Introduction
On the 12 October 2006 the Australian National Audit Office released a report on "Recordkeeping including the Management of Electronic Records". Rather than being an analysis of one particular agency, this is a performance audit across several agencies. The report found problems, particularly with electronic records, as found in two previous reports. This is a brief summary and guide to the latest report and discusses what might be done to improve electronic record keeping in agencies. These notes may be of use to students of "Information Technology in Electronic Commerce" at the Australian National University (COMP3410/COMP6341) and others. It is not intended as a detailed analysis. Comments, corrections and suggested additions would be welcome.
Background
The Australian National Audit Office, (ANAO) is an independent auditor of Commonwealth (Federal) public sector agencies and statutory bodies. The Auditor-General is an "Officer of the Parliament" and reports to Parliament.
Previous Reports
As well as audits of individual agencies, ANAO makes performance audit across agencies. The latest report makes three ANAO has made covered recordkeeping:
Recordkeeping including the Management of Electronic Records, No. 6, 2006/2007, 12th October 2006, Performance Audit Across Agencies:
The objective of the audit was to assess the extent to which entities were meeting their recordkeeping responsibilities. In particular, the audit examined how effectively the entities were managing records that were created and stored electronically in corporate recordkeeping systems and in other electronic systems in accordance with recordkeeping requirements.
See:
Recordkeeping in Large Commonwealth Organisations, No. 7, 2003/2004, 24th September 2003, Business Support Process Audit, Across agency (Assurance of the performance of the public sector):
The audit reviewed the recordkeeping frameworks of four large Commonwealth organisations. The objective of the audit was to assess whether recordkeeping policies, systems and procedures were in accordance with relevant Government policies, legislation, accepted standards and recordkeeping principles, and applicable organisational controls.
See:
- Report PDF .7Mb
- Brochure PDF .2Mb
- Recommendations and Agency Comments PDF .2Mb
Recordkeeping, No. 45, 2001/2002, Assurance and Control Assessment Audit, Across Agency (Accountability and Governance, Information Technology, Legislative and/or Administrative Compliance)
An Assurance and Control Assessment audit of recordkeeping was undertaken across four Commonwealth organisations to assess whether their recordkeeping policies, systems and processes accord with requirements under the Archives Act 1983, with relevant government policies, and with accepted standards and recordkeeping principles; and to identify better practices and recommend improvements. The audit addressed both electronic and traditional records.
See:
- Report PDF 1.2Mb
Latest Audit
The latest audit covered:
- Attorney-General's Department
- Australian Electoral Commission
- Department of the Prime Minister and Cabinet
The report points out that adequate recordkeeping ia a key part of public administration. The Archives Amendment Bill 2006 changes the legislation covering the NAA, clarifying some issues, such as that electronic records are records:
4 Subsection 3(1) (definition of record)
Repeal the definition, substitute:
record means a document, or an object, in any form (including any electronic form) ...
The report notes that the Australian Public Service Commission is examining record keeping issues in its next "State of the Service Report" (2006). The 2004-05 report noted previous issues with record keeping, including those from ANAO:
Record keeping has attracted substantial attention in recent years, both in general reports such as those published by the ANAO, and in the context of specific cases of concern such as the Magnetic Resonance Imaging Services case, A Certain Maritime Incident, and this year in the Palmer report. Record keeping in the APS has been affected by greater public scrutiny through administrative law reform and parliamentary oversight over the past few decades, and also by increased emphasis on achieving results. While administrative law reforms, including the Freedom of Information Act 1982,13 have generally led to improvements in public administration, the risk that these reforms may inhibit formal record keeping needs to be recognised. In addition, technology has also had a major impact on record keeping practices.
The audit examined management of records created and stored electronically in corporate recordkeeping systems.
ANAO found that organisations need to first determine which information needs for each business activity, then the information that needs to be in the corporate recordkeeping system to support that activity. These are needs, including the maintenance of context which were identified in a 1995 report:
Whatever strategy is adopted, the document management system must:
provide adequate context information for documents;
provide means to prove the authenticity of documents used as evidence
provide for the disposal of records in conformance with the Archives Act 1983;
be robust against organisational or technological change;
provide levels of support for different types of document that accord with agency policy; and
provide links between paper and electronic documents.
The ANAO suggested to enhance recordkeeping:
- recognise recordkeeping as an integral part of 'doing business ...
- undertake a recordkeeping needs analysis ...
- develop medium to long term strategies [for the] increasing volume of records are being created electronically;
- ensure that recordkeeping policies address all systems, whether paper-based or electronic ...
- for each major programme and business activity determine the information that needs ...
- supplement the entity's strategic and policy framework with practical guidance and advice, together with an ongoing programme of training and awareness ...
- assess the resources required to establish, and sustain, a recordkeeping regime that meets the entity's legislative and policy requirements.
While useful advice, this is much the same as would be given for any technology related activity and is much the same as the advice offered to agencies ten years previously.
The ANAO recommended NAA define minimum recordkeeping requirements, develop further practical guidance and publish advice. Since its move from DCITA to the Department of Finance, the Australian Government Information Management Office (AGIMO) has been active in communicating advice, including via seminars. Perhaps NAA should coordinate a program with AGIMO, given that responsibility for advising on electronic record systems falls to both NAA and AGIMO.
Guidelines
One difficulty with both paper based and electronic records is that there is no central authority to set standards for government agencies. Under the ARCHIVES ACT 1983, the National Archives of Australia (NAA) is charged with conservation and preservation of the existing and future archival resources of the Commonwealth. It can provide advice to Commonwealth institutions on the keeping of current Commonwealth records. NAA issues guidelines on recordkeeping standards setting, but has no power to require agencies to conform.
The ANAO report notes that effective recordkeeping is not easy. However, the legal requirements for doing so are clearly set down in legislation. The methods for doing this are detailed in standards and used by university courses. The author helped developed some of these and teaches some at the Australian National University.
Major documents from NAA include:
- DIRKS Manual: A Strategic Approach to Managing Business Information, September 2001, Revised July 2003, ISBN 0 642 34449 3. The manual is available both as web site and PDF file.
- Recordkeeping Metadata Standard for Commonwealth Agencies (RKMS), Version 1.0, May 1999, ISBN 0 642 34407 8. The manual is available both as web pages and PDF file.
- Australian Government Email Metadata Standard, Version 1.0, December 2005, ISBN 1 920807 32 2. The manual is available both as web pages and PDF file.
- Commonwealth Record Series (CRS) System Manual, December 1999
- Overview of Classification Tools for Records Management, 2003, ISBN 0 642 34499 X. The manual is available both as web pages and PDF file.
- Developing a Functions Thesaurus - Guidelines for Commonwealth Agencies, 2003, ISBN 1 920807 06 3. The manual is available both as web pages and PDF file.
Many of these standards are now several years old an need updating. As an example the DIRKS manual contains references to the superceded AS 4390 - 1996, Records Management Standard. These needed to be replaced with the international AS ISO 15489 - 2002. Also the standards needed to be better related to each other and provided with an overarching framework and easy to use online training materials.
ANAO considers that Archives could further assist entities by:
- setting minimum recordkeeping requirements that entities are expected to comply with to meet their legal and business requirements
- developing further practical guidance entities can use in developing their own guidance material
- coordinating, and periodically publishing, details of the legislation, standards, policies and guidance that impacts on the recordkeeping responsibilities of individual entities. This coordination role may also offer the potential for rationalisation of existing material, having regard to the minimum requirements set.
However, it is difficult to see how Archives could make the guidance already issued any more clear. Archives assumes that agencies will have competent professional records management staff and will train general staff in their responsibilities for records keeping. As ANAO noted one agency had implemented an electronic document management system (EDMS). This was a significant investment and resulted in changes to record keeping practices.
Agencies had used Archives Designing and Implementing Recordkeeping Systems (DIRKS) process which covers the design and implementation of recordkeeping systems. This had been developed by Archives in response to the 2002 and 2003 ANAO reports.
The DIRKS methodology is an eight-step process for agencies to use to improve their recordkeeping and information management practices, including the design and implementation of new recordkeeping systems. The methodology is compliant with, and expands on, the methodological framework of the Australian Standard for Records Management, AS ISO 15489 - 2002. ...
From Managing Business Information with DIRKS, Archives
Terminology
While the report has been provided as a web page and PDF, it is not as easy to read as could be. Both the web and PDF versions lack structuring. The sections of the report are not marked as sections in either the web or PDF versions and no table of contents is provided (nor can one be generated as the needed structure data is missing from the document).
The report in general uses a precise vocabulary. One lapse is the use of both "Archives" and "NAA" to refer to National Archives of Australia. But this, along with many other terms are contained in a useful set of abbreviations and a glossary at the front of the document. These are limited by being designed for print format, with no links. Archives also have a useful glossary of terms. Here are the abbreviations and glossary, consolidate, extended and hypertext linked:
Term | Description |
---|---|
ACSI 33 | Australian Government Information and Communications Technology Manual |
AEC | Australian Electoral Commission |
AGD | Attorney-General's Department |
ANAO | Australian National Audit Office |
Archives/NAA | National Archives of Australia |
APS | Australian Public Service |
AS | Australian Standard |
DIRKS | Designing and Implementing Recordkeeping Systems - A Strategic Approach to Managing Business Information (DIRKS) manual by NAA and State Records New South Wales. |
Disposal | Any action that changes the circumstances of a record or removes a record from its usual setting. Disposal can include destruction, damage, alteration, or transfer of custody or ownership of records. |
EDMS/EDRMS | Electronic Document Management System (or Electronic Document and Records Management System) |
Electronic systems | Electronic systems include: shared folder systems, email, ministerial correspondence systems, the corporate recordkeeping system and other business systems that support a line of business (such as the management of the electoral roll or legal opinions) or a corporate function (such as finance or human resources). |
e-permanence | A suite of recordkeeping policies, standards, guidelines and training published by the National Archives of Australia. |
ICT/IT | Information and communications technology (or Information technology) |
ISO | International Standards Organization |
MAC | Management Advisory Committee |
Metadata | Structured information that describes and/or allows users to find, manage, control, understand or preserve other information over time. |
NAP | Normal administrative practice: Archives Advice No.18, provides guidance to entities on the Archives Act 1983 allows entities to dispose of records without formal authorisation, usually for records duplicated, unimportant or for short-term use only. Archives Advice No.20 provides additional guidance on emails. |
PM&C | Department of the Prime Minister and Cabinet |
PSM | Protective Security Manual |
Recordkeeping/Records Management | The making and maintaining of complete, accurate and reliable evidence of business transactions in the form of recorded information. |
Recordkeeping system | A system (electronic or paper) that holds records and contains the mandatory metadata elements as set by the Archives. |
Records | The Australian Standard on Records Management, AS ISO 15489, defines records as 'information in any format created, received, and maintained as evidence and information by an organisation or person, in pursuance of legal obligations or in the transaction of business'. |
Records Disposal Authority/Records Disposal Authorities | A formal instrument issued by the National Archives of Australia under the Archives Act 1983 that defines the retention periods and consequent disposal actions authorised for classes of records described in the authority. |
Vital records | Records without which an organisation could not continue to operate, that is, those containing information needed to re-establish the organisation in the event of a disaster. Vital records are those which protect the assets and interests of the organisation as well as those of its clients and shareholders. |