Records Management Procedure

Policy code: OG1697
Policy owner: Manager, Registrar Services
Approval authority: Director of Student Services and Registrar
Approval date: 15 November 2023
Next review date: 07 July 2026

Purpose

As a public institution the University is bound by the Public Records Act 1973. Records received or created by university staff are deemed to be Public Records under the Act.

University staff including sessional staff, researchers and research staff are required to capture full and accurate records and manage and dispose of these records according to the authorised standards and records authorities issued by the Public Record Office Victoria (PROV).

All university staff are required to ensure records they create and/or receive on behalf of the University are captured, managed, stored and disposed of in line with this procedure.

This procedure has been developed to provide guidance for the identification, capture, use, storage, security and disposal of records to ensure a consistent approach to records management across the University.

Scope

This procedure applies to all university staff and individuals who may perform work on behalf of the University, including but not limited to:

  • Partner providers (onshore/offshore)
  • Commercial delivery
  • VETDSS
  • Sessional staff
  • Volunteers
  • Researchers and research staff

and members of the University community who may create and/or access University records.

No staff are excluded from this procedure.

Legislative context

  • Child Wellbeing and Safety Act 2005
  • Copyright Act 1968 (Vic)
  • Crimes (Document Destruction) Act 2006 (Vic)
  • Crimes Act 1958 (Vic)
  • Education and Training Reform Act 2006 (Vic)
  • Education and Training Reform Regulations 2017
  • Education Services for Overseas Students Act 2000 (ESOS Act)
  • Electronic Transactions Act 2000 (Vic)
  • Evidence (Miscellaneous Provisions) Act 1958
  • Evidence Act 2008
  • Federation University Australia Act 2010
  • Freedom of Information Act 1982 (Vic)
  • Health Records Act 2001 (Vic)
  • Higher Education Standards Framework (Threshold Standards) 2021
  • Higher Education Support Act 2003
  • National Vocational Education and Training Regulator (Charges) Act 2012
  • National Vocational Education and Training Regulator (Transitional Provisions) Act 2011
  • National Vocational Education and Training Regulator Act 2011
  • Privacy and Data Protection Act 2014 (Vic)
  • Public Records Act 1973 (Vic)
  • Standards for Registered Training Organisations (RTOs) 2015
  • Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act)
  • The National Vocational Education and Training Regulator Act 2011
  • The Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act)
  • VRQA Guidelines for international education
  • VRQA Guidelines for Minimum Standards in a non-school setting (Vic)
  • VRQA VET Standards and Guidelines

Definitions

Term Definition
Assessments
The determination of results to be awarded for a component of study (eg assignment, test, exam, unit, course) 
Authorising Officer Senior officer responsible for approving the destruction of records. This includes Dean, Executive Dean, Director, Manager, Course Coordinator or other authorised officer.
Corporate
Business System
An approved business system used by the University for the storage of records relating to a particular function. 
NAP

Normal administrative practice NAP is a process that allows agencies to destroy certain types of low-value and short-term information in the normal course of business.

NAP covers the destruction of ephemeral material of a facilitative nature created, acquired or collected by public officers during the course of their duties.

Permanent Records
Public records that have been identified as being worthy of preservation in a Public Record Office Retention and Disposal Authority or have been identified by the University as having historical significance. 
PROV Recordkeeping Standards 

A set of mandatory principles reflecting best practice methodology that Victorian Government agencies must comply with in order to meet the legislative requirements of the Public Records Act 1973

(Source: Public Records Office Victoria) 

Public Record
Any information created by or received by the University, regardless of format or source, that is evidence of a business transaction or activity. A record records an action, policy, decision or decision making process, renders the organisation accountable or commits the organisation to an action. Public records are governed by the Public Records Act 1973. 
Public Record Office Victoria (PROV)

Established under the Public Records Act 1973  PROV’s objectives are to:

  • issue standards regulating the creation, maintenance and security of public records, including the selection and disposal of public records not worthy of preservation
  • advise and assist agencies in achieving compliance with issued standards
  • preserve public records of permanent value as the state archives
  • ensure that the archives are accessible to the government and the people of Victoria.

(Source: Public Record Office Victoria

Public Records Act 1973

The Public Records Act 1973 established the Public Records Advisory Council to advise the Minister on administration of the Act and to promote co-operation between Public Record Office Victoria and other government agencies

(Source: Public Record Office Victoria

Records Disposal Authorisation
Authorisation process for the disposal of records, which must be approved by an approved Authorising Officer and the Senior Manager, Registrar Services (or their delegates). This ensures compliance with the Public Records Act 1973 and associated Standards
Retention and Disposal Authority (RDA)

A mechanism for the disposal of public records in accordance with the Public Records Act 1973. Details the minimum retention period of public records and authorises records to either be destroyed or retained permanently. 

Federation University records are primarily covered by two RDAs, regardless of format:

PROS 07/01 – General Retention & Disposal Authority for Records of Common Administrative Functions.

PROS 16/07 – Retention & Disposal Authority for Records of the Higher and Further Education Functions.

Actions

1. Capturing and Classifying University Records

To comply with mandatory PROV Standards and relevant legislation, it is the responsibility of all University staff to consistently create, capture, access, store and manage records as part of normal business practice.  The systematic capture of records in compliant systems ensures authentic, reliable and useable records are maintained as evidence of the University’s business activities and transactions, allowing for better decision making, transparency and accountability.

Any information created by or received by the University, regardless of format or source, that is evidence of a business transaction or activity. A record records an action, policy, decision or decision making process, renders the organisation accountable or commits the organisation to an action. Public records are governed by the Public Records Act 1973

  ACTIVITY RESPONSIBILITY STEPS
A Capturing all electronic records in a University approved business system All University employees and associates (as per Scope)
  1. Staff must not store records on laptops, desktops, temporary storage devices and portable drives.
  2. Electronic records must be stored in a University approved business system
  3. Records stored in the University approved Records Management System are classified against the relevant PROV Retention and Disposal Authority.
B Capturing all hard copy records All University employees and associates (as per Scope)
  1. Hard copy records must be stored securely to avoid possible theft, misuse or inappropriate access
C Capturing social media All University employees and associates (as per Scope)
  1. Official social media content published by Federation University is stored within the particular social media platform where the original content was posted. eg Facebook, Instagram
  2. Access to all official social media platforms is controlled by the Marketing department and limited to authorised users only.
  3. Any contributions to social media platforms by staff are controlled by codes of conduct within the university such as the Staff Code of Conduct and Information SecurityPolicy.

2. Accessing University Records

Access to University records is only permitted by authorised University Officers who require access for University business.  Hard copy records stored within business areas must be secured to avoid possible, theft, misuse or inappropriate access. 

Business system owners must ensure systems comply with the requirements of PROV Standards. Business systems must be able to guarantee the security of records at all times and track who has accessed or amended data within those systems. Access to these systems should be reviewed on a regular basis to ensure compliance with PROV Standard 11/10 – Access.

University staff must ensure their username and password for University systems are kept secure at all times and are not shared with anyone else under any circumstances, as outlined in the University’s Information Security Policy.

  ACTIVITY RESPONSIBILITY STEPS
A Requesting access to hard copy archived records Business area
  1. Email Central Records (centralrecords@federation.edu.au) requesting access
B Retrieval of hard copy archived records Central Records
  1. Central Records will retrieve records from offsite storage, if available, and provide relevant information to Business area
C Accessing digital records All University employees and associates (as per Scope)
  1. Access to University records by staff is managed via security levels in business systems.
  2. University staff must ensure their username and password for University systems are kept secure at all times and are not shared with anyone else under any circumstances, as outlined in the University’s Information Security Policy.
D Accessing social media records All University employees and associates (as per Scope)
  1. Official social media content published by Federation University is stored within the particular social media platform where the original content was posted. eg Facebook, Instagram. Access is managed by the Marketing department.

3. Archiving University Records

Hard copy records no longer required for normal business activities must be appraised by Central Records who will determine if they are to be transferred to offsite storage, PROV, or if they can be disposed of under a relevant RDA or NAP.

 Hard copy records no longer required for daily business activity that have not met the requirements for disposal should be transferred to the University’s offsite storage facility via Central Records. This facility has been assessed as being compliant with the Storage Standard (PROS 11/01) issued by PROV and ensures the preservation and security of the records until such time as they are ready for disposal or permanent transfer to PROV (for historically significant records).

Storage at other non-University approved offsite storage facilities is not permitted.

Electronic records stored in the University approved records management system are sentenced according to the relevant PROV retention and disposal authority.

  ACTIVITY RESPONSIBILITY STEPS
A Managing archiving of hard copy University records Business area
  1. Contact Central Records (centralrecords@federation.edu.au) for initial advice
B Providing advice to Business areas Central Records
  1. Central Records provide advice on how hard copy records will be managed.  If records are to be archived, Central Records will provide archive boxes and Archives Consignment form for completion by Business area.
C Archiving hard copy records Business area
  1. Box records, complete archives consignment forms for each box, including a copy of the relevant form.
  2. Email completed forms to Central Records and advise boxes are ready for collection
D Assessing Archives Consignment forms Central Records
  1. Assess forms for accuracy and completeness. 
  2. Liaise with Business area if necessary.
  3. Arrange to collect archive boxes
E Preparing archives for offsite storage Central Records
  1. Upload Archives Consignment forms into the University’s Records Management System and sentence records
  2. Label and arrange transfer of boxes to offsite storage facility

4. Disposal of University Records

University records cannot be disposed of if:

  • they are identified as having historical significance and / or are classed as a permanent record by PROV;
  • they have not met the minimum retention timeframe as specified in the applicable RDA;
  • it is known that the records may likely be required in evidence, either now or in the future – regardless of whether a valid RDA has been issued by PROV;
  • there has been an embargo placed on the disposal of records either by the University or PROV – regardless of whether a valid RDA has been issued by PROV;
  • it is identified that there is still a business requirement for the records to be retained.

Electronic records stored in the University approved records management system are sentenced according to the relevant PROV retention and disposal authority.

a. Disposal of hard copy University records

  ACTIVITY RESPONSIBILITY STEPS
A Initiating disposal of hard copy University records Business area
  1. Contact Central Records (centralrecords@federation.edu.au) for initial advice
B Providing advice to Business areas Central Records
  1. Central Records provide advice on how hard copy records will be managed.  If records are to be disposed of, Central Records will provide Records Disposal Authorisation form for completion by Business area and return to  centralrecords@federation.edu.au.
C Assessing Records Disposal Authorisation forms Central Records
  1. Assess forms for accuracy and completeness.
  2. Sentence records according to relevant PROV Retention and Disposal Authority
  3. Email form back to Business area for approval by relevant authorising officer.
D Initial approval of Records Disposal Authorisation form Business area
  1. Relevant authorising officer approves Records Disposal Authorisation form and emails back to centralrecords@federation.edu.au
E Final approval of Records Disposal Authorisation form Senior Manager, Registrar Services
  1. Senior Manager, Registrar Services, approves Records Disposal Authorisation form
F Disposal of hard copy records Central Records / Business area
  1. Central Records emails fully approved Records Disposal Authorisation form and advises Business area that records can be disposed of in secure confidential bins.

b. Disposal of electronic University records

  ACTIVITY RESPONSIBILITY STEPS
A Managing disposal of electronic University records Central Records
  1. Electronic records stored in the University approved records management system are sentenced according to the relevant PROV retention and disposal authority.
  2. Approval for final disposal will be managed in the approved records management system via a workflow process

Responsibility

The Vice-Chancellor, as head of the University, is responsible for ensuring the University complies with legislative requirements for recordkeeping, including the Public Records Act 1973 and other regulatory instruments, including PROV Standards.

The Director Student Services and Registrar, as the Vice-Chancellor's delegate, has the responsibility for overseeing compliance of the University's Records Management Policy and Procedure.

The Senior Manager, Registrar Services is responsible for developing, implementing and monitoring the Records Management Policy and Procedure.

The Central Records area is responsible for providing recordkeeping advice and support to business areas.

University staff in a supervisory capacity are responsible for monitoring and supporting staff to ensure they understand and comply with records management policies and procedures. They should encourage and support positive recordkeeping practices within their business area in relation to managing University records.

Promulgation

This procedure will be communicated throughout the University community via:

  1. A FedNews announcement and on the ‘Recently Approved Documents’ page on the University’s Policy Central website.

Implementation

This procedure will be implemented throughout the University via:

  1. A FedNews announcement and on the ‘Recently Approved Documents’ page on the University’s Policy Central website.

Records management

DOCUMENT TITLE LOCATION RESPONSIBLE OFFICER MINIMUM RETENTION PERIOD
Completed Archives Consignment form The University’s approved records management system Central Records Temporary - Destroy after administrative use has concluded
Approved Records Disposal Authorisation form The University’s approved records management system Central Records Temporary - Destroy 30 years after administrative use has concluded