The regular monitoring of records, recordkeeping and records and information management is beneficial for all public sector organisations.  

Beyond a mere assessment of conformity with requirements (compliance), monitoring can actively assist public offices to:

  • embed good practices and processes
  • identify maturity in records and information management which can be used to support records management initiatives across the organisation
  • identify efficiencies in managing records
  • identify and manage information risks, and
  • understand the business benefits and value in investing in the quality of information assets.

Monitoring supports the organisation’s capacity to use records, information and data for decision-making, policy development and the delivery of high-quality public services and ensures that records are accurate, authentic and trustworthy evidence of the business of Government.

Monitoring of records and information governance programs is a shared responsibility between State Records NSW and public offices. The State Records Act 1998 places a number of requirements on public offices regarding monitoring activities. 

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Regulatory Framework

The State Records Act 1998 establishes State Records NSW as the regulator of records management and recordkeeping within NSW public offices.

The State Records Act provides State Records NSW with regulatory powers and enables us to issue formal requirements (e.g. standards, codes of best practice, retention and disposal authorities) and to provide records management services (e.g. guidance, and training) to assist and support public offices in their compliance with the Act.

The Regulatory Framework describes our approach to regulating records management, and how we intend to use the powers in the State Records Act 1998 to support our regulatory activities. It replaces the Monitoring Framework (2004) and is applicable to all public offices.

The Framework will be reviewed in 2024.

Browse the Regulatory Framework online or access the print version (PDF, 476kb).


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Public Offices' role in monitoring records management

Public offices should regularly monitor the management of records within the organisation to ensure the effectiveness and efficiency of recordkeeping systems and processes, and conformity with the State Records Act 1998 and associated standards and codes of best practice. Generally, public offices undertake two types of monitoring activities to understand how the organisation is performing and to identify those areas which require further attention. The two types of monitoring activities are performance monitoring and compliance monitoring.

Performance monitoring

Performance monitoring involves an in-depth analysis of a process or project, to determine whether it is efficient and effective. It involves developing criteria, conducting interviews and examining documentation to determine how the process or project is conducted. This type of monitoring is also referred to as a process audit (CB029 - 2003, The Audit Skills Handbook, section 1.8).

Public offices typically measure performance to determine if a process or practice is effective and whether objectives or targets are being met, and thus satisfactory performance. Measuring performance allows the organisation to not just measure whether an outcome is being achieved, but how well or the degree of satisfaction of the outcome; in this way it is a 'qualitative' form of measurement.

Public offices should regularly assess the effectiveness and efficiency of their recordkeeping systems and processes to ensure that they are satisfactory and meeting the public office's business needs.

Performance monitoring activities can range from monitoring:

  • overall performance of the organisation's records management program
  • recordkeeping
  • records management processes
  • records management systems, and
  • assessing the records management capability of the organisation.

Performance monitoring can also include targeted assessments of recordkeeping, for example assessing high risk business areas to ensure that records are being created and captured, and that records are adequate (i.e. are the records being created and captured adequate for providing evidence of the business of the organisation?).

The starting point for some performance monitoring activities may be the identification of a business issue/problem. The organisation can analyse the problem using the relevant tool and develop a solution which may involve updating processes or developing new processes.

Organisations can monitor their performance by:

  • conducting assessments using the plans, goals and objectives of the records management program
  • assessing feedback from clients of the services provided by the records management program
  • benchmarking against standards such as AS/ISO 15489.1:2017 and standards issued by State Records NSW
  • assessing the level of understanding and use of records management policies and procedures by staff
  • conducting an internal audit of recordkeeping and/or management of records
  • using the Records Management Assessment Tool, and
  • conducting detailed reviews of high risk business areas to confirm that records are being created and captured into the recordkeeping system.

Public offices may also seek independent or external performance monitoring of their organisation's recordkeeping and management of records, for example, auditors can undertake both performance and compliance monitoring.

Compliance monitoring

Compliance is defined as 'adhering to the requirements of laws, industry and organizational standards and codes, principles of good governance and accepted community and ethical standards'. (AS 3806 - 2006: Compliance Programs, section 1.3.3)

Compliance monitoring and compliance auditing aim to establish whether a process or procedure is carried out in conformance with relevant external requirements, whether set through legislation, regulations or directions. It involves examining, at a fairly straightforward level, how organisations 'do something' and confirming 'compliance' with criteria. (CB029 - 2003, The Audit Skills Handbook, section 1.8)

Public offices should regularly assess their conformity with the obligations of the State Records Act and the associated standards and codes of best practice to ensure that the organisation is compliant and that issues of non-compliance are corrected.

Compliance monitoring activities can range from:

  • assessing compliance with obligations in the State Records Act
  • assessing the records management program
  • assessing recordkeeping
  • assessing the management of records, and
  • assessing records management system and business systems that create and capture records.

Documenting compliance monitoring activities is an important component in demonstrating the public office's compliance with the State Records Act 1998 and associated standards and codes of best practice. Public offices may be asked about their monitoring activities by other organisations with an interest in good records management (e.g. ICAC, the Information and Privacy Commission, or the NSW Ombudsman) or when responding to follow up on a recordkeeping issue by State Records NSW.

Public offices can monitor their compliance by:

  • using the Records Management Assessment Tool
  • assessing compliance against the minimum compliance requirements in each standard issued by State Records NSW
  • benchmarking against previous Recordkeeping Monitoring Exercise results or audit results to assess improvements or to identify issues of non compliance
  • the State of recordkeeping in NSW, the report on the 2023 Recordkeeping Monitoring Exercise is now available
  • the Report on the 2022 Recordkeeping Monitoring Exercise is also available on our website
  • undertaking a compliance audit using internal auditors or an external party to provide an independent assessment of the organisation's records management program, practices and systems.

Public offices may consider using the services of a consultant, internal or external auditors to conduct compliance monitoring activities.

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Monitoring tools

There are a range of tools which public offices are able to access to assist in monitoring records management programs and recordkeeping performance.

Published January 2015 / Updated January 2019 / Updated July 2021 / Updated November 2022/Updated October 2023

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