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Records Management - Retention and Disposal Procedure

This is not a current document. It has been repealed and is no longer in force.

Section 1 - Introduction

(1) Commonwealth and Northern Territory Government legislation requires that all members of the University community are responsible for proper records management and must contribute to the ‘corporate memory’ through compliance with University Records Management policies, procedures and guidelines.

(2) The retention and disposal of University records refers to the practice of determining the length of time each record must be retained before the record can be destroyed, application of that retention period and eventual destruction (disposal) of the record or the record being transferred to Permanent Archive.

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Section 2 - Compliance

(3) This is a compliance requirement under the Information Act 2002.

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Section 3 - Intent

(4) This document applies to all members of the University community. It is intended to specify how University records should be managed with regard to retention and disposal.

(5) No University record may be disposed of without consulting a current, authorised University Records Disposal Schedule. This procedure is not intended to be an authority to dispose of University records and cites examples of retention periods as a guideline only. The Interim University Disposal Schedule (included within this document) can be used as an authority to dispose of records.

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Section 4 - Relevant Definitions

(6) In the context of this document:

  1. Disposal means destroying a record once it is legally no longer required;
  2. Normal Administrative Practice means the disposal of short-term records without the requirement for a disposal schedule;
  3. Permanent Archive means transferring University records that must be retained indefinitely to the appropriate Archives Service;
  4. Record means:
    1. recorded information in any form (including data in a computer system) that is required to be kept by a public sector organisation as evidence of the activities or operations of the organisation, and includes part of a record and a copy of a record; and/or
    2. information created, received, and maintained as evidence and information by an organisation or person, in pursuance of legal obligations or in the transaction of business;
  5. Register means Register of Systems Approved for the Management of University Records;
  6. Retention means the amount of time a record must be retained before it can be disposed of or permanently archived;
  7. Senior Manager means a staff member of the University holding the position of Director or Head of School or equivalent;
  8. Sentencing means the application of a records retention schedule to a record; and
  9. University Community means officials and individuals carrying out University business. This includes, but is not limited to, all staff members, researchers, peer reviewers, students, volunteers, consultants, agents and contractors.
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Section 5 - Procedures

Disposal of University Records

(7) Records cannot be destroyed or deleted (disposed of) if:

  1. they have not been identified in a records disposal schedule (University or NT Archives) or relevant procedure and do not qualify under normal administrative practice;
  2. trhe minimum retention period has not been met;
  3. there is a current disposal freeze imposed on the records by the Federal or Territory Government; and/or
  4. the University is aware of a matter, such as a legal case, which may require the records be retained.

(8) Records that are ready to be disposed of must go through the following procedures:

  1. The Senior Manager of the area responsible for the records must approve and ‘sign-off’ on the destruction;
  2. the Manager, Records and Archives must approve and sign-off on the destruction;
  3. electronic records must be destroyed in a way that they are not recoverable once the destruction has taken place, such as data shredding;
  4. hard-copy records must be destroyed through an approved contractor by pulping, shredding or incineration;
  5. destruction must be handled in a secure manner such as use of confidential paper destruction service; and
  6. once the destruction is completed, notification must be provided to the Northern Territory Archive Service through the Records and Archives.

Records Disposal Schedules

(9) To enable the University to retain or destroy records in accordance with the Information Act 2002, University Records Disposal Schedules must be produced. This involves a thorough and systematic analysis of the business activity of the University and an assessment of the records produced as a result of that activity.

(10) University Records Disposal Schedules will identify types of University records and provide a length of time the records must be retained.

(11) Records retention decisions must be based on:

  1. the current and future business needs of the organisation;
  2. compliance with legal and governance requirements of the organisation; and
  3. the current and future needs of internal and external stakeholders, including the wider community.

Development and Maintenance of University Records Retention Schedules

(12) To enable the application of retention periods to University records in line with the NT Public Sector Organisations Records and Information Management Standards, the Records and Archives will establish University Records Disposal Schedules which all members of the University community must adhere to.

(13) The University Records Disposal Schedules will:

  1. meet retention requirements under applicable legislation and regulations. Many records may be subject to appeals processes or other legal scrutiny often for unanticipated events;
  2. categorise records and identify appropriate retention periods;
  3. Identify triggers for these categories to enable the eventual disposal of many records and a provision for the permanent archival of other records;
  4. ne approved by the Vice-Chancellor, the Director, Records Service (NT) and the Director Archives Service (NT) before they can be utilised; and
  5. be reviewed every three (3) years (as a minimum).

Legal Considerations for University Records Disposal

(14) Regulations and legislation that are in place determine the length of time a University record must be retained. These regulations and legislation provide the MINIMUM required retention period for various types of records. The University will determine the actual retention period (which may be longer than the required duration) and these will be published in the University Records Disposal Schedule.

(15) When developing the University Records Disposal Schedule, the following requirements will be taken into consideration:

  1. Taxation legislation requires that records generally need to be retained for a minimum of five (5) years.
  2. Work Health and Safety Regulations require an employer to keep certain employee records for a minimum of thirty (30) years.
  3. Under the Higher Education Provider Guidelines and the Higher Education Support Act 2003 – Vocational Education and Training (VET) Provider Guidelines, records relating to grievances and reviews must be kept for a least five (5) years.
  4. A General Direction from the Australian Skills Quality Authority outlines that assessment items submitted by a student must be retained for: the duration of the University assessment appeal period; or six (6) months from the date a judgement of competence was made; or for the duration of the student’s enrolment, whichever is the longer.
  5. The Standards for National VET Regulator Registered Training Organisations 2011 advises that records of attainment of units of competency and qualifications must be retained for a period of thirty (30) years.
  6. Other student records must be kept for up to seven (7) years after they cease studying as they may be required to justify the course of action taken by the University with relation to a student.
  7. Records may be required to identify reporting requirements for research grants, and further records required to prove that the grants were spent appropriately.
  8. The Australian Code for the Responsible Conduct of Research, 2018 states that the general minimum retention period for research records is five (5) years however retention periods should be determined by the specific type of research. For example:
    1. for short-term research projects that are for assessment purposes only, such as research projects completed by students, retaining research data for twelve (12) months after the completion of the project will normally be sufficient;
    2. for areas such as gene therapy, research data, for example, patient records must be retained permanently; and
    3. if the work has community or heritage value, research data should be kept permanently.
  9. Building design and construction records must be kept permanently as they may be required in the event that issues are experienced with buildings, if the building needs to be demolished or even if a building needs to be redesigned.

Approved Systems for University Records Retention and Disposal

(16) All systems on the Register must have a workflow process in place around them to manage the retention and disposal of records for that system. The workflow process must be reviewed regularly in conjunction with the Records and Archives.

Normal Administrative Practice

(17) Records of a short-term or transitory nature (including background notes, office messages, meeting requests, duplicated records etc.) can be disposed as part of normal administrative practice.

(18) This means that the record does not generally need to be recorded in a system approved for the management of University records and can be destroyed as part of everyday practice without the requirement of a University Records Retention Schedule. However, consideration should be given to the nature of the record to ensure that it is destroyed securely where required. If the record is held within an approved system, the Northern Territory Disposal Schedule - Records of Short Term Value must be used to facilitate destruction.

Disposal of Hard-Copy Digitised University Records

(19) Hard-copy records with a temporary retention period, which have been digitised, need to be retained for a minimum of three (3) months providing all quality checks have been made in this period (refer to Records Management - Capturing Procedure). These records can be retained for longer if deemed necessary for business requirements.

(20) Digitised records with a permanent retention period must be retained and transferred to NT Archives as defined in the University Records Retention Schedule.

(21) Some digitised records must be retained in hard-copy format regardless of the retention period, due to the legal nature of the records. Some examples are:

  1. contracts;
  2. agreements/memoranda of understanding;
  3. registration of business name; and
  4. other official documents or documents with original signatures.

Interim Records Disposal Schedule

(22) Until such time that a formal disposal schedule exists for University Records, the records outlined in the table below may be disposed of in accordance with this procedure. Only records high in volume and of low risk value may be listed in this interim schedule.

Function Activity Class
(Description of Records)
Term
Student Administration Assessment Copies of VET student assessment items or evidence such as an assessor’s completed marking guide, assessment cover sheet, criteria or observation checklist;
(Originals to be returned to the student)
Retain for a minimum of six (6) months following the end of the teaching period in which a final grade is entered on to the student management system.
Student Administration Assessment Higher Education Assessment Items (excludes examinations, practicums and thesis) Return to the student or retain for a minimum of the appeal period and then destroy
Student Administration Assessment Higher Education Examination Papers Retain for a minimum of the appeal period and then destroy
Hardcopy Temporary Value Records which have been Digitised   Hard copy source records which have been digitised and captured within TRIM;
Limited to
Student Administration Records
Evidence of Participation Records
Destroy six (6) months after digitisation (provided that quality checks have been completed and there are no legal or business reasons to retain them)

Records and Archives

(23) The Records and Archives is responsible for ensuring that the processes and tools are in place so that University records can be retained for the appropriate length of time before either being destroyed or transferred to permanent archive.

(24) The Records and Archives is responsible for:

  1. managing the University’s Electronic Document and Records Management System and the administration of that system;
  2. assessing systems and work processes for managing University records;
  3. maintenance of the Register of Systems Approved for the Management of University Records;
  4. conducting regular auditing on records management processes across the University;
  5. managing the storage of archived hard-copy University records;
  6. managing the application of retention and disposal of records;
  7. developing and reviewing University Records Disposal Schedules; and
  8. providing advice on how to implement new processes that involve the management of records.