Recordkeeping In Brief 23 - Managing records in administrative change

• Purpose
• Scope
• What is administrative change?
• When a function is transferred between NSW public offices
• When a function is transferred to another government
• When a new function is created
• When an existing function is abolished
• Amalgamation of public offices into larger organisations/entities
• Acknowledgements

Purpose

To provide guidance for public offices on managing records at times of administrative change. The efficient management and transfer of records between organisations will ensure that functions of government can continue to be administered effectively and that the corporate memory of New South Wales is preserved in the records.

Scope

This guidance applies where functions are created, abolised or transferred between public offices or governments. It also gives advice regarding the merging of public offices into larger entities.

For guidance on the recordkeeping issues associated with the outsourcing of government functions see State Records' guideline Accountable outsourcing. For guidance on the recordkeeping issues associated with the privatisation of public offices or functions see Recordkeeping in brief 29 Privatising public offices.

What is administrative change?

Administrative change may involve:

• the transfer of a function between NSW public offices
• the transfer of a function to another government, either from NSW to another government or into NSW from another government, e.g. the Commonwealth
• the creation of a new function, or
• the abolition of an existing function
• the amalgamation of public offices into a larger organisational entity.

Examples of triggers for administrative change can include:

• a new piece of legislation
• a reshuffle of Ministerial portfolios
• a change of Government after an election
• a merger (or de-merger) of two or more organisations.

Each of the types of administrative change and the recordkeeping issues to consider is addressed below.

When a function is transferred between NSW public offices

Overview

The transfer of a function between NSW public offices

• will involve the transfer of responsibility for records, and
• may also involve the relocation of staff and records to different premises.

Within NSW, a key principle is that records relating to a function should be transferred with the function. This will help the receiving agency to manage the function effectively and with as little disruption as possible.

Records relating to a function should be transferred with the function.

Transferring organisation: this is the public office which transfers a function to another public office.

Receiving organisation: this is the public office which receives an existing function transferred from another public office.

How to transfer control of records

The table below summarises the process for managing the records associated with a function when that function is transferred within or between public offices. Further detail on each stage is provided after the table.

Stage 1. Identify records of the function

The transferring organisation needs to identify all records associated with the function. Records of the function will be specific to the function, but may also include general administrative records such as personal files of staff transferring with the function. Talking to action officers will help with records identification.

Stage 2. Determine management arrangements 

Reaching a formal agreement 

In a transfer, the responsibilities of each public office should be agreed upon and formally documented. Discussions between those assigned responsibility for records management in the transferring and receiving organisations should begin early so that the right management decisions are made. The agreement should include:

• records to be transferred
• records to be retained by the transferring organisation
• roles and responsibilities
• details of any records in secondary storage including management issues such as contractual arrangements, costs, outstanding charges. 

Deciding which records to transfer

Check whether the records that relate to the function are maintained as a separate series or group. If they are, the series should be transferred in its entirety to the receiving organisation. If not, it may be necessary to transfer only part of a series, or to copy files or data to ensure that both organisations still have access to the records they need.

Records of the function already maintained in secondary storage should also be included in the review of management arrangements. If the records are required by the receiving organisation control should be transferred to the receiving organisation. Where the secondary storage is managed by a commercial storage provider, there should be an existing formal contract between the transferring organisation and the provider. Even when the records remain with the provider, responsibility for managing the contract should be transferred to the receiving organisation. 

Agreeing a cut off date

You may wish to agree a cut-off date for older records which will not be transferred to the receiving organisation. This will be based on an analysis of the needs of both organisations.

Determining whether State Records authorisation is required

The transferring organisation may require authorisation from State Records to transfer records to the receiving organisation. Under the State Records Act 1998, public offices are not allowed to transfer the possession or ownership of a State record without the authorisation of State Records. This applies to the transfer of records between separate organisations, such as local councils and universities. It does not apply to the transfer of records between agencies which are part of the NSW State Government.

For example, the authorisation of State Records is required to transfer records from one local council to another where functions have been transferred as a result of boundary changes. The authorisation of State Records is not required to transfer records from one NSW Government organisation to anotherorganisation where functions have been transferred as a result of administrative change.

If you are uncertain whether you need authorisation, contact State Records. Note: For the transfer of functions between governments, see the section 'When a function is transferred to another government'.

Stage 3. Review those records not required by either organisation

The transferring organisation should review records in its control which are not required by either organisation. The organisation should review records against current retention and disposal authorities and sentence records. This will involve: 

• transferring records to secondary storage for ongoing retention until they are eligible for disposal
• maintaining records within electronic document and records management systems or business systems until they are eligible for disposal
• making appropriate arrangements for the authorised destruction of the time-expired records, or
• transferring inactive records to State Records if the records are required as State archives.

Stage 4. Manage access

Two types of access arrangements need to be put in place:

• organisational access to records no longer in their control
• public access under provisions in the State Records Act 1998.  

Organisational access

Both the transferring organisation and the receiving organisation may have need in the future to access records of the function that are under the control of the other organisation. Agree and document arrangements for access. This should include:

• access by the transferring organisation to records it created and transferred
• access by the receiving organisation to records retained by the transferring organisation.

Arrangements for access to records in secondary storage or in the custody of State Records should also be documented.

Note: Access by another organisation to records in the custody of State Records would normally require the written permission of the organisation with control of the records. State Records would also normally require organisations other than the one with control, i.e. 'third party organisations', to view records in State Records' control in one of the State Records reading rooms. 

Public access

The State Records Act 1998 requires organisations to make access directions for records over thirty years old. The receiving organisation should make sure all records being transferred, regardless of age, are covered by an access direction. This will ensure that most records will continue to be publicly available after thirty years and that sensitive records will be appropriately protected. Records less than thirty years old can also be authorised for early public access.

If the receiving organisation does not already have access directions that appropriately cover the records, new directions will need to be made (see Recordkeeping in brief 21 Making access directions). The transferring organisation should advise the receiving organisation on existing access directions or the content of the records to help determine appropriate access directions. The receiving organisation may also wish to review access directions made by the transferring organisation.

Organisations that have made access directions, and records covered by access directions, are listed in the register of access directions available on State Records' website.

Stage 5. Manage the transfer of records

Listing records

The transferring organisation should list the records to be transferred. The list should include details of any records in current or semi-current storage, in any format, or any records that have been transferred to State Records as State archives. This list can be generated through the report-writing function of electronic records management systems or through other software if used. The transferring organisation should provide a copy of the list to the receiving organisation and also retain a copy for their own accountability needs. The receiving organisation should check records received against the list provided. 

Moving records

If the records are to be moved, paper files should be packed securely in labelled boxes and arrangements made with the receiving agency for their relocation. (See Recordkeeping in brief 15 Records in transit)

Arrangements must also be made for the transfer of digital records. This will involve the transfer of control of data and the associated metadata, it may also involve the transfer of software and/or hardware. The transferring organisation's staff should liaise with their own IT department and that of the receiving organisation to agree media and format and any other requirements for transfer.

Stage 6. Notify State Records

If any of the records being transferred have been registered in State Records' control system, the transferring organisation should notify State Records of the transfer of records. Also notify State Records if the records are over 25 years old and are covered by a 'still in use' determination or a distributed management agreement.

The receiving organisation should check with State Records whether any of the records are in the control and custody of State Records as archives, or in the custody of State Records through the provision of secondary storage in the Government Records Repository.

If you are uncertain whether the records are registered with State Records or covered by any directions or agreements, check with State Records.

Stage 7. Amend records management tools

A vital element of transferring responsibility for records is amending records management tools. 

Updating control records

Control records are used as tools to manage records. They are records in themselves and are used in both paper and electronic records management systems. Examples of control records include thesauri, file registers, indexes.

The transferring organisation should amend control records to indicate that responsibility for the management of the records has been transferred to the receiving organisation. Include the

• details of records transferred
• date of transfer, and
• details of the organisation to which they were transferred.

Provide a copy of the control records to the receiving organisation, either through the export of appropriate metadata from records management software or the physical copying of paper records.

It is important that the history of the records can be reconstructed. Identify transferred records in the receiving organisation's records management system and tools as transferred and note the details of the transferring organisation. They should not generally be re-titled, re-numbered or re-ordered. Link the transferred records to those created subsequently by the receiving organisation through the records management system and tools. Approved electronic records management software is able to support this (see Recordkeeping in brief 2 Selecting Records Management Software). 

Business classification scheme

A business classification scheme is a representation of an organisation's functions, activities and transactions.

The transferring organisation may provide the receiving organisation with copies of the development documentation for their business classification scheme. This will be useful in integrating the function into the receiving organisation’s own business classification scheme and, where necessary, developing thesaurus terms and functional retention and disposal authorities. 

Thesaurus

A thesaurus is a controlled list of terms linked together by hierarchical, associative or equivalence relationships. (AS ISO 15489.2, 4.2.3.2). A keyword thesaurus is a records management thesaurus where records are grouped into broad, functionally based areas represented by keywords. Records are further classified by the use of activity descriptors and optional subject descriptors.

The transferring organisation may need to revise its thesaurus following the transfer of a function as certain terms may no longer be valid. Redundant terms should not be deleted from the thesaurus. Instead change the terms to ‘non-preferred’ and indicate the end date.

The receiving organisation may need to integrate thesaurus terms for transferred functions into its own thesaurus. 

Retention and disposal authorities

A retention and disposal authority is a formal instrument that identifies records, defines how long they should be kept and when they should be destroyed or retained as State archives. In NSW, the destruction of State records is authorised through both general and functional retention and disposal authorities. General retention and disposal authorities (GAs) are developed by State Records for the disposal of common administrative records. Functional retention and disposal authorities (FAs) are developed by public offices and cover records of their core business functions.

The transferring organisation should provide the receiving organisation with copies of any functional authorities which relate to the records being transferred. The receiving organisation will have its own copies of the general authorities.

When functions move between branches or units within a specified public office, the functional authority does not have to be resubmitted to State Records. However, when functions move from one public office to another, State Records should be notified as the receiving organisation may need the approval of State Records to use the functional authority.

Where no functional retention and disposal authority exists, the receiving organisation must develop an authority and submit this for approval to State Records prior to any disposal of records taking place. Note: general retention and disposal authorities may, of course, continue to be used as appropriate.

When a function is transferred to another government

Overview

The transfer of functions can occur between different governments, for example between the Commonwealth Government and the New South Wales Government. Appropriate arrangements for the management of records following the transfer of functions will need to be made. Such arrangements will be affected, in general, by the fact that the ownership of State records must not be transferred from the NSW government to another government without the authorisation of State Records.

Principles

NSW public offices which are responsible for a function that is to be transferred to another government should contact State Records to discuss the management of the affected records.

There are a number of principles that apply to records of transferred functions. These are:

• the transferring organisation should close records of completed transactions
• the transferring organisation should close records of current transactions at or before the date the function is transferred
• the receiving organisation will need records of current transactions to ensure the efficient administration of the function.

To meet the need for records of current transactions, the transferring organisation may:

• loan the records to the receiving organisation for a specific period
• copy the records or data about the records (metadata) and supply copies to the receiving organisation.

When a new function is created

Overview

When a new function is created, the public office will need to update its records management tools to reflect this.

Process

Updating records management tools includes:

• updating control records
• updating the business classification scheme
• reviewing your thesaurus, and
• developing a functional retention and disposal authority

to incorporate the new function.

See Stage 7 Amend records management tools in the section 'When a function is transferred between NSW public offices' for more details.

When an existing function is abolished

Overview

When a function is abolished, the public office will need to retain the records but amend its records management tools to make it clear that no new records are to be created for this function.

Process

Review records against general and functional retention and disposal authorities to see whether they can be transferred to secondary storage or to State Records if the records are required as State archives.

This process also includes:

• updating control records
• revising your business classification scheme
• revising your functional retention and disposal authority, and
• revising the thesaurus

to indicate that functions and terms are no longer in use. Do not delete entries, revise to show the end date.

See Stage 7 Amend records management tools in the section 'When a function is transferred between NSW public offices' for more details.

Amalgamation of public offices into larger organisations/entities

Overview

When two or more public offices are amalgamated into larger entities, there may be a number of ramifications for records management and recordkeeping. Amalgamations may be complex or relatively straightforward depending on the timing and degree of:

• integration of functions and staff
• co-location or moving of staff and resources (such as services and records)
• integration of ICT infrastructure
• integration of information resources.

In some cases changes may be minimal e.g. where several organisations are merged into a ‘super-organisation’ but retain their own operational systems, software and personnel or adopt ‘shared service’ arrangements. In this case many of the steps below will not be relevant. See the section ‘Shared service arrangements’ for more information.

The changes to records management and recordkeeping can be significant when there are different systems, software and personnel that need to be integrated. A change of site may also have implications for managing records e.g. the availability of secondary storage or accessibility of recordkeeping expertise.

How to manage records when organisations amalgamate

The table below summaries the four main stages in managing records when public offices amalgamate their recordkeeping and records management systems. Further detail on each stage is provided after the table.

Stage 1: Preparation

Preparation involves forming a steering group consisting of key information and records management positions from across the merging organisations to plan for and carry out the necessary actions. This steering group should report to relevant high level committees established to oversee all aspects of the amalgamation so they remain informed of recordkeeping issues and progress.

The steering group for records management will need to identify the following in the preparatory stages:

• all business communications and recordkeeping systems in the organisations who are merging, including financial management systems, human resource management systems, electronic document and records management systems, customised designed business systems and unofficial recordkeeping systems
• the different hardware and software platforms in each organisation
• key staff with records management responsibilities or with knowledge of different systems
• all contracts and service level agreements for the supply of records management services
• all licensing agreements or arrangements for software applications or records management products and tools
• all recordkeeping tools covering the records of merging entities such as thesauri and functional retention and disposal authorities
• the location of all records storage areas including in-house and commercial facilities
• records transferred as archives to State Records and all access directions in place
• current corporate recordkeeping policies, procedures and rules, including security and access requirements, which apply to each of the merging agencies.

Preparation should also involve allocating relevant staff to: 

• ensure that any current files that are no longer in use are closed
• dispose of records that can be destroyed or transferred as State archives under current general and functional retention and disposal authorities.

These actions will help to reduce the volume of records that need to be managed during the changeover. See relevant steps within ‘How to transfer control of records’ for more information. If such activities constitute a major project they may be best addressed in longer term plans.

Stage 2: Planning for integration

If time permits, careful and systematic planning can streamline the process of change to records management and recordkeeping. If there is little warning before amalgamations occur, it may be advantageous to identify a lead partner to conduct most of the planning or deciding whose systems can become the basis for new recordkeeping systems. Issues to consider in planning include:

• which records management control system, e.g. EDRMS, to use 
• what records management model should be adopted 
• what file numbering should be used
• what file titling practices will be adopted
• how records management and business systems will be integrated
• which business systems across the merging organisations keep records
• what work needs to be done and who needs to do it
• change management initiatives required to help with staff transition
• whether storage contracts will be transferred to the new entity and any relocation of records required
• who will require access to what information resources when the organisations merge and how access will be provided 
• how work processes will change and the effects on recordkeeping requirements
• how recordkeeping and information management processes can be streamlined.

Further information about these issues is provided in the ‘Decisions to be made’ section below. Many decisions will require agreement and sign off by the high level committees of the merging agencies.

Decisions to be made

Decide which records management control system to use

Requirements for a system

The entity formed by the amalgamation is likely to require records management software to handle the volume of records created. The decision about what system to use should be based on an analysis of the requirements for the system.

An existing system

One or more of the merging organisations may already have records management software. Evaluate whether the existing system/s in use can meet the requirements you have identified, at least in the short term. If one or more of the organisations are using a product from the whole of Government contract 2602, Government Selected Application Systems, Information Asset Management Systems, it is sensible to use this for the new system. This way there will be continuity as at least some of the staff will be familiar with its operation and will be able to assist the others. If both organisations have different products from the GSAS contract, work out which one will best suit the needs of the amalgamated organisation.

If an existing system is used then the system functionality should clearly distinguish the records and files created by the new merged organisation. It should be documented clearly that ownership of the new system has been transferred to the newly formed organisation.

A new system

If records management software is not being used or does not meet the new organisation’s needs, consider choosing a product from the whole of government contract 2602, Government Selected Application Systems, Information Asset Management Systems. Details of the products and contact details for vendors are in Recordkeeping in brief 2 Selecting records management software.

Note: State Records recommends that councils purchase products from the IAMS contract although it is not mandatory for them. This is because the products on the panel contract have been assessed against rigorous criteria and provide the recordkeeping functionality required to manage records.

For more information see Recordkeeping in brief 2 Selecting records management software.

Decide on a new records management model

When an amalgamation occurs, previous records management models may no longer effectively support the newly merged organisation or its program objectives. Organisations should give consideration to what records management model would be the most suitable to adopt. See Recordkeeping in brief 41 Organisation of a records management program for more information.

Decide on titling practices

It is important to establish good file titling practices for the newly merged organisation. The Australian Standard AS ISO15489 recommends that keyword classification be used. A thesaurus or controlled language tool based on keyword classification may assist. For example, if two councils are merging and both are using State Records’ product Keyword for Councils the licence can usually be extended to the amalgamated council. Please contact State Records about this.

Likewise some or all of the agencies merging to form a larger agency may have licences for State Records’ product Keyword AAA and you may wish to extend this to apply to the merged organisation. Please contact State Records regarding licensing arrangements. A separate project may be required to develop thesauri to cover the functions of the newly merged organisation.

If file creation is decentralised to users the new organisation will need to provide some training and support to users not familiar with titling tools.

Decide on file numbering practices

It is important that file numbers are not duplicated, even between what may be different sites of the same organisation. State Records recommends the use of annual/running numbers for files e.g. 04/001, 04/002, 04/003. If you want to use annual/running numbers but plan to use different systems at different sites you may need to add an alpha prefix to the file numbers e.g. A04/8620. B04/5260 or implement some other means to ensure that each file number is unique.

Decide on how systems will be integrated

Careful consideration needs to be given to how systems will be integrated. See Stage 3: 'Managing the transition' for more information about how records management systems and business systems might be unified.

Decide on work required, priorities and allocating responsibilities

Detailed work plans need to be developed for the actual work required to bring about a smooth transition. Separate plans may be required for particular projects such as closing old files, relocating records from one site to another or training staff in new systems. Staff will need to be allocated to particular projects and tasks.

Decide on change management initiatives

New recordkeeping practices and systems may only be some of the changes staff are required to deal with during amalgamations. Staff will need to be kept well informed of their new responsibilities and these will need to be documented in new policies, position descriptions etc. Consider and plan for what change management initiatives such as training and support are required for staff and what documented guidance they require.

Decide on changes to storage

The steering group will need to decide whether storage contracts and services being used by the amalgamating organisations need to be transferred to the new entity. They will also need to consider whether any records require relocation. For more information on good practice when moving records, see Recordkeeping in brief 15 Records in transit.

Decide on access requirements

You will need to carefully consider who will require access to what information resources when the organisations merge, and how that access will be provided.

Consideration should not only be given to active records. Staff of the newly merged organisation will often need to access closed files to support their business activities. Plan to import control information for the files that are closed into the new records control system to enable cross searching. The system functionality can be used to show that the files are closed and belonged to a particular predecessor organisation.

Decide on changes to work processes

An amalgamation necessarily involves some changes to work processes or the introduction of new processes to meet business objectives. It is important that when work processes are being designed or redesigned that recordkeeping requirements are considered so that full and accurate records of the process can be captured and kept.

The potential for streamlining information and recordkeeping processes can also be considered.

For more information, consult Strategies for documenting government business: The DIRKS Manual, particularly Step B: Analysis of business activity and Step C: Identification of recordkeeping requirements.

Stage 3: Management of the changeover

Managing the changeover involves implementing the plans and projects described in Stage 2. Processes for achieving a unified records management system and managing records in business systems are described below.

Achieving a unified records management system

The two basic options for achieving a unified records management system are:

• close all files and open new ones – the ‘Big Bang’ approach
• run parallel systems for a time.

Whatever approach is taken to managing the actual changeover, be aware that users will require continuing assistance and support.

The ‘Big bang’ approach

When the new merged organisation begins operation, State Records recommends that, where feasible, the defunct organisations close their files and the new organisation opens new files for its ongoing business activities. Use the records control system to make any links between closed files and new files.

Operating parallel systems

The ‘Big bang’ approach can be resource intensive. If it is not possible to close all files and create new ones, an alternative approach is as follows:

Note: Be aware that this process may create confusion for users as there will be parallel systems in place for a time.

Achieving unified records in business systems

Some important records are managed outside of general records management systems. Personnel and financial records are two common examples. Many of the decisions about managing the transition of these business systems will be taken outside of the records management unit and it is important that recordkeeping issues are addressed during the transition.

Working with business managers

If business systems are to be closed or integrated, make sure that:

• changes to the business systems are clearly documented and records of these changes are captured in an official recordkeeping system
• data from closed systems is copied to the new systems as required
• records in closed systems are sentenced using current retention and disposal authorities and the accessibility of data in these systems is maintained as long as is required. For more information see State Records’ guidelines Managing digital records
• the recordkeeping requirements of new systems are assessed and the necessary functionality to capture and maintain records is either built in or there is an interface with the records management system e.g. monthly/quarterly financial reports are printed and filed.

Managing personnel records

By managing personnel records effectively the rights and entitlements of staff are protected over time. This enables the newly merged organisation to have a clear idea of its ongoing employee-related liabilities. You need to:

• make sure personnel records are transferred to the new organisation. This includes personnel files, payroll and superannuation deductions
• close personnel files and start new ones for the new organisation (ensuring that new and old files are linked in the control system)
• make sure that no personal staff identification numbers are duplicated. If new personnel or payroll numbers are assigned to staff make sure these are clearly documented. Unique personnel or payroll numbers are good tools to link all related records together and can be used as retrieval tools
• add summary information about the service of the staff member to the new file to protect their rights and entitlements. Do not remove records from the closed file. If summary records already exist, copy these and add them to the new file
• use the new organisation’s control system to link the new file to the old file
• close existing payroll systems. Data from the systems should be copied to the new system as needed.

Managing financial records

It makes it easier if the amalgamation of organisations coincides with a new financial year but this is not always the case. Organisations may decide to continue running parallel financial systems until the new financial year. Use the records management system to document on what date the new organisation becomes a legal entity. As with personnel systems:

• copy data from one system to the new system
• close files of input and output records, e.g. invoices, purchase orders, financial reports, and create new ones for the new organisation.

Stage 4: Future planning

Once the initial transition has been completed, planning is required for the ongoing management of the new entity’s records management program. This includes:

• developing a new records management policy and business rules for the organisation
• creating new functional retention and disposal authorities (if required)
• identifying and making provision for the protection of its vital records
• developing a disaster plan covering all records and recordkeeping systems
• developing or reviewing access and security schemes
• developing records management skills
• training staff in good recordkeeping practice according to their roles and responsibilities
• establishing new monitoring and review systems
• notifying State Records of mergers or changes.

Shared service arrangements

Some public offices may be moving to ‘shared service’ arrangements for the efficient and effective delivery of a number of services. Shared service arrangements generally involve a degree of standardisation to allow groups of organisations to use common technical platforms, systems and processes.

In records management, common models for shared services are:

• sharing records management services amongst a group of public offices, such as geographically co-located or functionally similar organisations, or with a 'parent' organisation, or 
• using a third party provider of services such as the Department of Commerce's ServiceFirst or NSW Businesslink.

For information about using shared service arrangements for amalgamated organisations, see Recordkeeping in brief 44 Using shared services for records management.

Acknowledgements

The following publications have been referenced:

State Records of South Australia. Managing Records Through Administrative Change. Draft v1.3. February 2002

National Archives of Australia. Handling Administrative Change. Archives Advice 27. Rev. June 2002.

National Archives of Australia. Developing a Functions Thesaurus: Guidelines for Commonwealth Agencies. 2000

Council of Federal, State and Territory Archives. Disposition of records following administrative change. Policy Statement 5. July 1999

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