Documenting Step C

• Documenting recordkeeping requirements
• Documentation to meet disposal requirements
• Report to management
• Maintain and update documentation

Documenting recordkeeping requirements

Importance of documentation

It is important to document what sources you have used for the Step C analysis as you may need to justify your findings or refer to the sources again. A simple list of sources is sufficient to record the location of sources.

You will need to document each of the business, regulatory and community-related recordkeeping requirements that you have identified in relation to your project. If you are continuing with DIRKS these can be used to assess your existing systems and work processes (Step D), develop recordkeeping strategies (Step E) and design new systems and work processes (Step F).

Tip: Making reference to the source of your recordkeeping requirements can help 'sell' them in your organisation
Being able to say, 'we have to do this because it is required by this piece of legislation, legal precedent, code of best practice, or accounting standard' can carry significant weight in your organisation.
A major research project into recordkeeping demonstrated this point. It found that including legal citations with requirement statements had a significant impact on the organisational acceptability of that requirement. Statements by auditors, business managers and IT managers justifying recordkeeping requirements also had a significant impact and increased acceptance of the requirements.
Providing sources therefore enhances the credibility of your recordkeeping requirements and so it is important to document where your requirements have been derived from. [3]

You should use a format for documenting your requirements that is easily maintainable as requirements are prone to change and will need to be amended or updated from time to time.

Tip: It is a recordkeeping requirement to document changes to recordkeeping requirements
The need for evidence of changes to recordkeeping requirements is in itself a recordkeeping requirement, because it enables your organisation to account for past recordkeeping actions and decisions.

Documentation options

There are a number of possible options for documenting recordkeeping requirements, depending on your organisation's needs and the number and complexity of its requirements. For example, you may choose:

• tables/templates in a series of word-processed documents
• spreadsheets, or
• databases.

Templates

The following table illustrates how full information on a recordkeeping requirement may be documented in a simple template format. The requirements are grouped together as they relate to the one record and come from one source.

See also Sample recordkeeping requirement documentation.

Spreadsheets

Spreadsheets offer more functionality than word-processed document and need not be complex. Benefits of spreadsheets include being able to sort by different elements, for example function or requirement type, making your research more useable for different purposes.

Databases

In instances where there are many recordkeeping requirements, or where requirements are likely to change frequently, it may be appropriate to place information about your organisation's recordkeeping requirements into a database. The advantages of a database over other options are:

• only having to record information, including changes, about a particular requirement, function, activity or function-activity pair once
• being able to produce tailored views of the information in the database to meet different needs.

This option will involve more work at the outset, because a database needs to be properly specified, designed and documented for it to be useful and maintainable.

Information to include

Regardless of the format that you choose, you will need to decide what data to compile about your organisation's recordkeeping requirements. Your organisation should consider the number and complexity of your recordkeeping requirements, the project scope, and exactly what information is essential, and create documentation that suits your needs. Documentation of the requirements could include all or a selection of the following:

• the name of the source including reference number (ie legislation title and number, publication title and details, personal name and position of informant)
• the date the source came into effect (ie publication or issue date and superseded or decommissioned date)
• a description of the source (eg legislation, regulation, directive, industry standard, best-practice standard, internal policy, community expectation)
• the specific paragraph, clause, section or page in the source that contains the requirement
• a statement outlining how the requirement relates to the organisation's specific situation (ie the recordkeeping requirement). Remember requirements relate to records and the statement should also identify the record involved, eg a register, minutes of meetings etc
• the stakeholder that has their interest met by the requirement eg. a community group or a particular section of the organisation
• the evidential need the requirement relates to (eg the content, form or quality of the record or its creation, retention, disposal or access)
• the business function, activity or function-activity pair the requirement applies to (ie drawn from the analysis of business activity in Step B)
• the citation of the precise text in source which specifies (or implies) the requirement
• the organisational position responsible for ensuring that the requirement is met, and
• results of any risk assessments.

Documentation to meet disposal requirements

If you are doing Step C to develop disposal coverage for your organisation, you will need to provide State Records staff with documentation that justifies the decisions you have made about record retention periods and disposal actions. This documentation will draw directly from your assessment of recordkeeping requirements.

Appendix 1 of State Records' Procedures for Disposal Authorisation provides an overview of the types of information you should gather in your Step C assessments to support of your disposal authority. Read this section prior to documenting your recordkeeping requirements, to save any duplication of effort.

Report to management

For most DIRKS projects, your prioritised recordkeeping requirements should be formally submitted to management for endorsement. It is also particularly important to justify your recommendations if you are not meeting certain recordkeeping requirements. These management-endorsed recordkeeping requirements will provide a mandate/specification for the creation of records in the organisation and for the design of systems to meet those requirements.

You may also wish to draw on the generic characteristics of systems that keep records to inform management about the structures necessary to support these recordkeeping requirements (see Introducing DIRKS – Characteristics and functionality of recordkeeping systems). This report can also be used as an opportunity to gain management support for future steps.

If you are developing a retention and disposal authority, you may wish to postpone seeking management approval until after you have completed disposal recommendations. However, it is important that management endorses the full set of recordkeeping requirements including creation, access, content and form, not just those relating to retention or disposal.

Maintain and update documentation

Recordkeeping requirements will form the agreed benchmark against which your recordkeeping practices will be judged, therefore it is important to track changes to recordkeeping requirements over time. Records about past and current requirements should be maintained, because such information provides context for the evidence that your organisation chooses to keep.

Changes to recordkeeping requirements could occur as a result of:

• changes to business practices or needs
• changes to legislation
• changes in perceptions of risk or priorities
• the organisation losing or gaining functions
• tests in Steps E, F or G that expose flaws or inconsistencies in the requirements
• the discovery, during systems design and implementation, that a particular requirement cannot reasonably be met due to financial, personnel, design, equipment or other considerations, or
• the results of a post implementation review of a recordkeeping system (Step H) or ongoing monitoring.

In these cases, you will need to review your analysis of recordkeeping requirements and risks and document the changes.

Footnotes

[3] Wendy Duff, 'Increasing the Acceptance of the Functional Requirements for Electronic Evidence', Archives and Museum Informatics: The Cultural Heritage Informatics Quarterly 10:4 (1996): 326-351.
Accessible via http://web.archive.org/web/19981202051911/www.sis.pitt.edu/