Guidelines for the development of a functional records disposal schedule

Issued: November 2014

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The chief executive officer of a public sector organisation is responsible for the proper management and orderly disposal of their organisation's records. This document is designed to assist organisations in developing a functional records disposal schedule. A functional records disposal schedule identifies records dealing with functions which are unique to an organisation and not covered by general administrative disposal schedules.

The Information Act 2002 (the Act) states in s 131 that the chief executive of a public sector organisation has a duty to ensure that the organisation complies with Part 9 of the Act which deals with records and archives management.

In the Northern Territory there are two types of records retention and disposal schedules:

  • General Records Disposal Schedules that apply to records common to most or all public sector organisations
  • Functional Records Disposal Schedules that apply to records specific to a public sector organisation or function.

Records disposal schedules must be approved by the NT Records Service, the NT Archives Service, and the chief executive of the public sector organisation responsible for the function to which the schedule relates.

This guideline outlines the processes involved in developing and seeking approval for a functional records disposal schedule.

Developing a functional records disposal schedule offers a number of benefits to public sector organisations. These can include:

  • increased knowledge of records' holdings in the organisation
  • identification of areas where records are not being created
  • identification of records that can be destroyed, leading to cost and resource savings and legislative compliance
  • identification of permanent (archival) and vital records.

The appraisal of records and development of the functional records disposal schedule is a shared responsibility between the public sector organisation, the NT Records Service and the NT Archives Service.

Scope

This guideline applies to all public sector organisations as defined in Part 5 of the Information Act 2002:

  • an agency
  • a government business division
  • a government-owned corporation
  • a local authority
  • a statutory corporation
  • a person appointed, or body established, by or under an Act or by the Administrator or by a minister
    the Police Force of the Northern Territory
  • a person holding an office or position under an Act
  • a court of the Territory
  • a tribunal of the Territory
  • a person or body declared by the regulations to be a public sector organisation.

Purpose

To provide advice to public sector organisations on how to research, develop, document and gain approval for a functional records disposal schedule. Advice is also provided on maintaining and reviewing an approved schedule.

Authority

This Guideline is issued by the Department of Corporate and Information Services, NT Records Service.

Legal and regulatory framework

The regulatory basis for this guideline is defined in:

  • the Information Act
  • the Records Management Standards for Public Sector Organisations in the Northern Territory
  • Australian Standards AS ISO 15489: 2002 - Records Management.

Responsibilities

A public sector organisation has responsibility for:

  • planning the project and assigning suitably qualified and experienced resources
  • researching the functions and activities of the public sector organisation
  • identifying records in all formats, including records in business information systems
  • researching appropriate retention periods
  • developing draft functional disposal schedule/s and preparing supporting documentation
  • submitting the draft and supporting documentation to the NT Records Service for assessment by the Records Retention and Disposal Working Group (RRDWG)
  • responding to requests from the RRDWG for any further information
  • implementing the authorised schedule
  • reviewing the schedule on a regular basis.

More information on the Records Retention and Disposal Working Group.

Acknowledgement

The NT Records Service wishes to acknowledge the use of material produced by:

  • Queensland State Archives
  • State Records Authority New South Wales
  • State Records of South Australia
  • Public Records Office Victoria
  • LINC Tasmania
  • State Records Office of Western Australia
  • Territory Records Office Australian Capital Territory, and
  • NT Archives Service.

Identify the need to develop a functional records disposal schedule

Consider the General Disposal Schedule before developing a functional disposal schedule. If a function is covered by the general disposal schedule and all legislative, regulatory and community expectations are covered, then a functional records disposal schedule is not required.

For further information regarding General Records Disposal Schedules please refer to NT Archives Service.

Tip: If the function is carried out by more than one organisation it is probably covered by a general disposal schedule.

The following questions will assist in determining the requirement to develop a functional disposal schedule.

  • Is there a close relationship between your organisation and another in respect to these functions?
  • Is the organisation dependent on another organisation to complete work for this function?
  • Is the organisation dependent on another organisation for approval to any processes for this function?
  • Does the agency consult regularly with other organisations in relation to this function?
  • Are there joint committees with other organisations in relation to this function?
  • Are staff members seconded in relation to this function (either to or from the organisation)?
  • Is there any joint funding in relation to this function with another organisation?
  • Does another organisation or outside body hold records in relation to this function?
  • Does the organisation have agreements with other organisations relating to this function?
  • Do other organisations have responsibility in relation to legislation for the organisation?
  • Does the organisation report to a governing body in relation to this function?
    Does any other organisation perform these functions?

If the answer to all these questions is ‘No’, then it can be determined that the function is unique to the organisation. A project plan outlining the process will need to be developed.

If the answer to any of these questions is ‘Yes’, then it can be assumed that another organisation either performs this function in parallel, or that another organisation may contribute to the performance of this function in some capacity. In this case, the organisation in question will need to be consulted during the development of the schedule.

Gaining senior management support

Developing a schedule is a complex and time-consuming project with potentially wide ranging implications for the organisation. The chief executive officer has a duty to ensure the organisation complies with Part 9 of the Information Act 2002 (Records and archives management), and is not in breach of s 145 of the Act relating to the disposal of records. For these reasons, it is important to ensure senior management of the organisation understand and support the project. This support will help ensure adequate resources are allocated to the project and that appropriate senior staff of the public sector organisation are available for consultation during the development of the schedule.

As well as meeting legislative requirements, the project can generate a number of benefits that senior management should be aware of.

These include:

  • increased knowledge of records created by the organisation
  • identification of areas where records are not being created
  • identification of records that can be destroyed, leading to cost and resource savings
  • identification of vital records (vital records are those without which the organisation cannot operate and are required to re-establish the organisation's critical functions in the event of a disaster)
  • identification of permanent records (permanent records have historical value and will need to be preserved and eventually transferred to the NT Archives Service).

Savings in records storage costs will only occur if resources are allocated for sentencing records with expired temporary records being destroyed.

Staffing

Developing a disposal schedule requires detailed research and analysis and therefore a substantial time commitment. It is not a 'spare time' activity for existing staff and thought must be given on how to best resource the project.
Options include:

  • moving a staff member currently within the organisation offline to work on the project and back-filling their position
  • employing temporary staff to undertake the project
  • engaging consultants.

Each approach has both benefits and costs, as outlined in the table below:

ApproachBenefitsCosts
Moving staff member offline Have existing knowledge of the public organisation, its context and records. Knowledge gained through project retained by authority. Cost to backfill position.
Employing temporary staff member May have greater experience in developing schedules. Less disruption to existing work. Potential loss of knowledge gained through project. Cost to employ staff.
Consultant experienced in developing schedules Less disruption to existing work. Cost of consultant's fees. Agency staff supervision of project required. Potential loss of knowledge gained through project.

Regardless of which approach is selected, essential skills and knowledge required to undertake the project includes:

  • knowledge of the organisation
  • knowledge of modern records management practices
  • analysis and research skills, including functional analysis
  • interviewing and consultation skills
  • confidence to engage with senior administrative, professional and technical staff
  • understanding of records and record keeping systems
  • understanding of NT Records Service and NT Archives Service requirements
  • knowledge of applicable records management standards.

These requirements may be met by assembling a team of people, not necessarily all full-time, to work on the project. For example, the records manager and staff members who manage off-site storage and retrieval.

When using temporary staff and/or consultants it is essential that the project is actively managed by the public sector organisation and strategies are put in place to transfer knowledge during, and at the conclusion of, the project. A staff member with responsibility for records and record keeping systems may work closely with the consultant, bringing knowledge of the organisation and its practices.

It should be noted that the NT Records Service and NT Archives Service will not communicate directly with consultants without the knowledge of the public sector organisation.

Tip: Contracts for consultants should make it clear that they are responsible for documenting reasons for retention recommendations and contextual information in accordance with NT Records Service and NT Archives Service requirements, not just preparing a draft disposal schedule. The contract should also specify that the draft schedule and supporting documentation must meet the standard required by the Records Retention and Disposal Committee and that the consultants are available throughout the approval process. Without these conditions, the public sector organisation may have to undertake substantial revision of the schedule without the aid of the original consultant.

It is also important that staff and/or consultants with detailed knowledge of the project are available to consult with the RRDWG during the preliminary review and approval processes.

Stakeholders

It is useful to identify key internal stakeholders at the commencement of the project. Stakeholders might include business area managers, legal staff and internal auditors, and provide essential expertise on the value and uses of records in the organisation.

Information technology staff are also important stakeholders, especially in identifying the various business systems in which records might be held and developing an understanding of how these records are managed. These stakeholders may form a reference group to support the project, or be consulted on an individual basis. The interests of external stakeholders, whether other government bodies, private organisations, client / customer groups or the wider community, should also be taken into account during the evaluation process.

Timeframe

The project timetable should allow sufficient time for the key stages of the project:

  • the preliminary review of the draft schedule by the RRDWG and negotiation of changes (if required)
  • sign off by the chief executive and / or senior management of your organisation before formal submission to the Records Retention and Disposal Committee
  • availability of the Committee for formal submission of the schedule
  • feedback received and addressed by the public sector organisation.

How long a records disposal schedule project will take depends on the size of the organisation, how many functions it undertakes, and decisions on the scope of the project.

For a medium-sized organisation with a limited range of functions and one person working full-time, it may take approximately three months to develop a schedule covering current records and a small legacy collection. In contrast, for a large organisation with a wide range of functions, many offices to cover, e.g. regions and extensive legacy collections, it may take considerably longer and require a small team of staff to identify and evaluate all current and legacy records. In this situation a phased approach could be adopted in consultation with the RRDWG.

The length of time required to complete the formal approval process depends on a number of factors including:

  • size of the organisation
  • quality of work submitted
  • level of detail in the draft schedule and supporting information
  • complexity of the schedule (for example, whether extensive legacy holdings or a large number of functions are covered)
  • timeliness of responses from public sector organisation staff on issues raised by the RRDWG

Planning the project

Developing the functional disposal schedule to cover core-business records of a function within a public sector organisation is a significant project particularly in medium and large organisations.

Stages of the project

There are five main stages in developing the schedule:

  • establish a project plan and identify resources, timeframes and deliverables
  • undertake contextual and background research, including records holdings
  • identify retention requirements through stakeholder consultation
  • draft the records disposal schedule and supporting documentation
  • submit drafts to the Records Retention and Disposal Working Group for comment and referral to the RRDC
  • seek approval.

It is important to consider ongoing issues early in the project. For example, the documentation produced to support the schedule, legislative mapping, record class description forms and retention period justifications should be sufficiently detailed to be able to be considered by the Records Retention and Disposal Committee.

Overview

Knowledge of the public sector organisation, its administrative and legislative context, and its functions and activities needs to be linked to a detailed analysis of its business processes and the records these processes create.

The analysis of records and business processes gives an understanding of how records are created in practice and how they support business processes.

Information collected from consultation and research is captured in the mandatory documentation required for the approval of a disposal schedule.

Sources for research

A number of written sources are useful in the research supporting the project. Some of these are identified below.

Administrative arrangements order

  • sets out the principal responsibilities of ministers and the acts that they administer.

Annual reports

  • identify business activities of the organisation
  • may identify various business systems that contain records, for example, by reporting on the implementation of new systems to manage business processes
  • identify relevant legislation
  • past annual reports are useful for historical analysis supporting the appraisal of legacy records.

Authorised or draft disposal schedules of the organisation

  • identify previous retention periods and classes of records created
  • record class description forms may contain valuable research information
  • may still have valid disposal actions and can be included in the proposed new schedule with updated information
  • identify records holdings, including legacy records.

Corporate internet/intranet sites

  • identify activities and processes
  • may identify business systems that contain records.

Corporate plans and strategies

  • identify functions of the organisation.

Information audits

  • if available, can be used to identify all formats used to create and retain information of the organisation.

Interviews and consultation

  • interviews, workshops or focus groups with relevant staff are an essential means of gathering information and obtaining confirmation on other research. They can also be used to promote good record keeping and gaining support for the project.

Legacy records

Most public sector organisations have collections of older records that have not previously been appraised. Sometimes these records have been inherited from predecessor organisations  or document functions and activities which may no longer be performed by the public sector organisation.

Public sector organisations are required to document any records created prior to 1 July 1978 that are in their custody and contact the NT Archives Service to have them appraised for permanent retention.

For further information regarding records created prior to 1 July 1978 please refer to Disposal of Government Records Created Prior to 1 July 1978 found at NT Archives Service.

Legislation

Researching and documenting relevant legislation is an essential part of developing a functional records disposal schedule. Legislation:

  • sets out the role and powers of the public sector organisation
  • may contain requirements to create records (either implicitly or explicitly). For example it may set out processes that must be followed, with implicit requirements to create records, for example 'applications must be assessed' implies that assessment documents will be created
  • may contain explicit information on how long records must be kept
  • may contain implicit information to help identify retention periods, for example length of appeal period.

It is strongly recommended that public sector organisations developing disposal schedules map their legislative requirements. This assists in identifying all explicit and implicit recordkeeping requirements prescribed in legislation and ensures they are covered in the schedule.

Legislative mapping involves the listing of provisions under the relevant legislation, noting any record implications (such as the creation of records or their retention) and where appropriate, noting the reference number where these records are covered in the draft disposal schedule.

Public sector organisations should also check all acts and subordinate legislation (regulations) that they administer as well as any regulatory legislation to which they are subject (although it may not be necessary to map those sections that do not apply to the public sector organisation). It is also important to identify any repealed legislation that affected past activities and therefore legacy records.
Business areas that administer the legislation must be consulted.

Ministerial portfolio statements

  • useful for core government agencies
  • include information on outputs, key strategies and achievements for each agency within a portfolio
  • may include information on legislation and relationships with other public sector organisations.

Organisational charts

  • identify key parts of the organisation and provides overview of work
  • can be used as 'checklist' to identify areas for research and consultation.

Policy and procedure documents for business areas

  • identify activities and processes
  • identify requirements to create records, explicitly or implicitly
  • may identify business systems that contain records.

Standards and general orders

  • identify activities and processes for compliance requirements.

Investigating context

Investigating the context of the public sector organisation is a key step. It helps develop an understanding of the administrative, legal, business and social contexts in which it operates. It can also identify the major factors that influence its need to create and maintain records. The contextual information is very important in clarifying the scope of the draft disposal schedule.

Identifying and describing functions and activities

Functions are the largest unit of business activity in a public sector organisation. Activities are the major processes performed by the organisation to accomplish each of its functions. An activity should be based on a cohesive grouping of transactions producing a singular outcome. Transactions are the individual steps or actions involved in an activity or process - for example, in an authorisation process, transactions may include:

  • receive application
  • assess application against criteria
  • approve or reject
  • enter decision on system
  • prepare response
  • issue authorisation if approved.

Examining the transaction levels helps to ensure that there is no overlap between activities and identifies the type of records created.

Functions and activities provide the structure for a disposal schedule. Most public sector organisations already have a current business classification scheme and can adopt this for use in the disposal schedule.

In identifying functions and activities:

  • consider what makes the public sector organisation unique and include these functions and activities
  • write scope notes for each function and activity that give a succinct explanation of what is, and what is not, covered by the term.

A number of activities, such as policy, advice, meetings and procedures, are common to many functions, whether administrative or unique to a public sector organisation. In analysing the functions specific to the organisation, note which of these common activities occur under the specific functions.

Coverage of these common activities, regardless of the 'parent' function, is included in the general disposal schedules. It is necessary to determine whether the general disposal schedule's coverage is sufficient.

Researching records holdings

In developing a comprehensive functional records disposal schedule, it is important to be aware of all record holdings of the public sector organisation, regardless of age or format. This is usually done via a records survey.

Collect as much information as possible about the records identified, including:

  • quantity
  • date range (this is particularly relevant for legacy records)
  • format/media
  • the relationship between different record keeping systems, both paper and electronic. For example, do clients fill out paper forms that are entered on a database and placed on a file?

Identifying requirements

Records' retention must be based on:

  • the current and future business needs of the organisation
  • compliance with legal and governance requirements of the organisation
  • the current and future needs of internal and external stakeholders including the wider community.

The main sources for determining retention periods are:

  • administrative and legal precedent
  • legislation
  • policy
  • procedures
  • general orders
  • standards such as ISO 9000 or National Association of Testing Authorities (NATA)
  • community research requirements.

When interviewing staff members, rather than asking ‘how long should a record be kept?’ ask more specific questions about how they use the record, for example:

  • do you need to refer to the record again after the matter is completed?
  • how long after a record is created do you refer to it?
  • what is commonly the last action in a particular transaction (there may be several scenarios)?
  • is there a legal reason or an appeal process that you might need the record for?
  • do other areas of the organisation use the records (for example, internal auditors)?
  • is there a community interest in the records?

There is an expectation by the community that certain records will be made available for research and historical purposes.

Special format records

It is important to ensure that all records of the public sector organisation are covered by the functional records disposal schedule, regardless of format. Records often overlooked include:

  • photographic collections
  • maps and plans
  • moving images
  • databases and other corporate systems
  • online resources and services.

Relating retention requirements to functions and activities

While functions and activities provide the framework of a records disposal schedule, an understanding of how records are organised is also important. During the analysis process, different activities may have been identified but in practice they all appear on a single file. A decision will need to be made on whether to replace the identified activities with a single term. For example, identified activities of applications, renewals and notifications, which all appear on a single file, can be indicated by a term such as authorisation or project management.

Paired classes – major / minor

Disposal schedule classes often use terms such as ‘major’ or ‘significant’, contrasted with classes for ‘minor’ or ‘other’ records relating to the same activity. When using major / minor distinctions it is important to clarify in the ‘description of records’ in the disposal schedule, what is meant by these distinctions. For example, it might be qualified by whether a building is heritage listed for permanent retention of plans, or if there was a major shift in policy or where a new precedent is set.

Privacy and security

Many records contain information on individuals, which gives rise to privacy concerns. While privacy is an important concern, it is not a reason in itself to destroy a record, unless destruction of the record was explicit when the records were created, (for example, the collection of survey data). Some records that are sensitive from a privacy perspective, such as personnel or workers' compensation files, also require long retention periods to protect an individual's rights and entitlements.

Disposal triggers

In addition to the actual retention period, a ‘disposal trigger’ must be identified, that is the event from which the retention period must be calculated. The most common trigger is ‘action completed’. Action completed is the date of the latest document or notation attached to the file, or the last update made to the record in the database.

The selection of the disposal trigger may also depend upon the type of record and the reason for retention and / or disposal. Other common triggers include (x years) ‘...after superseded’, ‘...after expiry of agreement’, ‘...after date of birth’.

The practicality of disposal triggers must ensure they are applicable and machine readable.
Permanent retention means that the record cannot be destroyed and will be transferred to the Northern Territory Archives Service as a Territory Archive.

Please note: For consistency of disposal triggers across government the current version of Administrative Functions of the NTG is an excellent guide for the types of disposal triggers typically in use.

For further information please refer to The Australasian Digital Recordkeeping Initiative (ADRI) Glossary of Disposal Schedules.

Mandatory templates for disposal schedules

These are the mandatory templates to be used by public sector organisations to document information relating to functional records disposal schedules.

TemplateDescription
Appendix A: Disposal schedule template DOCX (651.4 KB) To be used as the draft schedule for submission.
Appendix B: Class description form DOCX (56.5 KB) One form needs to be provided for each class within the draft disposal schedule (above).
Appendix C: Function class description form DOCX (55.1 KB) Only to be used if a new function (keyword) is being proposed.
Appendix D: Sample memorandum DOCX (62.9 KB), including written endorsement and background information for submission of a draft disposal schedule to the Records Retention and Disposal Committee Example of letter from senior management requesting the draft schedule and supporting documentation (Appendices A to C above) be considered by the Records Retention and Disposal Committee.
Appendix E: Letter from CEO of organisation for final authorisation DOCX (691.9 KB) Accompanies the formal authorisation (Appendix F below) requesting the Records Retention and Disposal Committee submit the schedule for final approval by the Director NT Archives Service and Director, NT Records Service.
Appendix F: Authorisation form for the disposal schedule DOCX (681.4 KB) Document signed by agency CEO and submitted for the Director NT Archives Service and Director NT Records Service to sign, formally authorising the disposal schedule for use. Accompanies the CEO letter requesting authorisation (Appendix E above).

Before submission to the Records Retention and Disposal Working Group

Consultation

The draft disposal schedule must be circulated to key stakeholders in the public sector organisation, such as business managers, audit, legal and information officers, for comment before submission of the draft to the RRDWG.  Stakeholders should be made aware that feedback from the RRDWG may result in further changes.

Draft disposal schedule/s and associated documents submitted to the NT Records Service for consideration by the working group must include:

  • function class description form
  • record class description forms
  • first draft of schedule

Type of feedback an agency may receive from the Working Group

Feedback may include:

  • clarification on the record class covered by the schedule
  • clarification of the reason for the retention or destruction of particular record classes
  • suggested changes to retention periods based on experience with previous disposal decisions and knowledge of related records in the Northern Territory Archives Service
  • establish if the records will have longer-term interest to the Northern Territory community
  • relationship between the functions and activities documented in the schedule and in other disposal schedules
  • request more information on the background or history of the functions and activities documented in the schedule.

Formal approval

After the RRDWG review process is completed, feedback (if required) is addressed and agreement has been reached, the disposal schedule will need to be authorised by the chief executive (CE) of the organisation, the Senior Director, ICT Policy and Governance (the Records Service) and the Director, NT Archives (the Archives Service).

The Senior Director, ICT Policy and Governance (the Records Service) and the Director, NT Archives (the Archives Service) will require:

  • hard copy and electronic version of the final draft, as signed off by the CE of the organisation
  • letter of request for approval of the disposal schedule from the organisation (see Appendix E for sample document)
  • signed original of the authority form (see Appendix F).

Agencies will lodge final documents in the first instance with the NT Records Service for authorisation.

The NT Records Service will facilitate the final approval through the Records Retention and Disposal Committee (RRDC).

NT Archives Service will register the disposal schedule in the Register of Disposal Authorities and formally notify the organisation of the final approval and the registration number allocated to the disposal schedule. A version of the disposal schedule will be published on the NT Archives Service (DoAM) and the NT Records Service (DCIS) websites.

Implementing a functional records disposal schedule

Once a new schedule is approved, the organisation will need to ensure relevant staff are made aware that the disposal schedule is available for use. Relevant work procedures and manuals should be amended to incorporate protocols for the disposal of records described in the schedule.

The new schedule will need to be loaded into the organisation's recordkeeping system. If the schedule supersedes a previous one, the former schedule will need to be deactivated and noted on the recordkeeping system as 'superseded'. A copy is required to be retained in the record keeping system so earlier decisions can be checked and validated if necessary.

It is also recommended that a copy of the disposal schedule is posted on the organisation's intranet site for internal clients' reference.

Maintaining a functional records disposal schedule

Public sector organisations, the work they do and the environment they work in, are not static and neither is the disposal schedule.

A public sector organisation is responsible for regularly reviewing its disposal schedule(s) to ensure they remain aligned with business, legislative, regulatory, administrative, cultural and community needs.

Reviewing a functional records disposal schedule

In addition to ongoing maintenance, disposal schedules should be reviewed on a regular basis in accordance with NTG standards. Events that may influence the content of a disposal schedule include:

  • administrative changes, for example, a restructure
  • a function or several functions change
  • there is legislative change affecting the responsibility of the public sector organisation
  • new legislation is enacted or current legislation repealed (for example, a requirement to keep certain records changes)
  • record keeping system changes (for example, from a paper-based to an electronic system)
  • plans are made to commercialise or privatise the business of the public sector organisation.

As with the development of a disposal schedule, please notify the NT Records Service when planning a review.

The review should involve a re-analysis of the organisational and record keeping context for any changes that may have occurred.

However, if the review has been initiated as a result of an administrative change or as a result of inheriting functions from another public sector organisation or internally within the organisation, a detailed analysis of the scope, history, regulatory context and records will be required for those new functions. Consultation should again be undertaken as part of the process.

Regardless of the reason for the review, any changes and supporting research should be documented in new versions of background research, such as the record class description form and the function class description form.

The new revised version of the disposal schedule will need to be submitted to the RRDWG.

Amending a functional records disposal schedule

There are several reasons to justify an amendment/s in a published schedule.

For further advice please refer to procedure for Requesting an amendment to a records disposal schedule.

Last updated: 07 March 2019

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