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Guideline 20 - Keeping web records

The purpose of this guideline is to help public offices manage their web records. Web records include content on websites, transactions performed via the web as well as any administrative records regarding the website.

Executive Summary

As NSW public offices increasingly use the web to carry out their business, the need to properly manage any records created in regards to the web is also amplified. Under the State Records Act 1998 all NSW public offices are required to 'make and keep full and accurate records of [its] activities' (s.12 (1)). This means digital records as much as it does paper records, including records created through the application of web technologies.

The purpose of this guideline is to help public offices manage their web records. Web records include content on websites, transactions performed via the web as well as any administrative records regarding the website.

This guideline is designed to be most beneficial not only for records managers, but for those involved in the creation, authoring and maintenance of public office websites.

This guideline discusses:

  • statutory requirements for web records
  • the current uses of web technologies within the NSW government
  • a definition of what a web record is
  • why we need to keep web records, and
  • how to capture and maintain web records.

This guideline in intended to assist NSW public offices in managing their web records.

1: Introduction

Background

Public offices across NSW are increasingly using websites as a means of delivering services and advice to the people of NSW. However as public offices increasingly use the web for delivering advice and services, many web based transactions must be kept as records, as each public office is required to 'make and keep full and accurate records of [its] activities' [1]. These types of records include publications, online transactions and administrative records regarding the website and intranet.

The New South Wales State Government through their ICT Strategic Plan - People First - A new direction for ICT in NSW [2], has also indicated its greater expectation of utilisation of online services from NSW public offices.

Purpose

This guideline has been developed to assist public offices meet their obligations under the State Records Act in regards to web records. This guideline aims to:

  • assist public offices in determining what constitutes a web record
  • suggest how to create and capture web records, and
  • discuss how to maintain web records.

This guideline focuses on helping public offices increase their awareness of what records are being produced through web based activities and offers advice on the management of these records.

Scope

All public offices including those that outsource their website management are obliged to make and keep adequate web records.

This guideline is relevant to web records produced for both public office internet or intranet sites and it is important to remember that both types of sites create State records.

This guideline should be read in conjunction with the suite of policies, standards and guidelines regarding digital recordkeeping produced by State Records.

Whilst this document addresses many areas and issues of web records, it is not exhaustive in addressing all unique issues relating to web records.

Awareness and responsibilities

Managing web records correctly is a shared responsibility extending to not only CEOs and records managers, but those stakeholders who create the web content and maintain the structure of the website. There is also the further responsibility of ensuring that external contractor provision of website management or additional website work including content and graphics creation, technical and other web support services are appropriately recorded.

This document is intended for:

  • Records and information managers
  • Corporate records managers
  • Business unit and strategic managers e.g. Chief Information Officers
  • Web managers
  • Information and communications technology personnel
  • Chief Executive Officers
  • Web content managers
  • Individual web content authors (if devolved web authoring happens within agency).

Acknowledgements

State Records would like to acknowledge the work of the Public Record Office Victoria, the U.S. National Archives and Records Administration and the National Archives of Australia as valuable reference sources used in the preparation of this guideline. Some of the recommendations in this guideline were based on the findings of these institutions. State Records would also like to extend its appreciation to the Department of Corrective Services and NSW Treasury - Office of State Revenue for their input into these guidelines.

Footnotes

[1] State Records Act, 1998 (s.12 (1))
[2] NSW Government ICT Strategic Plan - People First - A new direction for ICT in NSW, 2006
www.gcio.nsw.gov.au

2: How are public offices using the web?

Most NSW public offices are using the web as a 'customer service window'. Websites serve a variety of purposes for public offices ranging from delivery of basic information to the ability to download forms and complete transactions online seamlessly. For every purpose the web is used for, a different record may be generated. Public offices are also using the web to host intranets and extranets.

Website operations / technologies

Type of public office website technology Description How used Change frequency
Relatively static websites and web resources Website is a relatively stable repository for public office publications. The only real interactivity is that which allows movement from one document to another. Essentially the website is a collection of static documents sitting in folders on a server linked together with hyperlinks. Updates add information that is not likely to change.
Websites that serve as a fluid repository for public office publications and information Similar to a static website (see example above) in that the only real interactivity is that which allows movement from document to one another. The website is used by public offices as a communications tool for information that changes frequently. Updates to this kind of website will often include revision, removal and addition of information on an 'as needed' basis by the public office [1].
Static websites that serve as a limited communications tool through form based interactivity Website utilises forms where end users can submit questions or comments. These sites are largely static in that the form is generally submitted through a public mailbox yet other website content remains static. Website is designed for minimal interaction between the public and the public office. Used to collect information such as comments, requests and orders. The forms that are used for obtaining information may not change often, yet the public office needs to be aware of the frequent changes to the back end system or database which stores the information obtained from the forms.
Websites based on dynamic data access (query based access to public office information) Used as a user interface for accessing the public office's database/s. Often documents exist as objects in a database and each document has its own unique identifier. Site users search prepared lists or put together their own searches which query the content of a database. Information contained in databases behind the site may be continually changing even if the site's top level pages remain static.
Dynamically generated websites The website is an interface to multiple applications and information services. The component parts of each individual page are generated using a combination of databases and style sheets. This activity is also known as 'on the fly' [2]. Used to deliver the public office's major services online. This website may change frequently as information supplied by the end user and displayed on the site is varied. This form of website activity does not exist in a single form as each user can see a different 'site'. The processes used to build the pages involve the use of a number of software tools and hence the website will often behave more like a software application rather than a publication [3].

Footnotes

[1]The US National Archives and Records Administration website - NARA Guidance on Managing Web Records, January 2005. Accessed 21 December 2007.
www.archives.gov/records-mgmt/policy/managing-web-records-background.html
[2] The National Archives of Australia. Archiving Web Resources: Guidelines for Keeping Records of Web-based Activity in the Commonwealth Government, March 2001 http://www.naa.gov.au/records-management/publications/Archiving-web-guidelines.aspx
[3] Ibid.

3: Statutory requirements and policy context

Records generated from New South Wales public office websites operate under a legal and policy framework, including the State Records Act 1998, evidence laws and whole of NSW government policies on ICT implementation and management of publications.

Legislation

The State Records Act requires each public office to 'make and keep full and accurate records of the activities of the office' (s12 (1)). This refers not only to paper records but all records regardless of format. Section 14 of the Act also places obligations on public offices to '…maintain accessibility to equipment / technology dependent records.' This means that the ongoing retrieval of web records needs to be considered as well as the capture method.

Evidence laws, such as the Electronic Transactions Act and the Evidence Act, mean that web records may be tendered as evidence in court, discovered or subpoenaed. Public offices may need to produce past pages that are no longer publicly available and demonstrate that they have been properly protected from unauthorised alteration or deletion.

Standard on digital recordkeeping

State Records' Standard on digital recordkeeping sets out minimum compliance requirements for NSW public offices for defining their digital records, digital recordkeeping system functionality and the creation and management of recordkeeping metadata for digital records. This standard applies to all digital records, including web records.

The Standard can be used to ensure that web records are being managed appropriately as records. For example, content management systems can be assessed against the requirements of the Standard to determine whether they are also functioning adequately as recordkeeping systems.

ICT Strategic Plan - People First

In addition to requirements in legislation and standards, public offices need to be aware of policy requirements operating on NSW government websites, in particular the NSW Government ICT Strategic Plan - People First.

The goals of this plan include servicing a greater number of customers, tailoring electronic services to suit the needs of clients with differing expectations and promoting best practice in the management of ICT. By applying the strategies and goals of this plan to public office website management good website practice will be promoted as well as making the task of managing web records easier.

NSW Government Web Style Directive

One of the policy requirements of the NSW Government ICT Strategic Plan - People First document is the implementation of the NSW Government Web Style Directive to public websites.

The purpose of this document is to set standards for NSW Government websites in terms of their look and feel. Content, subject to general legislative requirements for privacy, security, accessibility, the GIPA Act and copyright, is a matter for each public office to consider.

Legal Deposit

There are collecting projects in Australia to capture online publications deemed to be of national significance as well as a number of requirements under Federal and State legislation regarding the legal deposit of publications [1].

Legal deposit requires publishers of public office publications to deposit copies of their publications in deposit libraries. These include the State Library of NSW, The University of Western Sydney Library, The National Library and your public office library. The purpose of legal deposit is so that all NSW produced publications remain publicly available and that the continuing cultural heritage of NSW is maintained. Secondary purposes may include provision of statistical information on publishing and bibliographic control.

These requirements are different from the requirements to keep publications as records and archives and should be done alongside mandatory recordkeeping requirements. For more information see Premier's Memorandum 2000-15 Access to Published Information - Laws, Policy and Guidelines. Chief Executives are responsible for ensuring that publications are deposited in accordance with the policy [2].

Footnotes

[1] The National Archives of Australia Archiving Web Resources: Guidelines for Keeping Records of Web-based Activity in the Commonwealth Government, March 2001
[2] NSW Department of Premier and Cabinet. Premier's Memorandum 2000-15 Access to Published Information - Laws, Policy and Guidelines http://www.dpc.nsw.gov.au/publications/memos_and_circulars/circulars/2000/c2000-68

4: What are web records?

Web records can be defined as records generated, captured or received using web technologies. Web records on an organisation's website can generally fall into three categories 1) web content records, including introductory or descriptive information about the organisation, its activities or particular areas it manages, but also publications that it makes available on the web, 2) inputs/outputs of transactions performed via the web e.g. data submitted via online forms and 3) website administration records, such as statistics, diagnostics etc, which provide evidence of website operations and management [1].

Web records are usually created in web content management systems or other Web Authoring software either on a user's computer or on a web page (e.g. Wikis and blogs) and like other digital records if they provide evidence of official business there is a need to keep them as records.

For the length of their life, web records, like other records need to be authentic, reliable and tamper-proof. In many cases a record could need to be kept beyond the span of a content management system, or with controls that the content management system cannot offer. In this case it is important that public offices capture records into proper recordkeeping systems.

Increasingly public offices are also looking to social media sites (e.g. Twitter and Facebook) in order to expand their client base or communicate more effectively with some client groups. Web records are being created as Government business is being performed on social media sites. Public offices will need to consider which of these records need to be captured and appropriate methods for capturing and managing them as records.

Likewise, many public offices are making use of cloud computing/software as a service for the creation and management of their records. A public office will need to consider recordkeeping implications of cloud computing arrangements. See the Bibliography for further information.

Footnotes

[1] The US National Archives and Administration, NARA Guidance on Managing Web Records, January 2005. www.archives.gov

5: Why keep web records?

There are three main reasons why web records need to be kept. These are:

  • business continuity
  • accountability
  • obligations relating to publications.

Business continuity

Web records must be kept in a form that will allow the business of the public office to carry on efficiently on a day to day basis. Examples of types of 'day to day' records that are required to be kept include but are not restricted to web-based invoices, rosters, schedules or emergency procedures.

Keeping good records of website activity is also beneficial as they can be used to help the public office's strategic planning regarding web management and identify key areas that can be improved or that the public responds well to.

Accountability

All public offices need to be accountable for internal and external transactions of their business. Public offices need to be able to account for any advice, justification or other action that it has undertaken in the course of business and be able to answer to those actions. Good recordkeeping underpins accountability and as more public offices are using the web as a point of service for their customers, good recordkeeping of web based activity is necessary.

Publications

Publications can be classed as any form of information which is published, intended to be made available to the public or able to be accessed by the public. This includes information available on a public office's website. Publications are not limited to those publications that have an International Standard Book Number (ISBN) or International Standard Serial Number (ISSN).

In this regard the retention of web based publications should be treated in accordance with retention periods recommended for publications. For further information see Recordkeeping in Brief 38 Keeping publications and promotional materials as records available on the State Records website.

6: A recordkeeping strategy for capturing web records

State Records does not require entire websites of NSW public offices to be archived. The National Library of Australia collects many samples of websites and online publications of Government agencies to fulfil its primary role of acquiring and maintaining comprehensive documentary material relating to Australia and preserves these records so that they are accessible for research now and in the future. This initiative is called PANDORA and its selective archive now holds over 5000 websites [1]. It is important to note that PANDORA does not lessen the recordkeeping obligations of public offices.

State Records recommends, rather, that public offices select records from the website that need to be captured in order to provide evidence of the business activity that is occurring in digital form. These records should be managed according to the business rules and requirements for the function they support, in the same way as records created by other means.

Public offices should develop a recordkeeping strategy for the capture of web reecords. This involves appraising:

  • what web records they need to make and keep
  • when web records need to be captured, and
  • how long they need to be retained.

This information can help the organisation to determine how to capture web records appropriately to meet their identified requirements. Managing risks appropriately is a major part of this strategy.

Appraisal of web records

What is Appraisal? The process of evaluating business activities to determine which records need to be captured and how long the records need to be kept, to meet business needs, the requirements of organisational accountability and community expectations. [AS 4390 Part 1 Clause 4.3]

Do the records need to be captured at all?

Appraisal of web records can involve considering each type of record on a website (or social networking site) and whether these records need to be captured at all.

Public offices should consider if the web is the only place where the record is available or whether it has been captured already e.g. into their EDRMS. If it is being captured elsewhere and there are policies/responsibilities assigned to ensure consistent capture, the organisation may not need to capture the web version at all unless perhaps the web version has a particularly different 'look and feel.'

For example, the organisation may have a collection of photographs displayed on their website. In all likelihood these are simply being accessed or delivered by a web browser but they are being managed as a collection by the organisation already in another way (e.g. a database of images). Web copies of the images may not require additional capture. However, if the organisation is selling these images online, they would need to capture the transactions taking place.

Do records need to be made and kept regarding the availability of web records?

Public offices should also consider whether records need to be made and kept of when a particular record (or version of a record) is made available on the website, who made the information publicly accessible, when the record was removed from the website and under whose authority. There may be significant risks if they cannot show these actions. Often requirements such as these can be met by carefully structuring recordkeeping metadata for web records, using the requirements of the Standard on digital recordkeeping as a starting point.

Example: An applicant to council had his development application refused as it does not meet current development rules. The applicant claims that before submitting his development application he checked the council's website. The version of the development rules available on the website was outdated. He blames the council for displaying incorrect information and demands to be compensated. The council needs to be able to prove what version of the development rules were on the website at that particular date.

How long do web records need to be kept?

How long public offices need to keep web records depends on the public office's specific legal and busienss environment as well as recordkeeping requirements. Records of websites, whether they are publications or transactional records of online business processes, are subject to the same disposal rules as other official records of your organisation. Public offices that have a functional retention and disposal authority (FA) approved by State Records should use it to assign retention periods to web records relating to their 'core business.'

For example, a public office that is responsible for renewing vehicle registrations may have this function available to the public from their website - that is the registration can be renewed online. This means that the public office will retain a record of this online transaction and as this transaction is part of the function of the public office, the record will be sentenced using their functional authority.

For administrative records (eg relating to the ICT implementation of a website) and some web content such as intranet information on HR policy or ICT procedures, public offices should assign retention periods using general retention and disposal authorities released by State Records such as General retention and disposal authority - Administrative records.

Once a retention period has been determined, web records must be kept in an accessible form for the entirety of their retention period.

What are functional and general retention and disposal authorities? These are documents authorised by the Board of State Records NSW that set out appropriate retention periods for classes of records. Functional retention and disposal authorities (FAs) authorise the retention and disposal of records unique to a specific organisation. General retention and disposal authorities (GAs) authorise the retention and disposal of records common to more than one organisation. Such records may include general administrative records, common records that relate to unique functions, or records relating to the unique functions of like organisations such as local councils, universities, and public health services.

Changes to web records

A record is captured at a specific point in time. However, web records tend to change. Some may change minimally where others with dynamic or interactive content will change many times a day [2].

An appraisal should consider whether changes to web records need to be recorded. Public offices need to conduct a risk assessment to determine what information needs to be captured about changes and how often new versions of web records need to be captured.

For example, does the organisation need to capture an audit trail of all changes made to a web record? Do they need to know who added or changed information and when it was published?

The rate of change of web records should also be considered as a factor when deciding on a method of capture.

Risk and risk assessment

During the planning phase of a new website for a public office, a thorough risk assessment should be completed with an emphasis on recordkeeping. However risk assessments are helpful not only for the planning stage of a website but can also be carried out on any current website to identify the current risks and determine ways to mitigate the risks found. Risk assessments help to identify the level of recordkeeping required for web records of any particular public office.

Risks to consider in regards to records created through web based activities generally stem from unauthorised loss or destruction and include:

  • litigation and legal disputes e.g. an inability to validate transactions that have occurred through the public office website's front end service and to have a record of what was on a website
  • political consequences / unfavourable media attention because of an inability to account for past web-delivered information
  • business discontinuity or increased costs if information is inaccessible, e.g. an inability to track web-assisted policy development.

For example, a State-owned corporation uses its website to notify customers, including industrial users, of any changes to its service. Without records to demonstrate that a notice about a disruption was placed on the website on a certain date and time, and what the notice contained, the utility would find it difficult to defend itself in the event of legal action arising from the disruption as well as possibly causing unfavourable media attention.

A risk assessment should address all possible consequences of incorrect, lost, or unrecoverable records. The results of a risk assessment will provide a basis for public offices on how web records should be created, maintained and how long they should be retained as a State record.

To mitigate risks, public offices need to preserve records as long as they are required, both legally and for business continuity. However managing web records can be a complex process as web content may change frequently and hence change the organisation of the content. Web records produced through front end user interfaces may also need to be captured.

Some steps to help mitigate risk associated with web recordkeeping are:

  • use process analysis techniques to determine where web records are created and should be captured
  • ensure there are proper procedures and processes to follow
  • ensure public office staff are trained and aware of their responsibilities.
  • document the systems used to create and maintain web records.

For more information on process analysis and risk assessment for recordkeeping see:

How to capture web records

The outcomes of risk assessments and appraisal activities will assist the public office in deciding how to capture their web records.

For example, when the rate of change is low, then manual methods of record capture might be suitable. When the rate of change is high, then the public office may need to consider automated methods of capturing changes to the information e.g. logging of changes and version control in a Content Management System (CMS), including tracking of who made the changes and when the changes occurred.

For example, if some web records only need to be retained for one or two years, if may be suitable for them to reside in the public office's content management system until their retention period has expired, providing they can be supported as records (e.g. unable to be altered or tampered with, remain accessible and useable). For records that need to be kept longer term or as archives, it is more appropriate to ensure capture within an EDRMS which will support their long term management.

Web records can have up to five essential characteristics that may be required for them to be understood. These are: content, context, structure, appearance and behaviour. An important factor to consider when choosing a method of capture is whether the characteristics essential to the record's meaning can be retained.

For example, if a web record contains a number of hyperlinks, will the meaning of the record be obsured if it is printed and filed so that the hyperlinks are no longer active?

If essential characteristics are unable to be retained by the methods available to the public office, they should consider the risks this poses.

Below are some suggested methods for capturing web records. The options given are not mutually exclusive. Please note that this section of the guideline has drawn strongly from findings of the Public Record Office Victoria's Advice 20b: Technical Issues for Capturing Web Records.

State Records recommends the use of the strategies listed in the table below in terms of applicability and useability. It should be noted that the State Records Act does not require entire websites of NSW public offices to be automatically archived.

Strategy Application Pros Cons

Capture in content management system (CMS)

Description: This strategy involves retaining web records in the organisation's content management system.

Static websites

Websites that serve as a repository for information that can change

Websites that are used as a communications tool through form based interactivity

Dynamic data access websites

If the organisation already has a CMS there is no additional work required to capture and retain these records

Only suitable for short term records where the CMS has been assessed as having adequate recordkeeping functionality

Automated capture

Description: This strategy involves the automated capture of web pages as they are published, linking web content management systemsw with a recordkeeping system (e.g. EDRMS or a line of business system which is able to keep records).

Static websites

Websites that serve as a repository for information that can change

Websites that are used as a communications tool through form based interactivity

Dynamic data access websites

Suitable for recording all new content as it is published on a website

Smaller storage space required compared to storing snapshots and archiving websites in their entirety

ERDMS applications increasingly designed to interface with or contain web content management systems

Recordkeeping is selective to your requirements

Ability to capture online forms transmitted via website front end users to agency email addresses rather than a database

Not all links may be preserved as active

Additional customisation may be required to save pages to more than one file/aggregation

Not suitable for complex dynamically created websites

Manual capture
Description: Users select pages / content to be captured into an EDRMS.
Websites that serve as a repository for information that can change

Static websites

Websites that are used as a communications tool through form based interactivity
Recordkeeping is selective to your requirements

Ability to capture online forms transmitted via website front end users to agency email addresses rather than a database
More labour intensive than automated options

Relies on staff following recordkeeping rules

Other strategies include:

Strategy Application Pros Cons
Print and file
Description:
All page changes are printed and filed within a paper file. All other information regarding the web site is also printed and filed.
Static websites

Websites that serve as a repository for information that can change
Suitable for recording new content

Applicable to public offices that do not have a website that changes often

For public offices without an EDRMS

Loss of context and potential for reuse


If site begins to change often can be difficult to print all changes

Must be part of procedures to work efficiently and effectively

Capture at Web Browser (Harvesting)
Description:
A harvester copies pages from a website and saves them locally. A harvester is able to capture most types of web pages.
Static websites

Websites that serve as a repository for information that can change

Websites that are used as a communications tool through form based interactivity (may also need back-end capture)
Capture can be simple and easily maintained. The capture process is the same irrespective of how the web page is generated by the web server.

Captures exactly what is delivered to the user

Harvesting tools are widely available through commercial or public domain software
Implementation can be complex.
Cannot deal with websites where the pages are not linked together

Difficulties when the content of a webpage depends on the context of a request (especially dynamically created web pages)

Only takes snapshots, that is only provides information at a single point in time.
May not recognise all links and reference URLs
Capture transactions at web server
Description:
Suitable for capturing HTTP requests made to the web server and the consequent responses as they occur ie user interaction.
Static websites

Websites that serve as a repository for information that can change

Websites that are used as a communications tool through form based interactivity

Dynamic data access websites
Useful when it is not desirable to capture the website itself in its entirety, only the interaction

Captures exactly what is received and sent to a user

Can capture non-linked websites

Can be used for highly dynamic websites
Only captures what is received and accessed

Possible privacy implications (the record will show what individual users requested from the website)

Difficult to associate requests with responses from one user

Few available products
Capture from back - end sources
Description:
Captures the data that provides the content for the website rather than capturing the website itself.
Static websites

Websites that serve as a repository for information that can change

Websites that are used as a communications tool through form based interactivity

Dynamic data access websites
Smaller storage requirement (as opposed to snapshot or entire pages being captured)

Possible to capture records of sites not linked or which change frequently
Does not record what the actual web page delivered to the user looks like

Processes generating the web pages have to be documented

Difficult to demonstrate how the web would have appeared if using more than one back end application
Maintaining a replica online website archive

Description:
Replicates all material posted to the active website, including past and present postings.
Suitable for the capture of all websites, although this form of capture may not be necessary for websites that have a low level of complexity as cost may outweigh benefit Easier to access archived postings as there is no reconstruction involved

The entire site can be seen as it was at any point in time rather than the last time it was captured by schedule

Reliable option for complex websites
Relies on linking recordkeeping system with a dedicated web server

High costs

Large amounts of storage space required

NB. This list is not exhaustive of all possible strategies for capture of web records, nor is the listing of applications exclusive.

Tracking changes to website structure

Changes to the organisation of a website and the interrelationships between the information and its placement on the site can be as important as preserving the content of the website, and care should be taken to ensure that these changes are recorded as well as the content. Decisions about documenting website structure, as with content, should be made as an outcome of a risk assessment. A good way to track changes to website structure is by keeping a record of the site map as it changes.

What to do about decommissioned / legacy websites?

Decommissioned or legacy websites can pose a variety of problems when there are records that need to be kept from the old website. These problems often stem from how the past website was created. Nonetheless if there are records from past websites that are required to be retained they must be preserved. Legacy websites need to be treated the same as current websites in regards to recordkeeping and the inheriting public office needs to treat the legacy website as if it were a record originally created by them. Similar questions to those a public office needs to consider when developing a recordkeeping strategy can be applied to decommissioned or legacy websites including:

  • Is the information on this website the only copy available and hence needs to be retained? Was there any information transferred intact to the new website?
  • Has any of the content been captured into a recordkeeping system or by some other means already?
  • To what extent is the site subject to the public office's functional retention and disposal authority or a general retention and disposal authority?
  • If maintained in an offline environment, is the site still contextually meaningful?[3]

For example, the former Premier Nathan Rees was the first New South Wales Prmier to have his own website (separate to the Department of Premier and Cabinet). The website contained a full set of media releases, all the videos of the Premier that had been uploaded to YouTube and elsewhere, biographical information and details of his policy objectives and Cabinet.

It was necessary when he left office to capture the content of the website as records for long term retention. The Premier's website, however, had been created and maintained in a proprietary software system which required use of its software to display the web pages, and which had limited export capability. So while the media releases and videos were simple to extract, being in formats that did not rely on the software, the pages themselves were a different story.

It was necessary in fact to convert the pages to a suitable preservation format - PDF. While this resulted in some loss of functionality, the orverall look and feel and content of the site were captured in line with State Records' Policy on digital records preservation.

The videos represented a separate challenge in that they were created in proprietary formats (Windows Media, Flash) and long term preservation formats suitable for digital audiovisual records are still under discussion in the digital preservation community. However these formats (Windows Media, Flash) are considered low risk being widely adopted and so were deemed suitable for now.

Footnotes

[1] National Library of Australia. Staff Papers - Keeping online information accessible for e-governance and e-democracy. 2004. Phillips, M.E and Cunningham, A. www.nla.gov.au/nla/staffpaper/2004/phillips1.html

[2] Public Records Office Victoria. Advice to agencies 20a: web generated records, Version 1, 2007 http://www.prov.vic.gov.au/records/Web_Advice/web_advice.asp

[3] ibid.

7: Maintaining web records

Implement disposal

What is Disposal? A range of processes associated with implementing appraisal decisions. These include the retention, deletion or destruction of records in or from recordkeeping systems. They may also include the migration or transmission of records between recordkeeping systems, and the transfer of custody or ownership of records. (AS 4390 Part 1 Clause 4.9)

Web records are subject to the same disposal rules as any other form of State record within a public office. Disposal of records involves a range of processes associated with implementing disposal decisions. Disposal can mean various processes and can include the destruction of records, the retention of a record as a State Archive or transfer of ownership. Web records should be included in a public office's routine disposal activities. For more information on disposal see State Records' RIB 48 Disposal at a Glance available on the State Records website.

Preservation issues

What is Preservation? Preservation is the process and operations involved in ensuring the technical and intellectual survival of authentic records over time. (AS ISO 15489 Part 1 Clause 3.14)

There are a number of preservation issues surrounding the long term preservation of web records. Once a web record has had a retention period applied to it, public offices need to ensure that the records will be preserved for that specific period of time and be accessible in their entirety for that period.

Many preservation issues for electronic records including web records is the subject of media and technology obsolescence including file formats, as well as linking metadata with individual records. For more information see Guideline 22- Managing digital records available from the State Records website.

Access and retrieval

Like other records, web records need to be accessible for as long as they are required. Records may need to be accessed at any time and may be required legally under the Government Information (Public Access) Act 2009 and the Privacy and Personal Information Protection Act 1998. A record's location should not impede retrieval and should be known to the public office at all times.

Web records, just like other records need to be accessible for their determined life period and need to be governed by standard documentation and location controls. For more guidance on the accessibility and retrieval of web and other technology dependent records, see State Records' Guideline 22- Managing digital records.

Due to the nature of web records and the increasing collection of personal information via the web, public offices have an obligation to ensure that private or sensitive information in web records is protected from misuse or unauthorised access. Web records should be retained in a secure system such as an electronic recordkeeping system which has purpose built security controls designed to protect private and personal information.

8: Where to get assistance

Public offices can get assistance from State Records, which is responsible for issuing policies and guidance to help public offices comply with statutory and regulatory recordkeeping requirements. As the State's records and archival authority, State Records also has a vested interest in ensuring all records in all formats and environments (including web records) are properly managed.

All the State Records publications mentioned in this guideline are available from the State Records website or contact Government Recordkeeping for more advice.

9: Bibliography

Archives New Zealand- Continuum Create and Maintain A guide to developing recordkeeping strategies for websites June 2006 http://www.archives.govt.nz/continuum/documents/publications/g20/

Australian Government Information Management Office. Archiving web resources - better practice checklist. Version 3 2004. www.agimo.gov.au/checklists

National Archives of Australia, Archiving websites: Advice and Policy Statement, 2011 http://www.naa.gov.au/records-management/publications/Archiving-web-guidelines.aspx

NSW Department of Premier and Cabinet. Premier's Memorandum 2000-15 Access to published information - laws, policy and guidelines http://www.dpc.nsw.gov.au/publications/memos_and_circulars/circulars/2000/c2000-68

NSW Government ICT Strategic Plan - People First - A new direction for ICT in NSW, 2006 www.gcio.nsw.gov.au

NSW Premier's Department. Access to published information - laws, policy and guidelines. May 2000, revised April 2006. http://www.dpc.nsw.gov.au/__data/assets/word_doc/0010/1225/Access_Published_Information_April_06.doc

Phillips, M.E, Cunningham, A. National Library of Australia - Staff Papers - Keeping online information accessible for e-governance and e-democracy. 2004 www.nla.gov.au/nla/staffpaper/2004/phillips1.html

Public Records Office Victoria. Advice to agencies 20a: web generated records, Version 1, 2007 http://www.prov.vic.gov.au/records/Web_Advice/web_advice.asp

Public Records Office Victoria. Advice to agencies 20b: technical issues for capturing web records, Version 1, 2007 http://www.prov.vic.gov.au/records/Web_Advice/web_advice.asp

State Records. Keeping publications and promotional materials as records (RIB38), revised August 2007, available in the Government recordkeeping manual under 'Recordkeeping in brief.'

State Records. Managing digital records (Guideline 22),  Jan 2009, available in the Government recordkeeping manual under 'Guidelines'.

State Records. Managing recordkeeping risk in the cloud: ensuring the proper creation, management and disposal of official records in cloud computing environments, 2010, available from the Future Proof website under 'Resources.'

State Records. Records management and Web 2.0 (Guideline 24), 2009, available in the Government recordkeeping manual under 'Guidelines.'

State Records. Managing records of websites and web-based transactions (RIB43), 2005, available in the Government recordkeeping manual under 'Recordkeeping in brief'.

State Records. Transferring records out of NSW for storage with and maintenance by service providers based outside the State, 2009, available in the Government recordkeeping manual, under 'General retention and disposal authorities.'

The US National Archives and Records Administration website - NARA Guidance on Managing Web Records, January 2005. Accessed 21 December 2007. www.archives.gov/records-mgmt/policy/managing-web-records-background.html

Appendix 1: How do I manage web recordkeeping in local government?

Council websites are key information sites for ratepayers and are increasingly the sites of much local government business. Because Council business is documented and performed on your website, it is important to make sure that you are making and keeping records of this business.

The purpose of this guidance is to explain what types of records need to be kept to meet business and accountability requirements.

The bulk of the information on your website should already be captured in your Council’s corporate records system. What is on your website should just be a copy of this information. If the record is already captured in your corporate records system, you do not need to capture a copy of it again or preserve another copy forever in your content management system.

However there are two key recordkeeping requirements that you do need to consider in relation to your website.

Requirement… Explanation…
Documenting what was on the website when You may need to determine if, for business, reporting or risk management purposes, you need to keep a record of when certain corporate records were made available on your website. You also need to determine whether you need to keep other records of web administration, such as who made the information publicly accessible, when they did this, when the record was removed from the website and under whose authority.
Capturing unique web material Some information will be unique to your website, such as introductory or descriptive information about your local government area and the services Council provides. You do need to determine whether some or all of this needs to be formally captured as a record in your corporate records system.

The rest of this guidance provides specific advice about managing the types of Council information commonly available on local government websites.

How do I manage…?

How do I manage information about Council services on our website?

Online information about Council services will tend to either be:

  • introductory or descriptive information about your services, processes or requirements and
  • links to formal documents about Council services and forms for applications, enrolments or enquiries.

Types of Council services that you may need to keep records about include:

  • planning and development
  • children’s services
  • disability services, or
  • any other services offered by Council and advertised or provided via its website that you believe need to be documented.
Introductory or descriptive information about your services, processes or requirements

This information will generally be unique to your website. That is, it is unlikely to have been captured as a formal record in your corporate record systems.

Because of the high risk nature of this area of your business, you may decide to save a record of this introductory or descriptive information in your corporate records system. If you do this, you should also save a new record each time this information changes, so that you can always account for your public statements about this key business area.

Links to formal documents about Council services or requirements and forms

Formal documents like these should already be captured into your corporate records system. The formal process for approving such documents should always involve capturing the final, official version in your records system. The version on your website is therefore only a copy and does not need to be captured again in your records system.

However, you should keep a record of when Council documents were published on your website and when they were removed. For accountability purposes, you may also want to record the names and positions of the staff responsible for uploading and removing this content.

If people can submit forms or enquiries online, you need to ensure that these applications or enquiries are captured into your corporate records system and that they are made accessible to the staff who need to process them.

Also, when using forms, make sure that you formally capture each new version of a form and that you record the specific dates that each version of your forms was used or accessible online.

How do I manage Council minutes and meeting papers on the website?

Making minutes and meeting papers freely available is an important requirement under the Local Government Act.

To document this area of your business you can:

  • ensure the final version of the minutes and meeting papers are captured in your corporate records system
This formal record should already exist in your corporate records system.
  • capture a record of updates to your publications section

Capturing a list of your publicly accessible minutes and meeting papers will provide a record of how you are meeting your s12 obligations under the Local Government Act. You could:

  • capture a copy of the online file list of available council papers each time new minutes or meeting papers are uploaded
  • clearly specify in your procedures for documenting and maintaining Council minutes that uploading the latest version of minutes is a key responsibility and nominate a specific officer to perform this task

How do I manage the news updates that appear on our homepage?

The homepage for many council sites includes an active news area with information about Council decisions and activities. There are no hard and fast answers about the records you should keep of this service. It depends very much on the type of information you provide via your news area and the types of risk associated with this information. With this in mind you can decide to:

  • capture a copy of these news stories each time a new story is added

In order to maintain a full record of Council news and events and in order to keep a record of your public statements about these, you may decide to capture a copy of your news stories each time a new story is added. You can do this by:

  • automatically capturing a full record of each news story as it is uploaded
  • capturing summary information of newsfeeds by capturing RSS notifications of news updates
  • capturing a weekly or fortnightly digest of news information
  • not capture a copy of these news stories each time they are added
You may perform a risk assessment and determine that, as each of these news stories is already captured in some way as a business record through the minutes of council meetings, newspaper advertisements or some other mechanism, you will make a business decision not to capture these news updates.
  • capture a copy of the news stories that you know deal with high risk business areas
You decide that most of the news you publish is of a low risk and informative nature and that most of this information is duplicated in other council records. However, from time to time, you know that important Council requirements are advertised in part via your news update page.
You therefore decide to implement a web management procedure whereby all news updates coming from a certain business area or all updates requiring community response or participation are flagged for capture as records in your corporate records system. In these instances, you may want to assign the responsibility for record capture to the business area involved.

How do I manage online surveys?

Many councils are now using online surveys to ask ratepayers about council services and how they should be updated or improved. This data is used as the basis for decisions to start, stop or refine council services. To capture records of this important research you should:

  • ensure the final version of the survey is captured in your corporate records system
This formal record should already exist in your corporate records system.
  • capture a record of the time period that the survey was available online

If the survey is going to have a direct impact on the services Council offers, you may have ratepayers complaining that they did not see the survey and they may ask you to demonstrate the specific time period that it was available for. Make sure that you have a record of these dates as evidence of your consultation process. You can capture this by:

  • a report from your content management system
  • a metadata notes description attached to the formal record of the survey captured in the records system
  • a formal business report to management that reports on the consultation process and specifies the location of the survey and the time period that it was available
  • make sure mechanisms are in place to capture a formal record of all responses to the survey

Council officers need the results of the survey to inform their business decisions. Make sure formal records are able to be kept of all survey responses. These records should:

  • link questions and answers. Some online survey tools or forms software do not connect answers with questions and so can make completed forms or survey responses very difficult to interpret
  • be captured into the corporate records system, either individually or as a comprehensive report of all survey responses
  • be anonymous where appropriate. If your survey claims that no identifying information will be linked to survey responses unless expressly added by the person completing the survey, make sure that no identifying information such as email addresses or server locations is captured in the corporate records system.

How do I manage documents that are posted online for comment?

These documents should be managed in the same way that surveys are managed:

  • make sure that the document is already captured as a formal record in your corporate records system
  • make a formal record of the exact dates that the document was available for comment online, so that you have an official record is required of the exact period that the document was publicly available.

How do I manage information posted about consultation forums or public meetings?

It is possible that this information exists only on the web. Therefore:

  • make a record of these information posts
If these information posts deal with contentious proposals, such a propositions to outsource childcare or reforms to zoning permissions, it could be important to make a formal record of your notices about consultation forums or public meetings. Even if you have also advertised in the local newspaper and kept records of this consultation, it could also be important to keep a record of your web announcements as well.
  • keep a record of how long the information was publicly accessible for
If you keep a record of these information posts, you should also keep a record of the period during which they were available online

Retention and disposal

All the records that you make and keep of your web activity are subject to the retention and disposal requirements of the State Records Act. This means that there are legally specified periods that your web records must be kept for.

There is not one specified retention period for all your web records. Retention periods differ according to different business needs. For example, web records from high risk business areas, such as planning and development, may have to be kept longer than records about less risky services. Your records manager will be able to give you more guidance about how long different types of records have to be kept for.

The records described in this guideline generally have retention periods ranging from five years and upwards. As a web manager, you should speak to records staff about the retention requirements that apply to your specific web records. Having this information will help you to plan for how these records can best be managed.

Example: Managing web records using retention requirements
You and your records manager identify that your news updates need to be kept for 5 years in accordance with your specified retention requirements. Together you decide that these records will best be managed as secure records in your content management system for this period.
However, you also both decide that all web records with retention periods longer than 5 years should be exported out of the content management system and into your corporate records system on a regular basis. The corporate records system is better equipped to sustain secure records for longer periods and so you decide that this is the best and most cost effective solution for managing long term retention requirements.

Knowing the retention requirements that apply to your records and understanding how these can best be managed means your web records will be protected and preserved and managed in the most cost effective way possible.

© State of New South Wales through the State Records Authority, 2008.
First published April 2008 / Revised edition 2009
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