Cultural collecting institutions are not only the custodians of their collections, but also the guardians of the contextual information for those collections, without which their cultural value is compromised.
At the ARC conference held in Melbourne in February 2012, we presented a session focussing on the collaborative project being undertaken by the National Gallery of Victoria and Museum Victoria to produce a records Retention and Disposal Authority (RDA) and also the importance of a corporate approach to information management in cultural collecting institutions.
The RDA, as well as being a legal standard, will be an important instrument of control in identifying and preserving classes of records that should be maintained permanently and those that can be disposed of when their useful life comes to an end.
The production of a RDA recognises the need for the records of collection items to be maintained in the agency that has custody of the object to which they refer; a need that sets these classes apart from the records of most other organisations, where their business use is finite and disposition to an archive repository is the appropriate outcome.
As well as business need, our work references existing authorities in Australia, as well as State, national and international legislation, codes and regulations that impact on the creation and retention of records in the sector.
We are both the officers primarily responsible for providing records and information management services and support to our respective organisations: the National Gallery of Victoria (NGV) and Museum Victoria (MV). We currently both have records management projects that have several aims and objectives in progress.
The projects aim to improve the records management practices of our organisations, by meeting the requirements specified in the recently revised and released records management standards from the Public Records Office of Victoria (PROV). While aiming to meet the specifications and requirements of the PROV standards, we are taking a practical approach and aim to meet our compliance requirements while also providing good business processes and solutions to ensure that the right information is available to the right people, at the right time.
Our collaborative project is focussed on developing a functional records Retention and Disposal Authority (RDA). A RDA is a legal instrument that categorises all records created or received by both our collecting institutions in the course of our core business functions. It specifies how long those records must be retained and the eventual disposal action for those records.
Examples of business functions are Collection Management, Audience Development, Exhibition Management, or Commercial Operations. All of these core business functions result in the creation of corporate records, either as structured data in databases, unstructured data in electronic documents, or in hardcopy.
Having an authoritative and officially endorsed records RDA is an important cornerstone for good information and records management practice in any organisation and, when implemented, ensures that records are preserved and accessible for the course of their life. It also ensures that records are not retained unnecessarily, thereby mitigating risk to the business in legal disclosure or Freedom of Information contexts.
This paper is presented in two sections, much as we presented the session at the conference. Firstly, we consider the legislative and regulatory framework with which our organisations must work and comply and the impact that has on the way we must manage our records. Secondly, we outline the methodology and approach we have taken to the development of the RDA, and how the outcomes fit into the larger picture for our organisations and their records management compliance obligations.
NGV and MV are, like most other cultural collecting organisations, awash with information. Much, but not all, of this information constitutes public records, as defined by the Victorian Public Records Act 1973. In addition to public records there is the additional information resources that are used in the conduct of our activities, (such as reference material, publications, working copies, notes, rough drafts and other resources, electronic and hardcopy), that are not considered records of our business.
By developing and referring to a RDA we can differentiate the records that require permanent retention from those that have a shorter shelf-life. Public records include records created and stored within business systems or databases, such as Collection Management Systems, Human Resources Systems, Digital Asset Management Systems, and Financial transaction systems.
Archives are those records that are judged to be historically significant and therefore retained permanently. Archives are a subset of corporate records, and would normally not constitute a significant percentage of the total records or information created or retained by any organisation; typically around 5%. Agencies responsible for cultural collections will have a larger than average proportion of archival records that, furthermore, remain in permanent use.
There is an existing general RDA for common administrative records under which our agencies may dispose of these as directed. The RDA we are developing will allow us to do the same with records of our agency-specific functions. It is a statutory requirement under PROV’s Disposal Standard to compile this document.
The RDA provides the direction for when the disposal takes place and also what the disposition arrangement should be. Retention in the agency is a possible action and will apply to most collection-related records. It is important to remember that disposal in this context does not necessarily mean destruction – it can mean disposition to archive.
As previously mentioned, the collaborative project we are working on is the development of a functional records retention and disposal authority (RDA).
The functional RDA will list the classes of records which are unique to our institutions here in Victoria, and not otherwise covered by the General Disposal Schedule for Common Administrative Records, issued by PROV.
As part of the formal process outlined by PROV for developing a functional records and disposal authority, MV and NGV entered into a joint project agreement with PROV, in mid 2011. The project agreement simply outlines the agreed timeframes within which our organisations will submit drafts to PROV for review and eventually to the Public Records Advisory Council (PRAC) for the final endorsement of the RDA.
The initial phase of our project has been the analysis of existing disposal authorities from other organisations and jurisdictions. There are many existing RDAs from similar collecting and cultural institutions that we have used as a reference and precedent in relation to record retention and disposal. The fact that State legislative requirements are different can have an impact on what records need to be retained and for how long. For this reason, examples of existing authorities from other jurisdictions are useful in the analysis phase as a source of standard existing practice, but they cannot be implemented without verifying our own legislative requirements.
These existing RDAs are a great starting point for discussion and review and can provide additional justification or support for the disposal actions we will include in our proposal to the PROV. There are some examples of these existing RDAs included in the references section of this paper.
Another major activity in the analysis phase is the review of the legislative and regulatory framework in which both of our organisations are working. We were lucky enough to have a good starting point for this phase, as we were able to draw upon work already done by our respective risk and governance departments in identifying and collating a comprehensive list of current legislation, regulations and standards, with which we must comply.
There are many obvious pieces of legislation that apply to our organisations; most obviously our enabling Acts the Museums Act 1983 and National Gallery of Victoria Act 1966. In our initial analysis, and our subsequent consultation with colleagues representing the business functions of our organisations, we have discovered an additional, extensive and varied list of legislation, regulations and standards with which we must comply and, therefore, ensure that we are keeping adequate documentation as evidence of that compliance. An interesting example of such legislation is the Firearms Act 1996, with which Museum Victoria is obligated to comply as the custodian of firearms within the State Collection; these firearms require the relevant permits and licences. The records and evidence of permits and supporting documentation must be suitably managed and retained for as long as the firearms are in the custody of the organisation.
The analysis of the regulatory framework can become quite convoluted and intricate at times, but we have been lucky enough to draw upon existing resources compiled by colleagues, as well as having business representatives who have a comprehensive understanding of the regulatory frameworks within which they conduct their business activities. This knowledge has been vital in the identification of relevant legislation, and the explicit and implicit recordkeeping requirements of such legislation.
Once the recordkeeping and retention requirements have been identified, they will be reflected in the RDA by describing the records we are obligated to create or retain, together with the retention period, and the ultimate disposal action, once the records have been retained for the period of time specified in the RDA.
The last and probably most important and valuable phase of the RDA development project, has been the stakeholder consultation. While the legislative compliance aspect of records management is important, there are also business requirements to consider, which are just as important. So to ensure we understand these, we have to consult the business experts.
The approach to stakeholder consultation we have decided to take has been, initially, to conduct a series of consultative workshops, involving representatives from each of our agencies. This commenced in October 2011 and will continue through until approximately May 2012.
Each workshop has focussed on a particular core business function of our organisations. They have involved representatives from both agencies, and from a variety of departments and sections within our organisations, who all contribute to the same business function.
Initially, we asked workshop participants to identify all the types of records and information they either create or require as part of the work they do, to support the particular business function we are focussing on during that workshop. It is important for us to identify all the different types and sources of information that are required and that is being used, irrespective of their format or medium.
We then asked participants to categorise or group those information and record types into ‘themes’ or categories of information that are similar in nature, or related to the same business activities. This helps us understand the relationships between various different records and information types and can also affect the retention requirements for one record type, if it is required as evidence to support another.
Probably the most valuable component of a RDA is the status and retention period, which outlines how long our records need to be accessible to our organisations, either for business requirements, or in order to comply with legislative or regulatory requirements.
We asked workshop participants to provide broad retention periods for the categories of records and information, based on their own business requirements or knowledge of legislative or compliance requirements. These suggestions will form the basis of our initial proposal for retention periods, and will be supported by the justifications or rationale obtained from workshop participants, as well as from current practice in other jurisdictions.
Given that we are cultural collecting institutions, there is a strong historical requirement or community expectation that we retain many records for the long-term, if not permanently as archives. The community in this instance is a significant stakeholder, and is an important consideration when determining the minimum length of time we should retain certain records.
The other important consideration is the disposal action for records once they have exceeded their minimum retention period. This is a decision about whether the records are destroyed, or need to be converted into an archival format and transferred into a more permanent storage facility, or electronically transferred to the State Archives.
Once we have conducted the initial consultation workshops, we draft the RDA for the business function we were focussing on. This is then circulated to workshop participants and other key agency stakeholders for further consultation and feedback. Many major and minor amendments are made, and will need to be made, as a result of continuing consultation.
The consultation and drafting process is time-consuming and needs to be very detailed, well considered and documented. But it is important to ensure we are identifying and describing all records and information being created or required by our agencies, so that records are not retained unnecessarily, and that vital and historically important records are protected from premature disposal and adequately preserved.
Our proposal, when submitted to the PROV for review and consideration, must contain justifications or rationale for the proposed disposal actions, so that the PROV can understand the regulatory frameworks within which we are operating, as well as our business requirements, and therefore why we are suggesting particular retention periods, disposal actions and custody arrangements.
The draft RDA will go through a series of reviews and modifications in consultation with PROV, until we have a final version agreed upon by both of our organisations, as well as the PROV. We are currently scheduled to have a final agreed RDA by April 2013.
Once PROV, NGV and MV have agreed on the final RDA, it will be submitted to the Public Records Advisory Council (PRAC), for final endorsement.
Once an RDA is endorsed by all parties, the next step for us will be to implement the authority within our respective agencies.
How this is done will differ between our organisations, but in both cases, the RDA will assist us in our ongoing records disposal programs, which are necessary in any organisation for purging and preserving information and records. It is important to mention that the RDA covers records of all formats – including those in business systems and databases.
The RDA will become our reference for identifying the records in a system that must be migrated, and perhaps what records do not need to be migrated or retained.
Similarly, it will be applied to the retention and disposal of hardcopy records, and can extend to unstructured data or documents which may reside on shared network drives. The technicalities of how the RDA will be implemented have not yet been planned, but this will likely be part of a future project for both of our organisations.
Part of that future project will also be identifying the various formats of electronic records, so we can ensure we have an adequate migration or preservation strategy in place, so we have access to records for the minimum retention period outlined in our RDA, and particularly for our permanent archives.
Our project agreement with PROV has us scheduled to have a final endorsed RDA by May 2013, so we still have much consultation, drafting and revision to do before we have a final product. The result will be a valuable instrument and tool for our organisations to accurately manage the disposal of our unique core business records.
By Rebecca Burns, Manager of Records and Archives at Museum Victoria and Karen Anderson, Archives Project Manager for National Gallery of Victoria.
Art Gallery of New South Wales
Arts & Cultural Development Records
Australian War Memorial
National Archives: Cultural Collections
National Museum of Australia
State Library of New South Wales
Australian Society of Archivists
National Archives Australia (NAA)
Australian Capital Territory
New South Wales State
Archives & Records Association of New Zealand
Archives New Zealand
National Preservation Office
London Museums – IRM Project