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Records and Archives Management Policy

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Section 1 - Purpose and Context

(1) The purpose of this policy is to establish standards for the creation, maintenance and legal destruction of records and archives of Western Sydney University.

(2) This policy applies to:

  1. all academic and administrative units within the University, and to all University records generated, kept or received by them; and
  2. organisations that are fully or partially owned entities of the University;
but does not apply to related organisations such as student associations, clubs and societies, or student unions.

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

(4) Under section 10 of the State Records Act 1998 (NSW), 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" and that the Act and regulations are complied with.

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

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Section 2 - Definitions

(6) For the purpose of this policy:

  1. Archives - are 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 (GDA) - are the authorities approved by NSW State Records which identify the minimum amount of time records must be kept (i.e. retention periods) and whether they are required to be kept permanently or may be destroyed.
  3. Legal document - refers to all legal documents, such as memoranda of understanding, contracts and agreements, but excludes staff employment contracts.
  4. Organisational unit - is a clearly defined operational unit within each division or school as defined in the University structure.
  5. Publications - are 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 and handbooks; annual reports; books; pamphlets, leaflets, brochures, journals; newsletters; video recordings; audio recordings; and films; but exclude journals produced by external bodies; stationery; and business cards.
  6. RAMS - is the University's Records and Archives Management Services Unit.
  7. Record - is 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 (State Records Act 1998).
  8. RAMS Liaison Officer (RLO) - is a records officer within RAMS responsible for providing advice and assistance to organisational units.
  9. Records Management - is the field of management responsible for the efficient and systematic control of the creation, receipt, maintenance, use and disposition of records, including processes for capturing and maintaining evidence of, and information about, business activities and transactions in the form of records (AS ISO 15489.1:2002 Records Management).
  10. Secondary storage - is a records storage area, provided centrally through RAMS, used to store records that need to be kept for longer than the period for which they are required within the organisational unit (semi-active records).
  11. Semi-active records (or non-current records or semi-current records) - are records that still retain administrative, operational, fiscal, audit or legal value but are used only occasionally in the conduct of current business and therefore can be transferred from offices to separate [secondary] storage areas.
  12. TRIM - is the University's Electronic Document and Records Management System (EDRMS).
  13. TRIM Coordinator - a nominated staff member/s in an organisational unit with responsibility for overseeing the 'day-to-day' records management within that unit.
  14. University records - are any records made or received, and kept, 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 (State Records Act 1998 (NSW)), and include records in any format such as paper, electronic (email, spreadsheets, word processing documents, images, etc), audio or video cassettes, film, photographs, publications and microfilm/fiche.
  15. Vital records - are 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.
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Section 3 - Policy Statement

(7) The University is committed to meeting its responsibilities under the State Records Act 1998 (the Act) and to implementing best practice in its records management practices and systems.

(8) The University's 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.

(9) The University manages its records to conform to the requirements of the Act and any policies, standards, codes of best practice and other requirements issued by NSW State Records under the Act.

(10) All University practices and procedures concerning records management must be in accordance with this policy.

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

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

(13) The University uses the TRIM electronic records and document management system (EDRMS) to manage all records and individual documents except where they are captured in a separate system that meets relevant standards of NSW State Records.

(14) The University maintains an archives collection of records of significance to the University and to the broader community.

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

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Section 4 - Procedures

Part A - Responsibilities

Records and Archives Management Services Unit

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

  1. developing a standardised records and archives management system for implementation across the University;
  2. facilitating best practice in records and archives management across the University;
  3. keeping and maintaining the University Archives Collection;
  4. the authorised, secure and timely destruction of records;
  5. providing records management advice and assistance to clients (staff) throughout the University;
  6. assisting administrative units and academic units to establish recordkeeping systems;
  7. developing draft University policies and standards for records management;
  8. monitoring compliance with policies and standards, including performance of records management services and operations;
  9. assisting in the identification of vital records and ensuring their protection, and appropriate storage;
  10. providing secondary storage for semi-active records;
  11. making and administering arrangements for the monitoring of the University's records management program by NSW State Records as required by section 12(3) of the Act, such as the annual Records Management Survey;
  12. administering and maintaining the TRIM EDRMS;
  13. providing advice, training and assistance to staff in the appropriate creation, management, protection and retention of records, and the use of the TRIM EDRMS; and
  14. educating all staff on recordkeeping best practice and responsibilities.

Organisational Units

(17) Each organisational unit must:

  1. comply with relevant University standards, guidelines and policies on records management;
  2. ensure full and accurate records are made and kept of all activities carried out by the organisational unit;
  3. ensure the role of the unit TRIM Coordinator is assigned to appropriate staff within the unit;
  4. ensure recordkeeping responsibilities are identified in all position descriptions;
  5. manage the records of the unit;
  6. create and maintain appropriate files;
  7. determine appropriate retention periods in consultation with RAMS;
  8. determine appropriate access restrictions in consultation with RAMS;
  9. identify vital records; and
  10. maintain security for records stored in office areas (particularly sensitive records).

All Staff

(18) All staff 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 training on commencing with the University, as provided by RAMS;
  3. capture all University records into TRIM;
  4. protect sensitive 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.

Committees, Working Parties and Project Teams

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

  1. manage all committee records;
  2. 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;
  3. create and keep full and accurate records of all committee, working party or project team meetings; and
  4. register all meeting papers on TRIM, including agendas, agenda papers, minutes, reports and decision pages.

University Archivist

(20) The University Archivist centrally manages the University's archives by acquiring and maintaining permanent records of the University, and its predecessors, and making them available for public inspection in compliance with the Act and relevant standards.

Manager, Records and Archives Management Services

(21) The Manager RAMS is the Corporate Records Manager for Western Sydney University and is responsible for:

  1. establishing and maintaining a consistent and effective records management regime across the University;
  2. facilitating compliance with the Act including any relevant standards, codes of practice and other requirements as may be issued by NSW State Records under the Act; and
  3. authorising the disposal of records held by RAMS (either in physical storage or electronically in the TRIM system) on behalf of business units.

TRIM Coordinator

(22) Each organisational unit within the University must nominate a TRIM Coordinator for the unit.

(23) The TRIM Coordinator does not need to be a position that is solely dedicated to records management and may form part of the duty statement of the designated position. Larger organisational units may have more than one position with records management responsibilities.

Part B - Records Management

(24) Supervisors' approval for their staff to attend TRIM training is taken as approval for the staff to have relevant access to the system based on their position or role in the University.

(25) Although related organisations such as student associations, clubs and societies and student unions do not fall within the scope of this policy, they may enter into an agreement with RAMS for the provision of certain services, such as records storage, destruction and archives management.

Publications

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

Retention

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

(28) Each organisational unit is responsible for evaluating whether the minimum retention periods identified in the approved records retention and disposal authorities are adequate for business needs. Minimum retention periods can be increased but not decreased.

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

Storage

(30) RAMS centrally manages the storage of semi-active records.

(31) 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 guidelines located on the RAMS website.

Protection

(32) 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.

(33) In most cases, appropriate authorisation may be given in the form of a general retention and disposal authority.

(34) 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.

Destruction

(35) Records must not be destroyed if they are or may be 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.

(36) Records registered in TRIM 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 RAMS.

Restructure

(37) 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 and other locations) prior to the closure of the unit.

(38) 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.

Relocation

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

(40) 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.

Vital Records

(41) 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.

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

(43) As soon as practicable after signing a legal document, the relevant organisational unit must send the original document to RAMS and RAMS will:

  1. scan the document;
  2. save the image to TRIM in the relevant file; and
  3. place the document in secure central storage.

Archives

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

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Section 5 - Guidelines

(45) 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. financial transactions held electronically or in hard copy format;
  7. personnel transactions (eg reports on performance and other dealings between staff and the University);
  8. course/unit outlines and learning guides;
  9. approved course and unit proposals and course accreditation documentation;
  10. research grant applications and records of application outcomes.

(46) Please refer to the Associated Information page.