ADAPTING THE DISPOSAL SCHEDULE FOR COMMON ADMINISTRATIVE FUNCTIONS

GUIDELINE 9:
Adapting the Disposal Schedule for Common Administrative Functions

CONTENTS

Adapting the Disposal Schedule for use in your country                                                       

Decide roles and responsibilities                                                                                        

Research the functions of your government or your organisation                                     

Check the language and descriptions are relevant                                                            

Finalise the Disposal Schedule                                                                                            

Obtain agreement and final approval for the Disposal Schedule                                     

Adapting the disposal schedule for use in your country

This document provides guidance for adapting Guideline 7: Disposal Schedule for Common Administrative Functions.

The Disposal Schedule for Common Administrative Functions is a model Disposal Schedule and it must be adapted for your own country’s legal, administrative and cultural requirements before it can be applied to inactive records.

The Disposal Schedule can be adapted for use across a country, state or territory or for use within a Department or Ministry. This is a decision you must make before beginning the adaptation of the schedule, as it will affect how you go about adapting it.

If the model Disposal Schedule is adapted for use across all government Departments or Ministries, then there will be one Disposal Schedule for all the administrative records of government. The advantage of this approach is that retention periods will be standardised across the country and there will be consistency of approach to retention and disposal.

If the Disposal Schedule is adapted for use within a Department or Ministry, then it will only apply to the records of that Department or Ministry, and should not be used for the records of any other Department or Ministry without being adapted first. The advantage of this approach is that the Disposal Schedule’s language, records descriptions and examples can be more extensively adapted for use within a single Department or Ministry.

Steps for adapting the Disposal Schedule

To adapt the Disposal Schedule for use in your country (either across or within government organisations) you must undertake the steps that are listed below. (Steps to implement the Disposal Schedule once you have adapted it are discussed later in this document).

1.      Decide roles and responsibilities:

2.      Research the records created and maintained by your government or organisation

3.      Use what you have learned about the records and with the model Disposal Schedule as a basis, make the following adaptations:

4.      Finalise the Disposal Schedule and add introductory notes, implementation guidance, etc

5.      Obtain agreement and final approval for the Disposal Schedule.

Decide roles and responsibilities

(a) Who adapts the disposal schedule?

A whole of government Administrative Disposal Schedule

If your country has a National Archives or similar institution, then it is suggested that this organisation manages the adaptation of the model Disposal Schedule across the whole of government and thereafter maintains it on behalf of the government.

A single organisation Administrative Disposal Schedule

The Records or Information Management Officer or similar position should be responsible for managing the adaptation and maintaining it on behalf of the organisation.

(b) Who Agrees to the Disposal Schedule?

This agreement ensures that the Disposal Schedule has been appropriately authorised for use in your government or organisation. A decision on who will agree to the Disposal Schedule is a key issue and should perhaps be the first issue you decide on before you make changes to the rest of the Disposal Schedule

A whole of government Administrative Disposal Schedule

In each of your countries the decision about which senior position agrees to a whole of government Disposal Schedule will be different. It is important that the position that signs it off has authority over recordkeeping and/or archival matters in Government. Some suggestions for sign off are:

·       The Chief Archivist or National Archivist [which will combine steps (b) and (c)];

·       The Minister responsible for the National Archives;

·       The Minister responsible for the Public Service Commission; or

·       Cabinet.

A single organisation Administrative Disposal Schedule

For a single organisation Disposal Schedule, it is suggested that the Chief Executive or Head of the Department or Ministry approves the Disposal Schedule. This signals that the Disposal Schedule has been viewed and agreed by Senior Management.

(C) Final approval of the Disposal Schedule

If your country, state or territory has a National Archives, or similar, and archives legislation, then there will be provision for the National Archivist or Chief Archivist to give final approval to Disposal Schedules. This is to ensure that the National Archives agrees with the recommended disposal actions and retention periods. This approval is in addition to any other approval already given to the Disposal Schedule.

A whole of government Administrative Disposal Schedule 

If a whole of Government Disposal Schedule has been developed and it has been agreed to by any position other than the National Archivist/Chief Archivist, then their approval must also be sought. The National Archives will have a standard process for approving disposals that can be followed.

A single organisation Administrative Disposal Schedule

Once the Disposal Schedule has been agreed to internally by a representative of Senior Management, then it must be approved by the National Archivist/Chief Archivist. The National Archives will have a standard process for approving disposals that can be followed

Research the functions of your government or your organisation

Before you can adapt the Disposal Schedule you must have some knowledge about the records that are created so that you will know which parts of the model Disposal Schedule to adapt.

If you are adapting and using the Record Plan so as to create new filing systems in your government or organisation, the information you gather as you develop the filing system can be used to help you adapt the Disposal Schedule as well. As you create the new files you will be adapting the language and adding to the descriptions and examples of the Record Plan and you can do the same with the Disposal Schedule.

You do not have to be using the Record Plan for your filing systems before you can use the Disposal Schedule. The Disposal Schedule can be applied to records in any filing system and even to records that have not been organised into a filing system.

Other ways of learning about the records that your government or organisation creates are:

1.      Reading existing file or record plans and lists of records

2.      Reading lists of records already deposited as archives in your National Archives

3.      Reading existing disposal schedules

4.      Creating an inventory of existing records if there are no file lists

5.      Looking at the records themselves once you have read the list (because sometimes poor file titles mean that you cannot tell what is in a file by looking at a list)

6.      Talking to the people who create and use the records – you may wish to create a working group within your organisation or across government to provide information and feedback for the adaptation of the Disposal Schedule.

Check the language and descriptions are relevant

(A) Adapt the language of the Disposal Schedule

Because the Disposal Schedule has been developed by people from many different countries, it may use words to describe some parts of the government’s business that are different to the way you would describe them in your country.

One example is under the heading Financial Management – Budgeting. In some countries, the documents Ministries use to ask the government for extra money as part of the budget process are called New Policy Proposals, while other countries might call these same documents New Spending Proposals. In other places they might just be called Budget Bids.

You should try to adapt the Disposal Schedule so that it uses words that officers in your government will understand. If staff do not understand the descriptions in the Disposal Schedule they might not be able to apply it to their records or they could apply the wrong disposal action to their records.

You can also make changes to the words you use in the headings in the Disposal Schedule. For example, the Disposal Schedule uses the heading Personnel and Establishment. There are, however, many different ways of describing the way governments manage their staff. In your country you may prefer to call this section something else, such as:

• Staff Management;

• Human Resources Management; or

• People and Structures.

The golden rule is to make sure that you use words that the people who use your Disposal Schedule are able to understand what each heading means, and that they won’t be confused about which heading they should use to decide the disposal of their records.

(B) Add to the descriptions and examples so they are relevant

The descriptions and examples are in the Disposal Schedule to help people determine which is the right disposal class for their records. Adding to the description and adding types of records to the examples as you adapt the Disposal Schedule will help people recognise their own records in the Disposal Schedule.

For example, under the heading Financial Management there is an activity Accounting. There are several examples listed already, but if your organisation or government has particular forms that are accounting forms and would be covered by this disposal class, you can enter the form names or numbers into the examples.

You may also decide that some examples are not relevant to your organisation or government and remove these from the Disposal Schedule so as to avoid confusion.

(C) Adapt and add retention periods

The Retention Period is the minimum period of time the record should be kept after it is inactive and before its disposal. It is entered into column 6 in the Disposal Schedule. Normally disposal actions are not applied immediately after the records become inactive because there may be a business need to refer back to them for a period of time.

The Disposal Schedule provides a recommended minimum retention period for records where the disposal action is DESTROY. This means that when you adapt the Disposal Schedule for your own country or organisation, the Disposal Schedule suggests the least amount of time you should keep the record for. You can decide to keep the record for longer (but ultimately the disposal action is still DESTROY).

For financial records it is suggested that your country’s legislation is checked before deciding a retention period, although a 7 – 10 year period is recommended as a guide. This is because most countries will have some legislation that sets time periods for the retention of financial records. For example, in New Zealand , the Tax Administration Act 1994 says that certain financial records must be kept for 7 years.

When you adapt the model Disposal Schedule, it is important that you review your country’s legislation so that the retention periods you decide are in line with legislation. If your legislation states a specific retention period for certain kinds of records, you should use that time period instead of the recommended retention period in the model Disposal Schedule.

The Disposal Schedule does not recommend minimum retention periods for records where the disposal action is ARCHIVE, as the National Archives or similar body in each country will have its own rules about the transfer of records to its custody.

The steps to finalising retention periods are:

·       Reviewing your country’s legislation to see if it specifies that certain records have to be retained for a certain period of time.

·       Reviewing your specific archives or public records legislation or the rules or regulations of your National Archives body (if there is one) to see when records of archival value should be transferred to them. (Some countries will have rules about how long organisations must keep records before they can be transferred to Archives institutions).

·       Reviewing your organisation’s internal rules about retaining records. These may be based on legislation, but they may also reveal a business reason for retention periods.

If there is no legislative or other specified requirement for the retention of some records, then you must find out the business need to refer back to the record over time, once it is inactive. This means the time period over which people will access the record for reference purposes, once they are no longer adding information to it.

To discover the business need you must understand the records and what they are used for. It is also useful to consult with the people who use the records. You must weigh up the information you gain from the users with what you know about the records and what they are used for.

When consulting with users on retention periods it is helpful to offer them standard periods of time, rather than simply asking them – “How long do you need to keep the record after it is no longer active?” Giving them a choice of time periods – for example “Two years, or up to seven years?” – helps them think more easily about their need to use the record over time. Use the recommended minimum retention periods in the model Disposal Schedule as a guide.

Retention periods can be separated broadly into two types:

·       Short term business need

·       Medium term business need

Often the medium term retention need can be confused with archival (permanent) value because sometimes it can be a very long period of time. For example, if information about maintaining an item of machinery must be retained for the life of the machine, that may be as long as 40 or 50 years. This does not mean that the information is of permanent value – it just has to be kept for a long time.

This table lists some standard retention periods and when they would apply.

(D) Add definitions where needed for ‘major’ and ‘minor’ activities

In parts of the model Disposal Schedule some activities are divided into activities around major and minor events or transactions. For example under the Financial Management function heading, the activity of banking is divided into Banking – management, Banking – major loans and Banking – minor loans. This is because there are different disposal actions for the records of major loans (Archive) and minor loans (Destroy).

In the Disposal Schedule, it states that major loans are loans over a certain amount, to be decided by the country. This is because the working group decided that it was important to keep the records of major loans as archival records but recognised that each country might have a different definition of what is a major loan.

In the same way, under the External Relations function heading, the activity Ceremonies, Events and Visits is divided into major and minor ceremonies events and visits. Again, this is because the working group decided that it was important to keep the records of major ceremonies, events and visits, but not the records of minor ones.

When you are adapting the Disposal Schedule for your country or organisation, you will have to decide what the criteria are for ‘major’ and ‘minor’, so that you can make that clear in the guidelines for your adapted Disposal Schedule.

The table below lists the disposal classes where divisions between minor and major have been made and makes some suggestions for deciding the criteria.

(E) Add specific descriptions of when a record is inactive

In the model Disposal Schedule often the retention period is described as
‘X years after the record becomes inactive’.

Inactive means that information is no longer being added to the record. This effectively means that a record is closed but it may still be accessed for reference purposes.

Another word often used for inactive is ‘closed’ or ‘non-current’, which can be used to mean the same as inactive.

When you are adapting the model Disposal Schedule it will be useful to have more specific descriptions of when records become inactive, so as to help the process of implementing the schedule. For example, in the model Disposal Schedule, some retention periods are quite specific – class DS5/10.1 states that the retention period is ‘6 months after the position is filled’.

There are triggers that tell you when a record is inactive and most of them relate to a time when an activity is completed. Potential trigger points for records to become inactive will depend upon the activities and transactions they record. The users of the records may be able to tell you when they stop adding information to a record

Some typical trigger points for the change in status are:

·       Project completed

·       End of financial year

·       Policy approved/signed off

·       End of calendar year

·       End of specified period of time for which the record had to be added to

·       Property or car is sold, or lease expires and is not renewed

·       Building is demolished

·       Contract expires and is not renewed

·       License expires and is not renewed

·       Litigation case is heard, a judgement is made and the appeal period is over

·       Employee has left employment

·       Vacancy is filled

In the case of policy or correspondence subject files, where parts/volumes are simply added as work continues, it is acceptable to determine that a physical part/volume becomes inactive when it is full and has been closed. It is also acceptable to apply retention and disposal to earlier closed parts/volumes of a still active record.

The general rule to remember is that records are developed to record activities, processes, or transactions and therefore they become inactive when that activity, process or transaction ceases, or at a specific time determined by the activity or process.

If you can identify specific trigger points for when records become inactive you should alter the relevant retention period statement so that it is specific, so that instead of saying ‘X years after the record becomes inactive’, it says, for example ‘X years after the project is completed’.

Finalise the disposal schedule

You can use a copy of the existing model Disposal Schedule as the basis for your own Disposal Schedule, and adapt and add in retention periods to create a final Disposal Schedule for your government or organisation.

The final Disposal Schedule should also include introductory or explanatory notes about the Disposal Schedule, and you can base these on the introductory notes for the model Disposal Schedule.

It is also useful to include implementation guidance and any specific instructions for sentencing and disposal in the final Disposal Schedule document. You can use the Implementation Guidelines in this document as a basis, but you will have to add in any instructions that are specific to your country.

Obtain agreement and final approval for the disposal schedule

Once you have adapted the model Disposal Schedule and added the retention periods, you will need to get agreement that the Disposal Schedule meets the requirements of your organisation or government.

If you have been working with a working group, then you should ask the working group to provide feedback and then sign-off that the Disposal Schedule has been agreed.

Then you must get agreement from the position you have determined is the appropriate position to agree to the final schedule. It is useful to add the authorisation into the final Disposal Schedule document, perhaps as a covering page or as part of the introduction to the schedule. An example of a model cover page follows.

Once you have agreement to the final Disposal Schedule, you need to follow the process set down by your country’s National Archives, or similar body, for getting final approval for the schedule from the Chief or National Archivist.

This Guideline of the Recordkeeping for Good Governance Toolkit was produced by the Pacific Regional Branch of the International Council on Archives with assistance from Archives New Zealand and NZAID.