeping Legislation

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:
  • Imposing statutory obligations on all Government departments and agencies for the management of their records
  • Making it illegal to destroy or alter Commonwealth records without the permission of the Archives, unless otherwise stated by law
  • Creating a fundamental right of public access to most records over 30 years old and allowing for some access to younger records
  • Governing the retention and disposal of records.
Electronic Transactions 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:
  • give information in writing
  • provide a signature
  • produce a document that is in the form of paper or other material
  • record information in writing
  • retain a document that is in the form of paper or other material
  • retain information that was the subject of an electronic communication
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:
  • authentic - it must be clear that the record or document has not been altered or modified without authority;
  • complete and accurate; and
  • logically sequenced and arranged.
Freedom of Information Act 1982 The Freedom of Information Act 1982 governs public access to documents kept by Australian Government agencies. The objective of the Act is to extend as far as possible the right of the Australian community to obtain access to information in the possession of the Australian Government by requiring agencies to:
  • publish information about their operations and powers affecting members of the public; and
  • provide access to documents in their possession unless the document is within an exception or exemption specified in the legislation.
The FOI Act sets out certain documents that may not be accessed (exempt documents). Generally, these documents are those which must be kept confidential to protect essential public interests, personal or business information.
Privacy Act 1988 The Privacy Act 1988 aims to 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 the Archives Act.
Australian Standard For Records Management - AS ISO 15489 The Australian Standard For Records Management - AS ISO 15489 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. The Standard has been used as guidance in preparation of these instructions.

14.3 Appendix C: Legislation Administered by DFAT

14.4 Appendix D: DFAT’s FOI Statements

Freedom of information

This statement is provided in accordance with section 8 of the Freedom of Information Act 1982 and is correct to 30 June 2008. For updates please refer to the Department’s latest Annual Report.

It covers:

Functions, organisation and powers

The broad functions of the department are described in the Departmental Overview in section 1 of the 2008/09 Annual Report.

Legislation administered by the Minister for Foreign Affairs and the Minister for Trade is published in the Administrative Arrangements Order, which is available at http://www.pmc.gov.au/parliamentary/docs/aao_july_2008.pdf

Access to records under the Freedom of Information Act 1982

The Freedom of Information Act 1982 extends the right to obtain access to documents in the Government’s possession. Access is limited only by exemptions that protect essential public interests and the private and business affairs of people about whom departments and statutory authorities collect and hold information. Members of the public seeking access to documents should lodge a formal Freedom of Information request. This must be made in writing, be accompanied by the $30 application fee, and include a telephone number, a fax number (if available) and an address within Australia to which notifications are to be addressed.

Requests should be sent to:

The department’s state and territory offices can also be contacted for this purpose

Decisions on granting access to documents under the Freedom of Information Act 1982 are generally made by the departmental Senior Executive Service member responsible for the work area to which the request relates.

The department levies the applicable fees and charges imposed under the Freedom of Information Regulations (Fees and Charges). Such fees and charges may be remitted, reduced or not imposed for any reason, including if grounds of financial hardship or general public interest can be established. Further advice regarding fees and charges may be obtained from the department’s FOI Section.

Access to records under the Archives Act 1983

Records more than 30 years old are available for public access under the Archives Act 1983, except for information that falls into an exempted category. Archival records are not subject to the Privacy Act 1988 and most exemptions in departmental records relate to intelligence, security, defence or international relations sensitivities. Records are mostly held by the National Archives of Australia.

Applications for access under the Archives Act 1983 should be addressed to:

The Archives Act 1983 also allows the department to grant approved individuals special access to records not generally available to the public. Inquiries about eligibility for special access or information on departmental history should be addressed to:

The department also publishes a comprehensive range of public information on our website at http://www.dfat.gov.au.

Categories of documents

Documents are captured, managed and maintained in accordance with the department’s recordkeeping policy. Documents not needed for current business are transferred into archival custody or destroyed in accordance with an authorised disposal schedule. Australia’s overseas posts have documentary holdings of their own, which may parallel or complement those the department holds in Canberra and in state and territory offices. The department has extensive documentary holdings including:

Documents relating to relations and communications with foreign governments, the United Nations, United Nations agencies and other international organisations

Documents relating to the administration of UN sanction enforcement laws

Documents relating to treaties

Documents relating to multilateral, regional and bilateral trade policy, including negotiations for trade agreements and the World Trade Organization

Documents relating to international security issues, including disarmament, arms control and nuclear non-proliferation

Documents relating to public diplomacy, including information and cultural programs

Documents relating to the history of the portfolio

Documents relating to passports and secure travel identification

Documents relating to provision of consular services to Australian citizens abroad

Documents relating to overseas property management

Documents relating to personnel management

Documents relating to financial management

Documents relating to internal departmental administration

Documents relating to parliamentary services

Documents relating to legal matters

Documents relating to the Export Finance and Insurance Corporation Act 1991

Registers of Australian births overseas

The Department of Immigration and Citizenship (DIAC) records details of Australians born overseas. People may seek extracts from the registers through that department. Consular officials of the Department of Foreign Affairs and Trade performing functions under the Australian Citizenship Act 1948 at Australian overseas posts also maintain registers of Australians born overseas. Although data entered in our registers are regularly notified to DIAC, the registers themselves are held at the posts concerned. People may request and obtain extracts from the relevant posts.