Appendix: How to develop retention and disposal authorities

Documentation is essential for disposal authorisation. Preparing an RDA involves research and analysis, which must be documented whether the work is done in-house or by a consultant. State Records NSW requires organisations to submit specific documentation to authorise disposal. 

When submitting an initial draft, State Records NSW requires:

• the draft RDA
• supporting documentation.

When submitting a final draft for approval, State Records NSW requires:

• the final draft RDA
• a signed formal submission letter from the chief executive of the organisation

Supporting documentation

Organisations must provide supporting documentation with the draft RDA. This information helps State Records NSW understand the role, responsibilities, and operating environment of the organisation and review the basis of the records appraisal decisions in the draft authority. Supporting documentation can be brief but should contain the following requirements:

About the organisation

• a brief history of the organisation and its functional responsibilities, including information about its establishment and, if relevant, any predecessor or successor organisations
• details of legislation administered by the organisation relevant to the functions and activities covered by the authority.

About relationships with other organisations and stakeholders

• a brief description of any formal reporting or compliance relationships between the organisation and other organisations related to core functions
• a brief description of any oversight role for the performance or operations of other organisations or individuals (for example, where functions or activities are contracted out)
• a brief description of any significant joint ventures, agreements, or consultative arrangements with other organisations related to core functions
• a brief description of any overlap of core functions or interrelationships with other organisations
• a brief description of any significant relationships with other organisations not already described
• a list of all identified external stakeholders.

About governing bodies and committees

• a brief description of any governing body, significant committees, councils, or advisory bodies that perform, oversee, or advise on key aspects of the organisation’s business.

About the records held by the organisation

• a brief description of recordkeeping systems, including paper-based filing systems, electronic document management systems, database applications, and collections of photographs, maps, plans, and audiovisual material
• a brief description of the oldest records held and whether they were created by the organisation in its current form or a predecessor organisation
• a statement of when the majority (80%) of the records covered by the authority date from
• a brief description of any legacy records covered by the authority relating to functions or activities no longer carried out by the organisation or legacy records of administrative processes no longer undertaken
• details of any previous disposal authorisation issued to the organisation (either functional RDAs or disposal recommendations).

Note: You do not need to include information about records already transferred as State archives.

About the retention periods and disposal actions

• a brief statement justifying each retention period and disposal action identified in the authority (if not included in the functional RDA itself).

About any external stakeholder consultation

• a brief description of the organisations or persons consulted during the development of the authority, the feedback provided, and how the organisation responded to this feedback.

Note: If no external consultation was undertaken, provide an explanation for this decision.

State Records NSW's requirements and conventions for RDAs:

Table of contents

If the RDA covers a large number of functions and activities, State Records NSW recommends including a basic table of contents to provide an overview of the functions and activities covered and to guide users.

Dates of coverage

In general, the date range can be left open. However, in some circumstances, it may be appropriate to nominate dates to indicate limitations on the date range of records to which the authority can be applied. Surveying your organisation's records holdings and systems will help identify if this is needed (for example to address records of predecessor organisations or changes in business processes). 

Supporting documentation submitted with the draft authority should provide a summary of your organisation’s records holdings and management systems. This will help State Records NSW consider and advise if date range limitations are appropriate.

Structure

The standard format is for the authority to be structured around function and/or activity terms presented alphabetically. 

Function and activity descriptions

Function and activity descriptions should:

• be clear and concise, providing a plain-English explanation of the processes covered
• avoid reproducing thesaurus, taxonomy or business classification scheme descriptions in full.

Where related functions and activities have similar or equivalent retention and disposal outcomes, it may be beneficial to combine terms in the authority and modify the descriptions accordingly.

See references

'See' references should guide users in making the best decision about how to sentence a particular class of records.

• See references to other functions should be placed at the end of the relevant function or activity description and can reference other general or function RDAs.

Disposal classes

Disposal class descriptions should:

• be clear and concise, covering the scope and limits of the processes
• start with phrases such as 'Records relating to...' or 'Records documenting...'
• include examples of records to help users apply the authority (the list should not be exhaustive).

Avoid using jargon or specific references to legislation that could date or unintentionally limit the authority. Clearly define distinctions such as 'major' versus 'minor' or 'significant' versus 'routine.'

Case records

When records relate to the management of a case, program or project, assess whether:

• records should be treated as a single class with the same retention and disposal requirements, or
• records should be described as separate classes in the authority with specific retention requirements depending on the process or aspect documented.

Separating records may benefit storage or system migration costs and ensure records are destroyed promptly after their retention period.

Databases

When developing disposal coverage, include records contained in databases and business systems. The authority applies to records of the functions, activities and business processes covered, regardless of format.

To determine retention requirements:

• identify systems and the business they perform
• assess how long the information needs to be kept
• plan for the ongoing maintenance or migration of systems.

IT staff can develop plans to ensure that database information will be accessible and usable for the entire retention period.

Records that do not need to be included

Organisations do not need to provide disposal coverage for records already covered by general RDAs. For example:

• records of committees, governing bodies, contracting out or tendering processes are covered by the General RDA: administrative records
• destruction of certain duplicates, drafts, working papers, back-up tapes, system logs and transaction reports is permitted by the State Records Regulation normal administrative practice provisions
• destruction of certain original records after copying is permitted under the General Retention and Disposal Authority for original or source records that have been copied.

Disposal actions

Disposal actions specify what should happen to a record. These are either:

• an authorisation to destroy records after a specified retention period expires (for example, 'Retain minimum of 10 years after action completed, then destroy')
• the identification of records as State archives ('Required as State archives').

Justifications

Justifications explain how or why retention periods and disposal actions were determined. They should:

• be clear, specific and measurable
• reference legislation, standards, rules, guidelines or other external sources.

If justifications are not provided or are insufficient, organisations may need to resubmit documentation with revised justifications before State Records NSW reviews them.

To ensure compliance with State Records NSW' requirements when submitting a draft RDA. Check the following information has been provided.

Content and structure

• Ensure the authority only includes functions, activities, and classes of records not already covered by general retention and disposal authorities.
• Structure the authority around functions and activities.
• Provide adequate descriptions for all functions, activities, and disposal classes.
• Justify all retention periods and disposal actions.

Format and layout

• Follow State Records NSW' template for the authority.
• Adhere to the layout conventions outlined.

Expression and wording

• Ensure descriptions of functions, activities, and record classes are clear to those outside the organisation.
• Avoid using acronyms and jargon.
• Follow the required wording conventions for disposal classes, triggers, and actions.

Supporting documentation

• Includes all necessary information to assist State Records NSW.