Administrative change - recordkeeping issues
Revised: September 2012
The purpose of this Records Management Advice issued in accordance with s 131A(c) of the Information Act 2002, is to inform and assist NT Government public sector organisations of the issues they need to consider when identifying and managing records (in any format) affected by Administrative Change.
What is administrative change?
An administrative change refers to a change in the way that government business is allocated. It is also known as a machinery-of-government change. Administrative change often happens after the following:
- an NT Government election
- sector restructures
- major departmental restructures
- new legislation or legislative amendment creating a new agency
- commercialisation of a government entity
- changes of Cabinet members or a redistribution of Cabinet portfolios.
The impact of an administrative change can include:
- the transfer of a function or functions from one public sector organisation to another
- the transfer of a function or functions from a public sector organisation to a non-government entity
- the assignment to a public sector organisation of a function previously carried out by a non-government entity
- the abolition of an existing function or public sector organisation.
All public sector organisations impacted by administrative change are required to comply with the Information Act 2002 during and after change. Compliance includes the appropriate management, retention and disposal of records.
Section 135 of the Information Act deals with the transfer of records and is quoted in full below:
“Where a function is transferred from one public sector organisation to another public sector organisation, the first mentioned organisation must transfer to the other organisation all of its records relating to that function (including records relating to the control of those records).”
The underlying principle here is that records follow the function, with the agency responsible for the function controlling all records relating to that function. Previously some agencies have tended to transfer only active records, with the inactive records continuing to be held by the agency no longer responsible for that function. Over time this has led to record series becoming fragmented and dispersed, increasing the likelihood of records being abandoned and lost.
Transfer of records - in any format - must be recorded so that a clear audit trail exists in the corporate records management system of both the transferring and receiving agencies.
The transferring agency is responsible for identifying all records relating to the function being transferred. Both current and non-current records should be identified, including records in business systems, stored in-house, in external storage and in the custody of the NT Archives Service. The transferring agency has a responsibility to ensure that all relevant information is identified.
The receiving agency is responsible for incorporating the transferred records into their corporate records management systems and ensuring that the records are identified as transferred from another agency.
Establish a joint information transition team
To facilitate an efficient transfer of records, discussion should be entered into at an early stage between the transferring and the receiving agencies to ensure both are aware of their recordkeeping responsibilities. It is recommended that a Joint Information Transition Team be established to identify and manage the handover of information and develop a transfer agreement that clearly identifies requirements.
The Joint Information Transition Team should consist of:
- business managers (responsible for functions under transfer)
- records managers (including TRIM administrators)
- business systems managers (including authorised administrators)
- IT specialists
- Freedom of Information officers.
The Joint Information Transition Team may also need to work through interim management arrangements during the transition period, including ongoing access post transfer, if required. A key objective of the Team is to ensure services and outputs of the business function are not affected by the transfer.
The agreement should include details such as:
- which records are to be transferred
- roles and responsibilities
- responsibility for transfer costs
- formats for transferring electronic records
- transfer timeframes
- contractual issues, for example, arrangements with external service providers for records stored offsite
- access and security arrangements
- the engagement of consultants for exporting or importing of data between agency systems, if required.
What to do if you are the transferring agency
The first task for the transferring agency is to identify all records associated with the affected function. Records may include:
- paper based records
- electronic records within an EDRMS (Electronic Document and Records Management System) or business system
- administrative records such as finance, payroll or personnel records
- records in other formats, e.g. emails, plans, photos, microfilm, etc
- control records, e.g. indexes, registers, EDRMS
- records held in secondary storage including those stored with an external storage provider
- archival records held by the NT Archives Service.
The affected records should be adequately listed to ensure that an accurate inventory of records is prepared for the receiving agency. Details may include:
- file title or description
- record identifier
- date range
For databases that are to be transferred, the following steps should be taken:
- gather all necessary technical knowledge on software packages and operating systems, in consultation with those responsible for the creation, use, maintenance and support of the database
- make any necessary contractual arrangements with the software company that created the database
- collate information on any special requirements for data protection issues
- gather other information relating to the management of the database, for example, system and procedure manuals.
When to copy records
Where records are part of a general recordkeeping series, and not discrete collections of files or data directly related to the function being transferred, these should remain with the transferring agency to maintain completeness. For example, a functional record may have a sub set of records such as Financial Management payment records. These will need to be retained by the transferring agency for audit purposes.
In these cases, a copy of the relevant records may be issued to the receiving agency, with the original being retained by the transferring agency. Alternatively, access to these records can be provided by development of a records access agreement between the transferring and receiving agencies.
When copies are provided, to facilitate retrieval and management by the receiving agency, relevant control records (or parts thereof) should also be copied. This may include indexes, registers or data from an EDRMS.
To facilitate future access to transferred records by the transferring agency, if required, an access arrangement should be agreed to and documented. This will include access to documentation for records in the custody of the NT Archives Service. Arrangements and authorisations for accessing archival records held at the NT Archives Service may also require updating. Further advice can be sought from the NT Archives Service on this matter.
Transferring the records
The transferring and receiving agencies must make the necessary arrangements for the secure transfer of records. The transferring agency should provide a detailed list of the records to be transferred and retain a copy for their own accountability purposes. The receiving agency should use the list provided to check the records as they are received.
Paper records should be packed securely in labelled boxes and arrangements made for their relocation.
For the transfer of electronic records, the transferring and receiving agencies should liaise with their ICT units to ascertain suitable transfer formats, media, software and hardware. Data migration plans and reports are to be kept as control records by the receiving agency.
Updating records management tools
To ensure compliance with the Records Management Standards for public sector organisations in the NT the transferring agency should retain minimum metadata in the recordkeeping system about transferred records including:
- record identifier, e.g. file number
- record title
- record creation date time
- record closed date
- transfer details, e.g. name of receiving agency and date of transfer
- annotations relating to the record.
Receiving agencies should incorporate the transferred records into their corporate records management systems ensuring that the records are identified as transferred from another agency and the date of the transfer.
Wherever possible, files should not be retitled or renumbered so as to preserve the integrity and provenance of the record. When retitling or renumbering is necessary to integrate or implement a system, original titles and numbers must be captured as part of the new record. Files should not be combined or split.
Recordkeeping tools such as the business classification scheme and retention and disposal schedules should be reviewed to reflect changes.
When functions or public sector organisations are merged
It is important for agencies about to merge into a single entity to collaboratively review their existing recordkeeping processes and establish new recordkeeping systems and processes as appropriate. Careful and systematic planning is required to reduce the risk of records being lost and to avoid inappropriate or unauthorised disposal.
All changes to recordkeeping and business systems should be documented and captured as control records. In particular where systems are retired or integrated with another system.
When functions or public sector organisations are abolished
When a public sector organisation ceases to carry out a function, and that function is not to be conducted by another entity, the function records are to be retained by the organisation as legacy records. The corporate records management system and relevant metadata should be updated to reflect that the function has ceased and that no new records are to be created for the function, once all business activity relating to that function has been completed.
Once the function has ceased, the following options are available for affected records:
- transfer records to secondary storage including offsite storage provided by an external service provider
- dispose of records identified as temporary in accordance with an approved records disposal schedule
- transfer records identified as permanent in accordance with an approved records disposal schedule to the NT Archives Service.
The Records Service acknowledges that material produced by the Queensland State Archives, the National Archives of Australia and the NT Archives Service was used in the development of this advice.
This advice has been issued by the NT Records Service of the ICT Policy and Strategy Section, Department of Corporate and Information Services.
The NT Records Service is responsible for developing, managing and implementing Records Management Standards for the NT Government. The regulatory basis for records management is the Information Act, Part 9 - Records and Archives Management.
For further information please contact:
Records Policy Unit
ICT Policy and Strategy Section
Department of Corporate and Information Services
Appendix A - Example: Transfer statement
Records of the transfer of information can be captured by utilising template - Transfer statement .
Appendix B - Transfer of records checklist
Records of government agency functions together with the regulatory framework for recordkeeping relating to those functions should be available to the agency responsible for the administration of those function(s).
The following checklist is provided to assist agencies to identify actions needed to meet this requirement.
- establish joint working party to oversee transfer process
- identify records in all formats (active and inactive) that relate to the transferring function(s)
- ensure appropriate users have access to the dataset during transition period - review security setup if required
- list record types to be transferred - include all formats of records for example, files, videos, maps, electronic records in business systems
- list record types NOT transferred that may need to be accessed by the inheriting agency – include all formats of records, for example, files, videos, maps, electronic records in business systems
- make arrangements, for example, formal agreement, MOU, for ongoing access to records that cannot be transferred (i.e. records in business systems), and records that are stored offsite for which the agency shares joint responsibility
- provide control records and any associated documentation for items in secondary storage at Iron Mountain, Centralian Records, other temporary storage locations or the NT Archives Service
- annotate records identified for transfer in the notes field in TRIM to reflect details of the administrative change
- provide copy of relevant functional thesaurus terms to receiving agency
- provide copy of agency disposal authorities and copies of any associated documentation to receiving agency, for example, class and function statements
- notify TRIM support to schedule an appropriate time for the migration of metadata
- make arrangements to effect transfer of records and associated control records
- review transferred data and confirm that TRIM records have been transferred without error
- receiving agency to audit records actually received and through joint working group document records deemed to be missing
- provide authenticated copies of records transferred to an agency which are part of a series which is not being transferred
- advise storage providers of changed access and charging arrangements, advise the NT Archives Service of changed access arrangements
- identify costs associated with transferring records - storage costs, reproduction, imaging, outstanding accounts, migrating data
- identify all relevant control records for transfer to receiving agency
- arrange copies of sections of control records if only part of the series is transferred. Annotate the original control records with movement of records
- advise or provide copies of relevant legislation, agency policies, legal advice, memoranda of understanding or contracts relevant to the transferring records
- report from the joint working party to the business delegates to sign off that the transfer process is complete.
Last updated: 05 November 2019
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