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1 RECORD AND DATA MANAGEMENT POLICY Version 2.0 Document data Document type: Rule/Policy/Plan/Guidelines/Operating Procedures Administering entity: Records Manager Date approved: 14 April2009 Latest amendment date: 18 February 2015 Approved by: (Academic Board/Principal) Indicative time for review: Annual Responsibility for review: Principal 1 Purpose The purpose of this policy is for the management of all the records of Top Education Institute (TOP), to establish principles for the creation, collection, maintenance, reporting and disposal of records including physical documents and electronic data, for the purposes of administration, security, corporate memory and legal obligations. This policy will also cover all data created for the purposes of reporting to external bodies such as (but not limited to) external auditor, HEIMS, TEQSA, ACPET and ASIC. TOP will capture and maintain records and data to: support TOP s day to day business activities provide evidence to ensure accountability preserve TOP s corporate memory. Ensure that a data trail is effectively documented within the processes associated with accessing, retrieving, reporting, managing and storing of data. Records will be organised, managed and protected in conditions appropriate to their context and nature, and to TOP needs. Records will be preserved so that they remain usable and accessible for as long as they are required. TOP s records are its corporate memory, providing evidence of actions and decisions and representing a vital asset to support its functions. They assist in policy formation and high level decision making; protect the interests of TOP and the rights of employees, clients and citizens. They support consistency, continuity, efficiency and productivity in program delivery, management and administration. 1

2 TOP is committed to meeting its responsibilities under the State Records Act 1998 and to implement best practice in its records management practices and systems. 2. Scope The policy applies to all academic and administrative units within TOP and to all records including , generated or received by them. All records are the physical property of TOP not the member of staff who created or received them. Key Accountabilities Each organisational unit within TOP will nominate a position that will have responsibility for 'day today' records and data management within that unit. This does not need to be a position dedicated to records and data management and may form part of the duty statement of the designated position. This is known as a Records Liaison Officer. For more information please refer to section 4 of this policy. Each member of staff within TOP is responsible for records creation and management and must: a. make and keep full and accurate records of all TOP related activities for which he or she is responsible; b. create records that document all substantive or formal decisions taken by him or her in the service of TOP c. create records that summarise important telephone conversations; d. capture all relevant records e. handle records with care; f. protect records from accidental damage; g. protect sensitive records in their custody from unauthorised access; and h. not destroy records without prior authorisation from his or her supervisor or from the Records Team. Committees, Working Parties and Project Teams The secretaries of all committees, working parties and project teams must: a. be responsible for the management of committee records; b. comply with all relevant standards, guidelines and policies on records management in regards to records of the committee, working party or project team; 2

3 c. create and keep full and accurate records of all committee, working party or project team meetings; and d. register all meeting papers with records management (where appropriate). Record and Data Officer There will be a designated position of Data Collection Officer. This officer will be responsible for the following tasks: To generate and integrate the student data reports from the internal student systems (including the EduPoint, Jobready, etc) and ensure the accuracy and validity of the data by checking with the Admission Manager and Academic Programs Coordinator; Regular maintenance of the above student databases for accuracy and security; Fully understand HEIMS and related external authorities policies, and to report the data to HEIMS, TEQSA and other applicable external authorities accurately and on schedule in line with the working menu; To provide relevant student performance data such as annual attrition rate and annual progression rate and other data requested by Academic Programs Admission Manager and other senior management; and The maintenance and updating of TOP s Record Framework. 3 Definitions For the purposes of this document: Appraisal The evaluation of business activities to determine which records should be retained and the period of retention, in order to meet legislative requirements, business needs and organisational accountability. Archive non current records, for permanent retention. Classification Scheme Grouping records according to their functionality. Disposal The range of activities involved in retention, deletion or destruction of records. Disposal Schedule List of various records and the period of time the record must be retained. It may also indicate the time at which records should be transferred to secondary storage. Disposal trigger The event such as; action completed or superseded, from which the disposal date is calculated. Destruction Destroying a record, either the physical destruction or permanent deletion of a record. Document Information treated as a unit of information. Record Recorded information created or received by TOP that provides evidence of business activities and affairs, regardless of format. Record Management System Information system used to capture and provide access to records. Retention the period of time a record should be retained by the institution before final disposal. It may also indicate when records should be transferred to secondary storage or Archived. 3

4 Sentence Identifying and classifying a record according to the Disposal Schedule in Appendix B. 4 Procedures 4.1 Responsibilities TOP staff, contractors and consultants Each employee of TOP, contractor and consultant will be responsible and accountable to the relevant Section Manager for creating records that document the business transactions and activities in which they take part, and to maintain these records in accordance with TOP policy and legislative requirements. All staff shall undertake records management training to a level suitable for their level of record keeping responsibilities. Verification of Data Where staff enter data into external systems (such as HEIMS database, TEQSA Provider Portal) the staff member must have the accuracy of data entered verified by their direct supervisor and/or the Principal (where appropriate). This must be done prior to submission of data. Record and Data Officer This officer is responsible for the establishment and management of records management systems, policies and procedures to ensure compliant recordkeeping. The officer reports to the Academic Program Coordinator and Admission manager for data verification or the Principal (where appropriate). Section Managers Section depending on their lines of reporting, will be responsible and accountable to the Principal, for implementation of the Records Management Policy, procedures and good recordkeeping practices within the organisational unit/s under their responsibility or any TOP wide functional areas that they may lead. Section Managers are responsible for ensuring that all appropriate material within their area, including , is recorded in an approved records management system. Record Area Student Records Financial Records Staff & Payroll Records Curriculum Records Legal & Contracts Library Section Manager Responsible Admission Manager and Academic Coordinator Senior Administration HR & Finance Manager Senior Administration HR & Finance Manager Director(s) of Programs Senior Administration HR & Finance Manager and Legal Counsel and Senior Manager for Governance Librarian 4

5 Creation and collection of electronic data: Refer to the Appendix A TOP Data Reporting Working Menu Access to Records Staff may have access to those records necessary to fulfil their duties. (a) Certain records of a confidential nature may have restricted access for the period of time which they remain confidential. (b) All requests by external agencies or individuals for access to records of a personal nature, other than their own record, must be referred to the Principal or the TOP Privacy Officer. TOP records must remain on site with the exception of the following: (a) Archived records may be stored off site with an approved service provider. (b) Records are required to be made available to a court or for other legal purposes. (c) Any other exceptional purpose with the approval of the Principal who may stipulate special conditions to be taken while the record is off site. Staff leaving employment a) Any staff member who ceases employment shall ensure all TOP records under their control, regardless of format, have been identified and included in the official recordkeeping system. b) Section managers should ensure the departing staff member has complied with section (a). c) Where it would appear that section (a) as not been complied with, the Principal may authorise the IT Manager to have access to the departing staff member s drives and/or to ensure all TOP records have been captured into the records system. 4.2 Training All staff will receive record management training as part of their orientation. 4.3 Auditing Regular auditing of record management activities will take place. This is to ensure that records are being created and maintained correctly and an accurate record of the Institutes business activities and affairs is being captured in the record management system. 5

6 4.4 Creation of Records Records should be added to the recordkeeping system at the time of creation or receipt of a document Wherever possible records should be held in electronic format All records should be classified according to the appropriate record keeping naming conventions. The record classification scheme will be used to classify all the Institute records If possible all records should be sentenced at the time of creation in accordance with the appropriate disposal schedule. 4.5 Record Maintenance All records must be stored for their period of retention All records must be accessible All records (electronic and hard copy) must be maintained in good condition. 4.6 Retention and Disposal of Records All records should be disposed of according to the appropriate disposal schedule All records must to be sentenced according to the appropriate disposal schedule The disposal date must set according to the disposal trigger No records can be destroyed of without the permission of the Principal All records that are destroyed must be recorded in a register of Destroyed Records The destruction process must be secure to ensure confidentiality. 4.7 Archiving Records Inactive records should be archived with the approval of the Records and Data Collection Officer The archive will include records that must be held indefinitely and inactive records during their retention period. 4.8 Record Security Records must not be altered and all care must be taken not to damage records Access to records will be limited by a password hierarchy All records will be kept in a secure environment TOP s Critical Incident Policy is in place to minimise the potential loss of records. 4.9 Detailed procedures for the handling of records may be prepared by each record section Section procedures must defer to this Record Management Policy Section procedures may only be prepared and used with the approval of the Records Officer. 5 Related documents i) Delegation Schedule ii) Privacy Policy 6

7 iii) Accounting and Financial Management Policy iv) Critical Incident Policy v) Information Security Policy See Appendix B for Disposal Authority Schedule 7

8 Appendix A Appendix B TOP Data Reporting Working Menu Disposal Authority Schedule TOP shall retain records for a period no less than as prescribed in the NSW State Records, General Retention and Disposal Authority University records GDA and disposal authorities/generalretention and disposal authorities/files/gda23 university records For all other records the NSW State Record Dags will be used to determine a minimum retention period. See GA 28 Administrative Records The following schedule provides a guide to some of the most commonly used records. List of Functions covered: Governance and General Administration Library Equipment and Stores Technology and Telecommunications Occupational Health and Safety Marketing Financial Personnel Student Administration Teaching Exams Results Reference Function / Activity Disposal Action Governance and General Administration Institutional establishment Permanent Retention 1 Note that NSW State Records does not specify record keeping requirements for private organisations. See asked questions 1/frequently askedquestions#can state records provide advice about how long private organisations and individuals should keeptheir records 8

9 1.2.0 Restructuring The establishment of new organisational structures Accreditation Final submission and official approval Accreditation Drafts, research, analysis Planning Final approved version Planning Drafts, research, analysis Policy Final approved version Policy Drafts, research, analysis Procedure Final approved version Procedure Drafts, research, analysis Agreements Establishment, negotiation, maintenance and review of agreements Reports submitted to external organisations, eg. TEQSA, ASIC, ATO Permanent Retention Permanent Retention Retain 3 years after action completed, and then destroy. Retain 7 years after planning is superseded, then destroy. Retain 3 years after action completed, and then destroy. Retain 7 years after policy is superseded, then destroy. Retain 3 years after action completed, and then destroy. Retain 5 years after procedure is superseded, then destroy Retain 3 years after action completed, and then destroy. Retain 7 years after expiry or termination of agreement or after action completed, whichever is later, and then destroy. Retain for 7 years after action Library Fines and Penalties Retain 6 months after action Records of borrowings and use of library materials. Retain until no longer required for administrative purpose, then destroy Equipment and Stores Acquisition Quote, negotiation, correspondence Retain 7 years after action 9

10 3.2.1 Insurance Policy, renewals, information Retain 7 years after expiry of the policy, then destroy Stock take Retain 2 years after action Technology and Telecommunications Acquisition Quote, negotiation, correspondence Workplace Health and Safety Accidents Records relating to incidents that result in serious personal injury or incapacity to employees Accidents Records relating to incidents that DO NOT result in serious personal injury or incapacity to employees Accidents Records relating to the provision of first aid treatment. Records include: Audits The organisation's workplace health and safety management systems or processes Marketing Production of Publications Final approved versions Production of Publications Draft, research, graphic designs Organisation's website Pages relating to the organisation's core business, and records of substantial changes made Market Analysis Including market research, forecasting, advertising, promotion, pricing Student Recruitment to encourage perspective students to apply including overseas marketing activities. Retain 7 years after system is superseded, then destroy. Retain for 7 years after action Retain for 2 years after action Retain for 5 years action Retain 6 years after action Permanent Retention Retained until ceases to be of administrative or reference use, then destroy. Permanent Retention Retain 2 years after action Retain 2 years after action 10

11 7.0.0 Financial Accounting Retain for a minimum of 5 years after audit Employee taxation records Retain 5 years after separation / termination of employment, Personnel Recruitment Selection process Contracts Employment, promotion, work / position redesign, separation Staff Leave administration of leave, leave requests, long term entitlements whichever is the longer, then destroy. Retain for 2 years after recruitment has been finalised, then destroy. Retain for a minimum of 7 years. Retain for a minimum of 7 years Performance Management Administration, implementation, individual performance agreements Grievances formal grievances raised by an employee Student Administration Application Records relating to offers and applications which are successful and accepted Retain for 7 years after employment ceases, then destroy. Retain for 10 years after action Retain for 6 years after completion or discontinuation of course or program of study by student, then destroy Unsuccessful applicants Retain until appeal period has expired or for 6 months after action completed, whichever is longer, then destroy Student Enrolments Retain for 6 years after completion or discontinuation of course or program of study by student, then destroy. 11

12 9.3.1 Withdrawal from a course of study. Retain for 6 years after completion or discontinuation of course or program of study by student, then destroy Student Fees Retain for 7 years after completion or discontinuation of course or program of study by student, then destroy Student attendance and related documents e.g. medical certificates Retain until end of appeal period, then destroy Grievances Records relating to formal grievances raised by a student Retain for 7 years Graduation Notification Notification of students of their eligibility to graduate. Retain for 1 year after action Register of Graduates Permanent Retention Student ID card Records relating to the provision of student identification Variation of student details Address and contact details Variation of student details Notification of student name change Retain until no longer required for reference or administrative purposes, then destroy. Retain until no longer required for reference or administrative purposes, then destroy. Retain for 6 years after completion or discontinuation of course or program of study by student, then destroy Student Orientation planning and management of student orientation Teaching Course delivery materials eg. subject outlines, study guides, readings, reading lists, assignment lists, lecture notes handbooks and guides course descriptions, requirements, prerequisites, content and outcomes. Retain for 2 years after action Retain for 5 years after no longer required for teaching. Permanent Retention 12

13 Quality assurance Records relating to the assessment of data/feedback on course delivery Curriculum Approved Curricula Curriculum Records of the approval process. Retain until no longer required for reference or administrative purpose, then destroy. Permanent Retention Retain for 7 years after Curricula superseded, then destroy Curriculum Curriculum development / Working papers Exams Administrative arrangements for the conduct of examinations and other assessment activities Retain 3 years after curricula superseded, then destroy. Retain until no longer required for reference purpose, then destroy. 13

14 Examination papers Master set of questions Results Permanent Retention Student academic transcript/final results. Permanent Retention Grading/marking of individual assessment components Eg. Assignment, essays, theses. Retain 1 year after end of appeal period, then destroy Special consideration requests Retain for 7 years after completion or discontinuation of course or program of study by student, then destroy. Page

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