• Section 1 - Purpose and Context
• Section 2 - Definitions
• Section 3 - Policy Statement
• Section 4 - Procedures
• Part A - Responsibilities
• All Staff
• Organisational Units
• Committees, Working Parties and Project Teams
• Part B - Records Management
• Archives
• Commercial Contracts/Agreements (value $150K or more)
• Destruction
• Legal Documents
• Protection
• Publications
• Relocation
• Restructure
• Retention
• Storage
• Student Records
• Vital Records
• Section 5 - Guidelines

Section 1 - Purpose and Context

(1) The University recognises records as the corporate memory of the institution. The University values records as a vital asset in supporting its daily functions and operations, and will provide systems and support for this purpose.

(2) This policy specifies the responsibilities of Western Sydney University, its employees, contractors, and its fully or partially owned entities, regarding the management of records.

(3) This policy does not apply to related organisations such as student associations, clubs and societies, or student unions although such organisations may enter into an agreement with RAMS for the provision of certain services, such as records storage, destruction and archives management.

(4) All University records are subject to the State Records Act 1998 (NSW), the Government Information (Public Access) Act 2009 (NSW), the Privacy and Personal Information Protection Act 1998 (NSW) and the Health Records and Information Privacy Act 2002 (NSW).

(5) Under section 10 of the State Records Act the Vice-Chancellor, as the "chief executive" of the University, has a duty to ensure "the [University] complies with the requirements of [the] Act and the regulations".

(6) This policy should be read in conjunction with the Intellectual Property Policy, the Code of Conduct and the Delegations of Authority Policy.

Section 2 - Definitions

(7) For the purpose of this policy:

1. Archives means those records that have been identified as having continuing value and that are kept permanently as part of the University Archives Collection.
2. General retention and disposal authorities (GA) means the authorities approved by NSW State Records identifying the minimum retention period for records, and whether they are required to be kept permanently or may be destroyed.
3. Legal document means all legal documents, such as memoranda of understanding, contracts and agreements, but excludes staff employment contracts.
4. Organisational unit means a clearly defined operational unit within each division or school as defined in the University structure.
5. Publications means any works, irrespective of format, issued for distribution or sale internally or to students or to the public. These can include, but are not limited to: calendars, handbooks, annual reports, books, pamphlets, leaflets, brochures, journals, newsletters, video recordings, audio recordings and films; but excludes publications produced by external bodies, stationery, and business cards.
6. RAMS means the University's Records and Archives Management Services Unit.
7. Record means any document or other source of information compiled, recorded or stored in written form or on film, or by electronic process, or in any other manner or by any other means as per the definition in the State Records Act.
8. Records management means the efficient and systematic control of the creation, receipt, maintenance, use and disposal of records, including processes for capturing and maintaining evidence of, and information about, business activities and transactions in the form of records as per the definition in AS ISO 15489.1:2002 Records Management.
9. Secondary storage means a records storage area, provided centrally through RAMS, used to store physical, semi-active records.
10. Semi-active records means records that still retain administrative, operational,fiscal, audit or legal value but are used infrequently in the conduct of current business and can be transferred from offices to secondary storage areas.
11. System of record means a business system that has been assessed by Information Technology and Digital Services and RAMS as meeting the compliance requirements of the Standard on Records Management.
12. TRIM (Content Manager) means the University's Electronic Document and Records Management System (EDRMS).
13. University records means any records made or received by any person in the course of the exercise of official functions in the University, or for any purpose of the University, or for the use of the University, and include records in any format such as hard copy, electronic, audio or video, film, photographs, publications and microfilm/fiche.
14. Vital records means those records that are essential for the ongoing business of the University, without which the University could not continue to function effectively, and which contain information essential to recreate the University's legal and financial position and preserve its rights and those of its employees, clients and stakeholders.

Section 3 - Policy Statement

(8) The University is committed to meeting its responsibilities under the State Records Act 1998 (the Act). Effective records management is part of the University's overall strategic decision making.

(9) All University employees, contractors and entities are responsible for the creation, protection and management of records of University activities they undertake, and must ensure those records are only used for proper and authorised purposes.

(10) The University records:

1. are its corporate memory;
2. provide evidence of actions and decisions;
3. represent a vital asset to support the University's daily functions and operations;
4. support policy formation and high level decision-making;
5. protect the interests of the University and the rights of employees, clients and citizens;
6. help the University deliver its services in consistent and equitable ways;
7. help the University to make good use of precedents and organisational experience;
8. support consistency, continuity, efficiency and productivity in program delivery, management and administration; and
9. form part of the cultural resources of the University, and also of the State where kept as State archives.

(11) Examples of University records can include, but are not limited to:

1. records of formal decisions taken by staff under delegation;
2. official communications to or from students, external persons and other organisations;
3. all correspondence created or received in the course of an investigation (eg misconduct, complaint, etc);
4. meeting papers of formally established University boards and committees (including agendas, agenda papers, minutes, reports and decision pages);
5. meeting papers of ad hoc committees and working parties (including agendas, agenda papers, minutes, reports and decision pages);
6. contracts, agreements or legal documents;
7. financial transactions held electronically or in hard copy format;
8. personnel transactions (eg reports on performance and other dealings between staff and the University);
9. the Online Handbook, which includes program/subject information and learning guides;
10. approved program and subject proposals and program accreditation documentation; and
11. research grant applications and records of application outcomes.

(12) All University practices and procedures concerning the management of its records must be in accordance with this policy.

(13) University records are the property of the University, and not of the staff member who created or received them.

(14) The University has a devolved model of records management by which organisational units are responsible for managing their records with the support of RAMS.

(15) The University uses TRIM (Content Manager) to manage all records and individual documents (except where they are captured in a separate system that has been assessed as a ‘system of record’). Refer to Knowledge Article KB0016005 (staff login to WesternNow is required to access this article).

(16) The University Archives Collection maintains records of significance to the University and to the broader community.

(17) The University keeps records that are required as State Archives within the University Archives Collection in accordance with the requirements set out in a Memorandum of Understanding with NSW State Records.

Section 4 - Procedures

Part A - Responsibilities

All Staff

(18) All staff, including contractors, must:

1. create full and accurate records of all University activities for which they are responsible and of all substantive or formal decisions they take in the service of the University;
2. attend TRIM (Content Manager) training on commencing with the University, as provided by RAMS;
3. save all University records into TRIM (Content Manager) (unless captured into an authorised ‘system of record’. Refer to Knowledge Article KB0016005 (staff login to WesternNow is required to access this article));
4. protect records in their custody from unauthorised access;
5. not destroy records without authorisation from their supervisor or from the Manager, Records and Archives Management Services; and
6. not maintain individual or separate files or recordkeeping systems or unmanaged electronic records except as otherwise authorised by the University.

Organisational Units

(19) Each organisational unit must:

1. ensure record keeping is built into all business processes of the unit;
2. ensure record keeping responsibilities are identified in all position descriptions;
3. ensure full and accurate records are made, and kept, of all activities carried out by the unit;
4. ensure records are retained in accordance with the relevant GA;
5. identify vital records;
6. maintain security for any physical records stored in office areas (particularly sensitive records); and
7. contact RAMS for advice and support.

Committees, Working Parties and Project Teams

(20) The secretaries and/or chairs of all committees, working parties and project teams must:

1. comply with all relevant University standards, guidelines and policies on records management in regard to the records of the committee, working party or project team;
2. create and keep full and accurate records of all committee, working party or project team meetings; and
3. save all meeting papers to TRIM (Content Manager), including agendas, agenda papers, minutes, reports and decision pages.

Records and Archives Management Services Unit

(21) The Records and Archives Management Services Unit (RAMS) is responsible for:

1. establishing, maintaining and delivering a consistent and effective records management regime across the University;
2. developing, facilitating and monitoring compliance with this policy and the Act, including relevant standards and codes of practice for records management;
3. educating staff on recordkeeping best practice and responsibilities;
4. training staff in the use of TRIM (Content Manager);
5. acquiring, centrally managing and maintaining the University Archives Collection which includes permanent records of the University and its predecessors;
6. making archives available for public inspection in compliance with the Act and relevant standards;
7. the authorised, secure and timely destruction of records held by RAMS (either in a physical storage or electronically in the TRIM (Content Manager) system) on behalf of business units; and
8. maintaining an onsite secondary storage facility for hard-copy records.

Part B - Records Management

(22) The following procedures are provided in alphabetical order.

Archives

(23) Staff are to coordinate the transfer of records that have been identified as having archival value with the University Archivist.

Commercial Contracts/Agreements (value $150K or more)

(24) As soon as practicable after a commercial contract/agreement is executed, the relevant organisational unit must scan/save the document to TRIM (Content Manager) in accordance with RAMS procedures.

(25) Procurement Services will complete recording of the contract into the Contracts Register in accordance with Section 27 of the Government Information (Public Access) Act 2009.

Destruction

(26) Records must not be destroyed if they are, or staff believe they have potential to become, the subject of a request under the Government Information (Public Access) Act 2009 (NSW), subpoena, or other formal request for access or relate to any ongoing action such as an appeal, regardless of whether the minimum statutory retention period has expired.

(27) Records registered in TRIM (Content Manager) may only be destroyed:

1. where the head of the organisational unit responsible for the records (or a senior delegate) has signed an undertaking that the records are no longer required to support the business of the unit and they are aware of no other legal, business or reference requirements for the retention of the records; and
2. in accordance with any instructions provided by the Manager, Records and Archives Management Services.

(28) In most cases, appropriate authorisation may be given in the form of a GA.

Legal Documents

(29) As soon as practicable after signing a legal document, the relevant organisational unit must send the document to RAMS (in accordance with RAMS procedures).

Protection

(30) Under Part 3 of the State Records Act 1998:

1. a person must not abandon, dispose of, transfer or offer to transfer, or be a party to arrangements for the transfer of the possession or ownership of, damage or alter, or neglect University records in such a way that causes or is likely to cause damage to them without appropriate authorisation from NSW State Records; and
2. a person found to be contravening these provisions may be subject to a personal penalty of $5,500.

(31) Where a supervisor directs a member of staff to illegally dispose of records in contravention of the Act, the supervisor, rather than the member of staff, may be subject to a penalty.

Publications

(32) As soon as practicable following publication, staff must deposit with the University Archivist a copy of each publication produced by or for the University.

Relocation

(33) Where an organisational unit is physically relocated, the unit must ensure records are properly managed by relocating them to new premises, digitising them or (after consultation) transferring them to RAMS.

(34) When relocating, the unit must ensure no records are left in the previous building or in any furniture being relocated as leaving records behind may constitute a contravention of Part 3 of the State Records Act 1998 and the responsible staff member may incur a financial penalty under the Act.

Restructure

(35) Where an organisational unit no longer exists, the unit manager must ensure the proper management and transfer of records (including electronic records on network drives, email folders and other locations) prior to the closure of the unit.

(36) Where a function of an organisational unit is transferred to another unit, the unit manager must ensure any records relevant to that function are transferred to the unit with responsibility for the function.

Retention

(37) All University records must be retained for the minimum retention periods identified in the GA that has been approved by NSW State Records for the University.

(38) Each organisational unit is responsible for evaluating whether the minimum retention periods identified in the GA are adequate for business needs. Minimum retention periods can be increased but not decreased.

(39) The organisational unit and RAMS must agree to any increase in minimum retention periods.

Storage

(40) RAMS centrally manages the storage of semi-active, hard copy records.

(41) When records are no longer required regularly and can be stored off-site, the organisational unit should transfer the records to RAMS (in accordance with RAMS procedure).

Student Records

(42) The Academic Record of each student is maintained within the Student Management System (SMS).

(43) Records providing documentary evidence to support information held in the SMS must be saved to TRIM (Content Manager) (in accordance with RAMS procedures). Example of records include, but are not limited to:

1. appeals;
2. assessment/grades;
3. change of grade (requests and approvals);
4. completion letters;
5. misconduct;
6. notification of prizes/awards;
7. Disruption to Studies (requests and supporting documentation);
8. student advice;
9. student progression/at risk; and
10. variation of program.

Vital Records

(44) The identification and protection of vital records is a primary objective of records management and disaster management planning, and will assist units in resuming normal business immediately in the event of a disaster.

(45) Each organisational unit is responsible for identifying and managing vital records in consultation with RAMS.

Section 5 - Guidelines

(46) Please refer to the Associated Information page.