Transition Guidelines: Managing legacy data and information. November 2013 v.1.0

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1 Transition Guidelines: Managing legacy data and information November 2013 v.1.0

2 Document Control Document history Date Version No. Description Author October 2013 November Draft Department of Finance and Services 1.0 Final Department of Finance and Services Approvals Name ICT Leadership Group Date Document custodian Name Signature Department of Finance & Services, Strategic Policy Page 2 of 21

3 CONTENTS 1. PURPOSE INTRODUCTION SCOPE REQUIREMENTS FOR TRANSITION OPTIONS FOR TRANSITION IDENTIFYING MATERIAL FOR DIGITISATION RELATED GUIDANCE CONTACT APPENDIX A GLOSSARY APPENDIX B RESOURCES FOR MANAGING TRANSITION APPENDIX C INFORMATION MANAGEMENT PRINCIPLES Page 3 of 21

4 1. Legacy data and information is data and information stored in superseded formats and systems. The purpose of these guidelines is to assist agencies to manage or transition legacy data and information in ways that will minimise business risks. The guidelines provide direction to address risks associated with: migrating data to new systems, including transitioning from paper to digital records; transitioning to shared services, Cloud computing or other third-party arrangements; maintaining legacy data and/or legacy systems; disposing of legacy data and/or legacy systems. These guidelines will assist agencies in making decisions to ensure data and information remains reliable and fit-for-purpose, to ensure core business information is sustained and time expired information is accountably destroyed, to enable better service delivery and better value investment in the NSW public sector. The guidelines will be implemented by agencies in various ways according to their specific business needs and operating environment. This document does not include procedures for managing or conducting a transition project. Appendix B indicates resources which address specific transition scenarios and provide more detailed procedural guidance for migration or conversion. The guidelines can help agencies implement the Information Management Framework and best practices for managing information across the NSW public sector Information Management Framework A key initiative of the NSW Government ICT Strategy is the development of an Information Management Framework to support the way government designs systems, and administers and uses data and information. The Framework is a set of standards, policies, guidelines and procedures which are implemented either manually or, where possible, automated through technology. This Framework will enable data and information to be managed in a secure, structured and consistent manner. It will ensure that data and information can be appropriately shared or re-used immediately and in the longer term by agencies, individual public sector staff, the community or industry for better services, improved performance management and a more productive public sector. Page 4 of 21

5 2.2 About transition As they move to new ways of working or ICT sourcing arrangements, agencies will often have to determine how best to manage or transition data and information stored in superseded formats and systems. This could require the transition from one hardware or software platform to another; or the proactive digitisation of incoming paper records for current business; or retrospective digitisation of older paper records. Questions about legacy data management can also arise during periods of administrative change. Where responsibilities are transferred, agencies may relinquish or inherit relevant data and information in a range of formats and systems. In transition scenarios, some legacy data and information may be needed to support ongoing business operations, while some may be accountably destroyed. It is important to assess the risks and benefits associated with either: Maintaining data and information in superseded formats or systems; or Converting or migrating data and information to new formats or systems. Requirements for managing legacy data and information will vary according to the drivers for transition; the business case and objectives for transition; the use and value of the data or information being transitioned. Agencies need to ensure appropriate controls continue to be applied to data and information, during and after a transition. These guidelines identify the issues that need to be considered to support and manage business information assets through transition scenarios. 3. These guidelines apply to the management and maintenance of data and information assets within all NSW Government Departments, Statutory Bodies and Shared Service Providers and related entities of departments/divisions. The guidelines are recommended for adoption by NSW: State-owned corporations (SOCs); Public trading entities (PTEs); Entities fully funded by the NSW Government; and Local Government Authorities. Page 5 of 21

6 4. Requirements for managing legacy data and information will vary according to the drivers for transition; the business case and objectives for transition; the use and value of the data or information being transitioned. Understanding these requirements will enable agencies to identify the best option or approach to transition. This section describes the issues and critical factors agencies should consider to determine pathways for managing data and information with ongoing business value. Effective transition strategies can maximise the process efficiencies and cost savings made possible in the digital environment, whilst also enabling the routine and authorised destruction of time-expired information. 4.1 Drivers for transition Various circumstances may compel the need to transition and each scenario will highlight different areas of risk to be addressed as a priority. DRIVER FOR TRANSITION Automating a business process (eg scanning paper documents to create a seamless digital work process) Identify documents for scanning and capture into the new system. Determine which controls and functionality are required to support it in the new system. Understand the lifetime of legacy data and information, and its relationship to newly-created data or information to determine needs and limitations for back-capture. Management arrangements for: source paper documents, once scanned legacy paper documents which are not scanned, - including search, accessibility, security, retention and destruction or transfer to State Records. Retiring or decommissioning a system (eg due to upgrade or new application) Identify data for migration to the new system. Determine which controls and functionality are required to support it in the new system. Management arrangements for legacy data which is not migrated including search, accessibility, security, retention and destruction or transfer to State Records. Page 6 of 21

7 DRIVER FOR TRANSITION Implementing a completely new system (eg when a new service is commenced Dependencies between this new source of data, particularly any requirements to integrate or merge datasets for analysis. Potential for re-purposing; value of new data for informing decision making in other operational areas. Continuity or preservation of data/information required long-term (eg changing the format, storage medium, or transferring to Digital State Archives) Identify data or information that can be transferred to the Digital State Archives maintained by State Records. Management arrangements for legacy data which is not transferred including search, accessibility, security, retention and destruction. Particular requirements for future format conversions or system migrations that may be required to support long-term preservation. Administrative change (eg where functions move from one agency to another; or a function ceases to be carried out by NSW Government) Identify which data or information should be transferred with the function, and which is required to meet ongoing business or legal requirements. Clarifying custodianship responsibilities of the relinquishing agency and the receiving agency. Reconciling legal or business needs for data with the realities of different ICT environments. Moving to a new provider or service delivery model (eg shared services, cloud services, or other contract arrangements) Clarify the responsibilities of each party (agency, provider) for applying information controls. Identify which data should be transitioned into (and subsequently, out of) service arrangements. Performance monitoring and reporting. Page 7 of 21

8 4.2 Business considerations A number of considerations in the broader business environment can potentially influence decisions around whether to transition legacy data or information; and if so, which legacy data or information should be transitioned and how. These factors will be assessed in combination with the specific data or information management requirements, to determine the overall value proposition associated with each transition option. The business case for the transition should be clearly established, to ensure the transition meets the objectives and delivers anticipated benefits. KEY ISSUES FOR TRANSITION Have the business case and/or anticipated benefits of transition been clearly established and agreed by all key stakeholders? Will service delivery be improved by transition? What will be the impact on service delivery during transition? Is there sufficient capability/expertise to: identify business needs and technical/management requirements for the legacy data and information? carry out the transition process? maintain legacy data or information systems for the duration of their lifetime? Is there sufficient understanding of how the legacy data or system was used? What are the implications of not transitioning? Does the resourcing and funding model cover the entire transition process; and/or the maintenance of legacy data or information for its entire lifetime? Has a plan for communications or change management been prepared? Confirm that transition is required and/or can deliver the anticipated benefits. Identify any alternatives to transition which may be suitable for consideration (eg staff training; process re-design; policy enforcement; data disposal). Requirements for business process or organisational change. Customer service and communications. Availability of key staff or cost of external contractors for business analysis, information management and technical tasks. Availability of system documentation and/or staff with applied knowledge of the original purpose of the data or system; and its current use within the organisation. Risk of incomplete transition or legacy data and information becoming unsupported Impact on costs, timelines, business processes Have staff training needs been considered? Who will determine the feasibility of the transition? Input required from management, operational staff, information management and ICT staff. Page 8 of 21

9 4.3 Data and information management considerations Agencies need to ensure appropriate controls continue to be applied to data and information, during and after a transition. It must be possible to find, use and understand data and information; it must be stored and managed in a secure, efficient and accountable manner whether it is migrated, converted, maintained in a superseded format or system, or until it is accountably destroyed. Summary checklist Steps to manage the transition process: Define, assign and resource accountable roles for managing legacy data or information, including senior responsibility. Define appropriate information governance frameworks that will direct the management of data and information in the new custodian/service arrangement, system or format. Inform, train and support users of legacy data or information. Monitor and review ongoing management of legacy data or information against business objectives. Steps to manage legacy data or information: Review legacy data or information to understand how it is created, organised and used. Understand also accountabilities, opportunities, compliance obligations, cost, value and risks associated with the data or information. Determine whether any or all legacy data or information needs to be transitioned to new custodian, system or format. Define pathways for identified legacy data or information to be transitioned to new custodian, system or format, managed by appropriate governance frameworks and tagged with relevant metadata that enables its ongoing use and accessibility. Establish systems or processes that support effective management and appropriate internal and/or external use of legacy data or information that is not transitioned. Establish a system of ongoing checks to ensure that legacy data or information remains accessible and usable for as long as it required. Establish systems or processes which enable legacy data or information that is not transitioned to be routinely and accountably destroyed when it is no longer required, in accordance with the State Records Act. Page 9 of 21

10 Detailed questions The following table provides more detailed questions to help clarify the relative costs and risks associated with either maintaining or transitioning legacy data and information. The key issues are organised below according to which business outcomes and principles of the Information Management Framework are being supported. Refer to Appendix C for more detail around the IM Principles. IM PRINCIPLE: GOVERN Data and information are governed according to their value, as assets for which we are accountable KEY ISSUES FOR TRANSITION Who has responsibility for the business process? Is this being transitioned? Who is the data/information owner, custodian? Can all existing governance requirements be met by the new custodian/service, system or format? What alternate strategies can be put in place if they are not? Decisions to retain some legacy data and information may incur ongoing licensing or storage costs. Clarify roles, responsibilities and accountability. Assign critical tasks for data and information management (SLA, MOU, etc). Ensure transparency and effective decision-making. Define and document transition pathways and the information governance decisions made. Establish the governance framework for effectively managing data and information in the new format, system or custodian/service environment. Cut off periods between legacy and new business environments must be clear and understood. If they are not, duplicate transactions and the lack of a single source of business truth can cause risks. Page 10 of 21

11 IM PRINCIPLE: COLLECT Data and information are captured to enable services and operations; and collected in line with standards so they are fit-for-purpose KEY ISSUES FOR TRANSITION What is the quality of the data and metadata to be transitioned? In which different business, system and network environments is the legacy data stored? How was it collected, and for what purpose? Identify possible privacy issues Evaluate the risk/benefit of managing data in multiple formats or converting and consolidating Estimate growth and storage requirements Is data collection ongoing? (eg the business process is current) Does the transition require data to be collected in a different format? Does the transition propose a new use for an existing source of personal information? Page 11 of 21

12 IM PRINCIPLE: ORGANISE Data and information are organised for easy retrieval and efficient management KEY ISSUES FOR TRANSITION How is the information organised? What relationships exist between data and information components or aggregations; or between the legacy system and other systems? What metadata is present in the legacy system? How does it map to the target system or dataset? (can legacy systems be cross-referenced?) Has it been / can it be standardised? What metadata is necessary to access, use, manage and understand legacy data and information? How can this be maintained and/or carried forward? Metadata can be critical for authenticating and managing legacy data and information? How can this form of metadata which may not be connected directly to the data but which may be kept in security or audit logs be maintained as required? Can all data and information be tagged with relevant retention and destruction requirements during transition? Is some form of data management on the legacy data required before it can be transitioned? For example, legacy accounts should be appropriately managed and not transitioned as a whole to a cloud service environment. Retain metadata especially where it provide context and meaning to data: Data can be used and understood Helps inform decisions made under other principles. Technical capacities of systems may limit the legacy data and information that can be transitioned. Limited information management frameworks in some business environments may make identification of legacy data and information to be transitioned or managed challenging. Building these requirements into new custodian, system and format management environments will streamline management, reduce ongoing costs and facilitate future transitions. Large demands can be placed on staff organising information for transition and staff in these roles need to be adequately resourced and supported. Resourcing of the retrospective organisation of data and information can be a significant cost but expending money on this can yield significant cost, management and accountability dividends in the new custodian, system or format environment. Page 12 of 21

13 IM PRINCIPLE: SECURE Data and information are secured to protect their integrity and with respect for their sensitivity KEY ISSUES FOR TRANSITION Is any of the data/information personal, private, privileged, confidential, classified or otherwise sensitive? What protective markings or access controls have been applied? (Note: controls may have been applied via roles/positions, workflows, or data and information classifications/containers.) Can these controls be applied in the new format, system or custodian/service environment? Can the security be down-graded? If not now, when and how? Evaluate the functionality required and any cost implications associated with maintaining controls. Implement appropriate security measures to ensure the data and privacy are not compromised. Consider rights and permission management for legacy data and information. Does the target system (through functionality or the presence of other data) allow de-identified data to be re-identified? IM PRINCIPLE: USE Data and information are used to support evidence-based policy, targeted service delivery, and re-used to derive maximum return on investment KEY ISSUES FOR TRANSITION Who needs to / could use the legacy data? (within the agency, across business units) How will the legacy data be used? Is it still in use for a specified business purpose; what is the frequency of retrieval? How will it be accessed? Do on-going use considerations identify that different transition strategies should be applied to different types of legacy data? For example, it may be necessary for action officers to reference the last 2 years of customer enquiries and so these records should be digitised, but there is not a sufficient use case to justify the digitisation of the last 10 years of these records so the remaining paper records will not be digitised. What is the impact of transition on the business process and users? Will transition improve the accessibility of data and information? Evaluate the functionality required and any cost implications associated with maintaining usability and providing access. Multiple parties may require access to legacy data, across a range of business environments. Can this be enabled? Page 13 of 21

14 IM PRINCIPLE: SHARE Data and information are shared to streamline service delivery and reporting; to enable value adding; and support transparency KEY ISSUES FOR TRANSITION If appropriate, can the legacy data or information be shared or published? (outside the agency) Free? Or at what cost? What licensing options are applicable? Identify possible privacy issues. Consider rights and permission management. Evaluate the risk/benefit of managing data in multiple formats or converting and consolidating. Does the transition propose sharing, linking or matching personal information between different organisations? IM PRINCIPLE: MAINTAIN Data and information are maintained for as long as they have value then disposed systematically and accountably KEY ISSUES FOR TRANSITION Is the legacy data or information considered vital for ongoing operations? Is the legacy data or information stored in a format that is proprietary or standard? Is it still supported? Is the legacy data or information in a stable condition, or is it unstable/fragile? Does the legacy data or information need to be kept? Can it be destroyed or transferred according to an applicable disposal authority? If not now, when and how? Maintain metadata mappings from former to new (target) systems Ensure adequate system and configuration documentation Does full testing of the new custodian, system or format demonstrate a successful validation? Have the results been verified? Is the transition successful, with all anticipated information, governance and functionality? Will transition help preserve the data or information for a longer period of time? Is the format unique? Is a recognised/standard migration path or conversion process available? Will transition expose the data to an unacceptable risk of loss or damage? Is any management or reporting functionality lost or gained in the transition? Evaluate the functionality required and any cost implications required to maintain the data for the full duration of its retention period. Implement appropriate mechanisms to implement approved disposal. Develop appropriate backup strategy and disaster management plan for legacy data and information. Opportunity to implement stable, long-term formats, to limit format and system dependencies. Post validation, can source data be maintained for a business appropriate validation period then destroyed? Page 14 of 21

15 5. There are several options or models which agencies may consider for managing legacy data and information. The most suitable approach will depend on the unique combination of requirements identified according to the risks and benefits assessed in the preceding sections. Each approach involves a combination of: Maintaining data and information in superseded formats or systems; and/or Converting or migrating data and information to new formats or systems. Custodian agencies must ensure the capability, functionality and resources required to apply appropriate controls to data and information, during and after a transition. It is important to ensure the new environment incorporates robust information management controls and data disposal mechanisms. The selected approach will enable the strategic application of governance frameworks and the maintenance of core business information in both new and legacy environments. OPTION 1. Transition all legacy data or information (with appropriate metadata) to new custodian, system or format. After transition is completed, reviewed and success is confirmed, destroy any source data or information according to an applicable disposal authority. Ongoing access to legacy data or information is necessary for process continuity. Standard migration / conversion paths available 2. Transition some legacy data or information required by ongoing business processes (with appropriate metadata) to new custodian, system or format. Establish the governance and management requirements needed by the new custodian/service, system or format to support the legacy data or information. Retain remaining legacy data or information in the superseded format or system, until it is eligible for destruction. Determine which legacy data or information is required for ongoing business needs. Identify the governance requirements/responsibilities to be transitioned. Determine whether retained legacy data or information will be maintained in-house or stored and managed by a third party. Page 15 of 21

16 OPTION 3. Transfer some legacy data or information (with appropriate metadata) to the Digital State Archive (State Records). Transition remaining legacy data or information (with appropriate metadata) to new custodian, system or format. 4. Transfer some legacy data or information (with appropriate metadata) to the Digital State Archive (State Records). Retain remaining legacy data or information (with appropriate metadata) in the superseded format or system, until it is eligible for destruction. 5. Maintain all legacy data or information in the superseded format or system, until it is eligible for destruction. Data or information identified as State archives in an applicable disposal authority. Agree on an appropriate migration plan with State Records for the archived data or information. Data or information identified as State archives in an applicable disposal authority. Determine whether retained legacy data or information will be maintained in-house or stored and managed by a third party. Understand the retention period for the data or information. Specify when and how it will be disposed. Resources are available to maintain superseded format or system and ensure data or information remains accessible for the retention period. Determine whether retained legacy data or information will be maintained in-house or stored and managed by a third party. Page 16 of 21

17 6. The requirements and options for transition, outlined in these guidelines, apply to data and information in any format including digital, paper or microforms. Most agencies have large stores of paper files and may be considering whether or not there is a business case for digitising (or scanning) these documents. The following checklist provides high-level questions to determine whether digitisation could be beneficial and/or feasible. Further resources are listed in Appendix B. They offer more detailed procedural guidance for transitioning from paper records to digital and managing digitisation projects. YES High activity if documents are frequently accessed and requested by multiple users. Digitisation will significantly enhance access or increase use by a specific user group (staff, customers, general public). High volume if savings in storage and consolidation outweigh the costs of digitisation. Documents at risk of loss or inaccessibility due to deterioration, before retention period expires cost of digitisation outweighs alternative preservation options. Specific workflow or process efficiencies can be demonstrated. Identified business objectives or service delivery targets will be met or enabled by digitisation. NO Retention and disposal requirements are unknown. Retention period has expired and documents are being maintained "just in case" (ie there is no defined legal or business requirement). Low activity documents are rarely accessed and remaining retention period is short (eg less than 3 years). Inadequate systems agency does not have skilled staff, appropriate software or policy framework for managing digital records (ensuring security, integrity and accessibility). To create a backup of documents that have been legally disposed; or have been transferred to a new custodian. Page 17 of 21

18 7. This document is consistent with: guidance provided by the NSW State Records Authority for records management; guidance provided by the NSW Information and Privacy Commission for information access and privacy; and requirements for information security outlined under Premier s Memorandum M Digital Information Security Policy. 8. For assistance with any aspect of this document, please contact: Principal Policy Officer, Information Strategic Policy Department of Finance & Services Level 15, McKell Building 2-24 Rawson Place SYDNEY NSW 2000 (02) Page 18 of 21

19 TERM Custodian Legacy data/information Legacy system Transition DEFINITION The agency with possession, control of and/or responsibility for the legacy data or information. The custodian is primarily responsible for: the development, management, care and maintenance of a specified dataset or information asset; ensuring that all legal, regulatory and policy requirements are met in relation to the management of the specified dataset or information asset; and determining the conditions for appropriate use, sharing and distribution of the specified dataset or information asset. Data or information retained in a superseded format or system. Database or information system which has been superseded or decommissioned for current business processes. A change in the responsibilities for controlling or managing a particular set of data or information; and/or A conversion from one format to another, for a particular set of data or information; and/or A migration from one system or storage location to another, for a particular set of data or information. Page 19 of 21

20 The following resources provide more detailed guidance or procedures relating to specific scenarios for transitioning or managing legacy data and information. (IPC) = Information and Privacy Commission (SRA) = State Records Authority Identifying Privacy Impacts Identifying privacy issues checklist (IPC) Providing Access GIPA Act Compliance checklist for agencies (IPC) 3.5 Searching for information; 3.12 Providing access Transferring State Archives Digital Archives Migration Methodology (SRA) Transition to Shared Services Recordkeeping In Brief 44 - Using shared services for records management (SRA) Migration to New Systems General Retention and Disposal Authority GA33: Source records that have been migrated (SRA) Guideline 22: Managing digital records 4. Effectively manage the migration of your digital records (SRA) Transition to Cloud Services Recordkeeping In Brief 62 - FAQs about cloud computing (SRA) Recordkeeping In Brief 54 Storage of State records with service providers outside of NSW (SRA) General Retention and Disposal Authority GA35: Transferring records out of NSW for storage with and maintenance by service providers based outside of the State (SRA) Transitioning Paper Records to Digital General Retention and Disposal Authority GA36: Imaged records (SRA) Guideline 25: Managing digitisation programs and projects 12. Managing original paper records (SRA) Guideline 25: Managing digitisation programs and projects 13. Disposal of original paper records after digitisation (SRA) Transfer of System Ownership/Responsibility Recordkeeping In Brief 23 - Managing records in administrative change (SRA) Page 20 of 21

21 NSW Government data and information are managed in a way that enables better service delivery and better value investment. They are Governed Collected Organised Secured as assets of strategic, operational and administrative value to NSW Government agencies; in a manner that is transparent and accountable to NSW citizens and organisations. to document or facilitate delivery of services and the functions of NSW Government agencies; with regard for the privacy of NSW citizens and the confidentiality of NSW organisations; once, according to standards that support relevance, accuracy and consistency so they are reliable, fit for purpose and can be appropriately re-used by NSW Government agencies to improve service delivery or management reporting. described and linked to related data or information, so they are easy for NSW Government agencies to search, retrieve, use and compare; identified and integrated into systems that allow NSW Government agencies to routinely track and manage them according to their value. against unauthorised access, alteration, loss or deletion, to ensure their integrity and ongoing value to NSW Government agencies; using controlled and auditable processes that demonstrate to NSW citizens and organisation the protection of sensitive data and information. Used to support planning, decision-making, resource allocation, reporting, communications and transactions by NSW Government agencies; processed and analysed by NSW Government agencies to develop evidence-based policy and deliver targeted services to NSW citizens and organisations. and re-used, so NSW Government agencies derive maximum benefit from their investment in these assets. Shared Maintained with regard for the privacy of NSW citizens and the confidentiality of NSW organisations; with other NSW Government agencies to reduce duplication of effort, streamline service delivery and provide a consolidated view of customer needs or public sector performance; published and made available for discovery by NSW citizens and organisations, providing opportunities to communicate, consult and collaborate or to engage in value-added processing, analysis and development. using cost-effective, risk-based measures that facilitate business continuity for NSW Government agencies; to ensure their availability and reliability, for as long as they support service delivery and accountability by NSW Government agencies; and then systematically destroyed when their use and value has ceased, to minimise the costs and risks to NSW Government agencies of over-retention; or systematically archived to protect the enduring rights and interests of NSW citizens and organisations. Page 21 of 21

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