For the Record October 2021

ISSN 1321-6260
October 2021 - 149

FAQs about the Records Management Assessment Tool (RMAT)

Attendees at our recent webinar on the RMAT raised a number of questions which we would like to share with other public offices. We will also be adding these to our RMAT FAQ webpage.

When will SARA be undertaking annual reporting using the RMAT?

As noted in the Regulatory Framework, SARA will re-commence annual reporting processes using the RMAT in the first half of 2022. Each public office will be asked to do an assessment of their records and information management at that point in time and provide a report to SARA. This reporting will give SARA an overview of the state of records management in NSW Government. SARA will contact each public office with further information about the monitoring activity in early 2022.

We appreciate that it’s been some time since SARA conducted a monitoring exercise, so we have tried to get the RMAT to you as soon as possible, to provide time for public offices to familiarise themselves with the RMAT and conduct assessments in order to gauge the current levels of recordkeeping and records management.

When and where will the results of the annual reporting be published?

We anticipate publishing the results of the annual reporting on our website and in our Annual Report in the first quarter of the 2022/2023 financial year. The reporting will be at an aggregate or summarised level (i.e. Sector/Cluster).

How should large and complex organisations undertake RMAT assessments?

We suggest that large and complex organisations consider undertaking individual assessments of divisions, lines of business, or groups of business units. These assessments are then brought together, and a consolidated view of the organisation’s records and information management is developed. Importantly, the consolidated view should be negotiated and agreed upon by those who have undertaken the assessments.

The individual assessments of divisions, lines of business, or business units will be useful in understanding the current state of recordkeeping within these areas of the organisation, as it will identify the gaps or issues, and this information can then be incorporated into the plans for corrective actions. This will also enable the organisation to track progress over time and ensure that recordkeeping issues are managed.

One of the organisations that pilot-tested the RMAT took this approach: The RMAT was provided to a number of different officers within their organisation. Those individuals went away and assessed from their perspective or lens on the organisation. Then they came together to discuss the individual responses to each question and settle on an overall score for each question. From the individual assessments, they could see where there’s good practice or areas that needed improvement.

How frequently should I use the RMAT?

SARA is not mandating how many times a year you should use the RMAT but it should be used regularly - the assessment shouldn’t just be a one-time or annual activity. We want to see public offices using the RMAT because it helps your business and assists your organisation to understand how recordkeeping is working or not working in your organisation.

How long does the assessment process take?

It will depend on the scope of the assessment (e.g. business unit, business system, whole of organisation) and the process you’ve decided to use (e.g. one person doing the assessment, a small team of information professionals from across the organisation, records and information management team with other key staff). It may take a couple of hours or a day to complete the assessment depending on the scope and process used.

We are a very new government organisation and don’t have any records that are 30 years old. How do we answer Question 19 about access directions?

Even if you don’t have records that are 30 years old, we encourage each organisation to consider making access directions. More information about making access directions is available on our website. When answering Question 19 in the RMAT, select the maturity level which best describes your current state.

If you have queries about the RMAT, the assessment process or the results of an assessment, please feel free to contact us on govrec@records.nsw.gov.au

Webinar: What is the RMAT?

Thank you to everyone who attended the recent webinar on the RMAT. The webinar has been recorded and is available from our website. The webinar provides an introduction to the RMAT and a virtual tour of the RMAT.

Check out Webinars & Forum Presentations on the website for recordings of webinars, mini webinars on retention and disposal authorities, and presentations from Records Managers Forums.

Recordkeeping Focus: COVID-19 vaccination certificates

Do public offices need to retain vaccination certificates?

No.

Many public offices need to sight proof of vaccination or exemption to comply with public health orders or internal business requirements. This could be from members of the public entering buildings, employees, contractors and service providers entering workplaces, and organisations or individuals who are licensed or accredited by the public office. Recent examples we have been asked about include members of the public on jury lists, family daycare operators who are approved to operate by Councils, employees returning to work, and members of the public entering buildings.

In most cases vaccination or exemption certificates need to be sighted but not retained. If for some reason, the validity of the certificate needs to be checked at a later stage it can be requested again. The primary record of vaccination is the Commonwealth Medicare system. We recommend:

returning the certificates without copying them and creating and capturing a record that the certificate has been sighted
deleting the email if the certificate has been attached, and capturing the response that the certificate has been sighted

The level of detail needed to record that a COVID-19 certificate has been sighted depends on the circumstances. For example:

if it relates to an employee you may want to create a register or annotate the employee record. This is because your public office has a resposibility to ensure a safe workplace.
if it is a member of the public attending a building where they need to sign in, it might be an additional tick in the sign-in book. If they are entering the building using a QR code and their details are captured in the contact tracing system, it is probably sufficient to ensure that your procedures note that certificate are sighted by relevant staff members. The new Vaccine Passport will reduce the need to check COVID-19 certificates as the Passport is part of the QR code check-in.

If you do need to retain a copy of the certificate for verification purposes or transmission to another public office, dispose of the copies as soon as business use ceases

Note in your communications with the individual submitting the certificate that it will be deleted, returned, or destroyed once it has been sighted and will not be retained in your systems.

We recommend public offices have documented procedures for handling of these types of documents based on a risk assessment. Creating and capturing a record that the documents were sighted fulfills the requirements of the State Records Act and your retention and disposal authorities.

How long should a record that vaccination or exemption certificates have been sighted be retained?

There is no one answer to this question. It depends on the reason the certificate was required and the minimum retention periods in the relevant retention and disposal authorities issued by SARA. Please note that if a risk analysis shows the records need to be retained longer than the minimum retention periods in our disposal authorities then this should be documented and the record retained as per your risk analysis. Common examples are:

employee and volunteer vaccination required by the employer: 7 years after employment ceases (GA28, 14.5.5 or GA39, 22.9.3)
family day care providers and family members residing in the property: 3 years after the last date on which the nominated supervisor or staff member provided education and care on behalf of the service (Section 183 of the Education and Care Services National Regulations)
contractors required to enter workspaces: 7 years after action completed (GA28, 14.5.4) or maintain as per the record of the contract which is 7 years after expiry or termination of the contract (GA28, 4.0.1 )
members of the public entering property managed by the public office: this depends on how the public office already captures their presence in the building. If they are required to sign in and show proof of identification it may be simpler to record the sighting of a certificate as part of the secure sign on process. Sign in books to secure areas are required to be retained for 7 years (GA28, 16.24.5). If a separate sign in record has been created to facilitate COVID - 19 contact tracing the sighting of certificates could be managed as part of that process and retained until administrative or reference use ceases (GA28, 16.24.7). This aligns with the Public Health Orders which stipulate that contact tracing records are to be destroyed as soon as practicable when no longer required for contact tracing purposes (i.e. within 28 days)
jurors and legal professionals entering a Court building for a hearing/trial: retain until administrative or reference use ceases (GA28, 16.24.7).

This does not apply to public offices that provide vaccinations - a record of the vaccination should be retained in accordance with the disposal authority for public health services - 7 years after last attendance or official contact or access by or on behalf of the client, or until client attains or would have attained the age of 25 years, whichever is the longer (GDA17, 1.2.1).

Please get in contact with us at govrec@records.nsw.gov.au if you have specific enquiries in relation to the vaccination certificates that are not covered above. Additional advice is available from our COVID-19 pages.

Certificates of title

Currently certificates of title are required to be retained until the property is sold, then transferred to the new owner under the General retention and disposal authority: administrative records GA28, 16.1.4 and the General retention and disposal authority: local government records GA39, 5.2.4.

The Registrar General of NSW has declared that 11 October 2021 is the day on which all certificates of title (CTs) will be abolished, known as ‘cessation day’.
By order under section 33AAA of the Real Property Act 1900, from cessation day all current CTs have no legal effect and the Registrar General will no longer issue CTs for any reason.
The Torrens Title Register remains and has always been the single source of truth as to a person’s ownership or interest in land.

To permit public offices to dispose of certificates of title we will be amending both general disposal authorities to permit disposal of certificates of title once administrative or reference use ceases. We will be seeking approval for the amendments at the December meeting of the Board and will advise public offices as soon as possible after the date of the meeting (8 December).

Updated Guidance

In light of recent recordkeeping enquiries, we have updated our guidance on COVID-19 with an additional scenario.

Scenario 8: Your organisation is monitoring compliance with Public Health Orders. This includes reporting confirmed or suspected employee cases of COVID-19 and confirming vaccination status and travel permits.

We have also updated our guidance on Establishing Effective Information Management to support key guidance for the Records Management Assessment Tool (RMAT).

Advice on social media recordkeeping for Councillors is now available. This will assist councillors and the council’s social media coordinator/records officer in defining State records on social media platforms.

How to Move a Zoo

How to Move a Zoo is a collaboration between Sydney Living Museums and NSW State Archives and opens soon at the Museum of Sydney.

Over the course of six months in 1916, hundreds of Sydney’s animals left behind their cages at the old Moore Park Zoo and were shepherded through the city streets before being ferried across the harbour to their new, purpose-built home – Taronga Zoological Park. From a 4-ton elephant named Jessie, to kangaroos, lions and cockatoos, animals big and small made this journey to a new life in one of the world’s most beautiful zoos. Check out a preview here.