From Policy to Practice
A Whole of Government Approach to Records Management in New South Wales 

David Roberts
Manager, Records Management Office 
Archives Authority of New South Wales 

Paper for presentation at an IIR Conference
Electronic Document and Records Management for Corporate and Public Sector Environments
Sydney 5 February 1997
This paper examines the whole of Government approach to records management that is being taken in the New South Wales public sector.  Central to this approach is the development of new State records legislation: the paper provides background about its purpose and the philosophy behind it, as well as an update on the process of developing it and preparing for it.  Central also to the approach are records management standards, notably the Australian Standard on records management, AS 4390.  This paper examines how we are using standards and related documents and products to promote best practice in records management across the New South Wales public sector.  Finally, the paper examines the national nature of many of these developments and notes whole of government approaches in a number of other Australian government jurisdictions.
A framework for records management in New South Wales 
In a paper presented at a conference in 1995, I wrote:
‘A new model for recordkeeping in the New South Wales public sector is emerging. The model is the product of a range of developments in the work of the Archives Authority of New South Wales, among recordkeeping practitioners in the New South Wales public sector and by our colleagues in other jurisdictions around Australia and overseas. In New South Wales we have not sat down and designed a comprehensive and coherent model from the start. Rather we have found that a number of parallel developments — new State records legislation, new strategies for managing electronic records, the push for recordkeeping standards, the continuum approach to managing records and archives, the recordkeeping perspective — are so connected, and contain so many common elements, that they fall together to represent a coherent model with remarkable ease.’
In that paper, I described the model through a set of twelve guiding principles, which are worth briefly noting here:
1.	Recordkeeping in the New South Wales public sector should comply with national best practice 
2.	Recordkeeping systems and practices in the New South Wales public sector should be designed to satisfy identified recordkeeping requirements
3.	Recordkeeping in the New South Wales public sector should be systematic
4.	Recordkeeping in the New South Wales public sector should be managed
5.	Recordkeeping in the New South Wales public sector should be responsible
6.	Recordkeeping in the New South Wales public sector should be routine
7.	Recordkeeping performance in the New South Wales public sector should be monitored and measured
8.	Recordkeeping practices in the New South Wales public sector should be based on an understanding of what records are and do
9.	Records in the New South Wales public sector should be captured and maintained as records
10.	Records in the New South Wales public sector should be managed under a coherent regime throughout their existence
11.	Maintaining, managing and providing access to electronic records over time in the New South Wales public sector is a shared responsibility
12.	The role of the Archives Authority should be to steer, rather than to row.
Today I want to present the model in a different way, by showing in a graphical form the relationship between the various standards, guidelines and other products — along with the Government policy and legislation that they are intended to support — making up the whole of Government framework being developed for records management in New South Wales.

Figure 1: Whole of Government framework for records management in New South Wales 
In this model, policy refers to Government policy applying across the New South Wales public sector.  Our two draft electronic recordkeeping policies, on Electronic Recordkeeping and on Electronic Messages as Records, as well as the Australian Archives’ draft policy on management of records and information for the Commonwealth Government, are examples of policy in this sense.  Thus, records legislation is an instrument for achieving the government’s policy objectives for records management and derives from them.  
We use standards here to refer to the type of standard that is mandatory, measurable and, therefore, subject to a regime of compliance auditing.  Two standards already drafted in preparation for the new legislation — the draft Standard on Full and Accurate Recordkeeping and the draft Standard on Records Management Programs — are examples of this type of standard.  
By contrast, we use codes of best practice to refer to the type of standard that codifies and describes best practice, functioning as a benchmark against which an organisation can measure its practices and systems.  While we do not expect a formal audit regime to apply to the codes of best practice, failure to comply would leave an agency open to criticism in an investigation where recordkeeping practices were an issue.  In New South Wales we are treating Australian Standard AS 4390 as a code of best practice in this sense.  Both the standards and codes of best practice in this context will derive their authority from the new State records legislation. We will return to the legislative situation in New South Wales shortly.
Guidelines and manuals represent a means of providing practical guidance in support of the standards and codes of best practice.  A number of our existing publications fall into this category, while others are in the pipeline.
Training, services and support provide further guidance and assistance to agencies and their staff for practical application.  This category includes not only the regular training courses and customised training services offered jointly by the Records Management and Archives Offices, but also the bulk records storage and related consultancy services that are offered on a more commercial basis by the Government Records Repository, another branch of the Archives Authority.  We are now adjusting the content of our program of records management training to focus on best practice as embodied in the standards and codes of best practice, especially AS 4390.
At this level of the model, we need to be especially carefully about how much we want to ‘steer’ and how much to ‘row’.  Thus, for example, a policy objective is to have a skilled records management workforce in the New South Wales public sector.  We can approach this by encouraging agencies to employ staff with records management qualifications to work in their records units and by sponsoring and promoting continuing education and training opportunities in records management for agency staff (these are ‘steering’ activities).  While we can continue to provide regular and customised training courses (this is more in the nature of ‘rowing’), we do not necessarily have to do so in order to achieve the policy objective, particularly if high quality short course records management training is available from other sources.
We have used a pyramid shaped model partly to emphasise that we see the bulk of our effort and energy being directed to the bottom layers.  While the upper layers establish the rules, our primary role will be to provide the guidance and other assistance needed by New South Wales Government agencies to comply with the rules and, thereby, achieve the improved records management outcomes that the Government seeks.
New State records legislation
Many of you will be aware that new State records legislation, to replace the Archives Act, No. 46 of 1960, is in preparation.  While this sometimes seems an interminable process, especially to those of us involved in it, the light at the end of the tunnel is growing inexorably brighter.  At the time of writing, a draft Bill had been circulated to those agencies who raised issues in response to the Cabinet Minute of 1995.  We held meetings with those agencies in November 1996 and a revised draft Bill was to be circulated more broadly, including to professional bodies and other interested parties, for further comment in the early part of 1997.
One of the distinctive features of the draft legislation is that it takes a ‘continuum’-oriented approach, having an impact on the making and keeping of records in New South Wales Government agencies and on their management as current records, as well as on the management of records identified as State archives, which has been the traditional focus of government records legislation. 
Thus, key provisions of the draft Bill require ‘public offices’ to:
•	make and keep records that fully and accurately document their operations and administration, and 
•	establish and maintain a records management program to be managed in conformity with standards and codes of best practice formulated by the (new) State Records Authority.
In preparation for the new legislation, we have drafted two of the key standards that need to be ready when the legislation comes into operation.  Exposure drafts of these two standards, on Full and Accurate Recordkeeping and Records Management Programs, respectively, were released for comment in May 1996 to major New South Wales Government agencies and to interested parties outside the New South Wales public sector.  We also undertook substantial work on standards and associated guidelines for records storage and for the management of records of joint (particularly inter-government) bodies.
The two draft standards are intended to sit in the third level of the pyramid model and to contain overarching principles from which the remaining standards, codes of best practice, guidelines and other materials will flow.  Together they are intended to represent authoritative statements of the responsibilities of agencies in relation to records and records management under the new legislation and of the means of meeting these responsibilities.  They and the subsequent documents are based on national and world best practice and are being developed in consultation with government records authorities and other relevant bodies around Australia.  The whole standards regime under the new legislation will be introduced progressively following consultation with the central and other New South Wales Government agencies as part of the implementation of the new legislation.  Where possible, we expect to adopt, endorse or adapt existing standards, guidelines and other best practice documents.  
Standards for records management 
The work of the Archives Authority in developing records management standards for the New South Wales Government is part of a broader movement around Australia, and indeed the world, to make better use of standards to achieve improvements in records and archives management within individual organisations and across jurisdictions.  
Some of the recent Australian developments in this movement have included:
•	the release in February 1996 of Australian Standard AS 4390, Records Management
•	the Records Management Policies and Standards Manual issued by the (now) Public Records Office in Western Australia to government agencies in 1992.  The PRO continues to issue new documents regularly and the manual represents an excellent model of its kind
•	the Australian Archives’ Documentation Standard project established at the beginning of 1995.  Despite its initial emphasis on the documentation of government business (ie. ensuring the creation and capture of records to support accountability), the project has evolved into a broader records management endeavour
•	the work of the Australian Council of Archives’ Sub-Committee on Standards and Guidelines, notably in developing a common position statement on electronic recordkeeping, in conjunction with the Council’s Electronic Records Committee
•	ongoing work on the Australian Common Practice Manual (‘ACPM’) covering archival descriptive practices, and
•	the release by the Commonwealth Government’s (then) Information Exchange Steering Committee, and subsequently by the Office of Government Information Technology, of guidelines for managing electronic documents in the Australian Public Service.
All of these examples have involved developing some kind of standards document which variously sets rules, describes best practice or promotes common approaches.  Another aspect of records management standards has been the adoption of common records management software across whole jurisdictions.  In South Australia, a whole of Government approach to records management has included the purchase of a whole of Government licence for the RecFind records management software product.  In New South Wales, two such products, RecFind and TRIM, were successful in a tender process to be placed on State Government contract.  At the time of writing, a tender process for the Commonwealth Government, run through the Office of Government Information Technology, was well advanced.
While each of these exercises has involved a different approach in some respects, they share the objectives of producing efficiencies through the use of common application software across a whole government and of influencing records management practices through the use of common technological tools.  In a recent letter to the editor of the Informaa Quarterly, the journal of the Records Management Association of Australia, I described our specifically records management objectives for the NSW exercise, which I am sure apply equally in the other exercises, in the following terms:
‘The Archives Authority strongly supported the records management exercise and, through the Records Management Office, took an active part in it.  From our point of view, there were additional benefits to be gained, besides the Government’s overall objectives.  The use of a less diverse range of records management software will contribute to a consistent level of best practice in public sector agencies: while software and the practices they support are two different things, there is no doubt that the adoption of the right software influences and promotes good records management practices.  Reducing the number of records management products in use should also help make records management skills more transferable across the New South Wales public sector.’
We can contribute to the same objectives by adopting other common tools.  The Archives Authority’s thesaurus of general terms, Keyword AAA, which was developed first and foremost for the New South Wales Government, is becoming something of broader public sector standard, having been adopted as the standard general records management thesaurus in South Australia and Western Australia.
Australian Standard AS 4390, Records Management 
The best known, and probably the most important, of the recent records management standards developments in Australia has been the release in February 1996 of Australian Standard AS 4390, Records Management.  I have discussed the background and some of the principal features of the Standard in other places and propose today to focus on a couple of specific aspects of its role in the New South Wales Government.
Firstly, how does AS 4390 fit into the whole of Government framework that I described above?  AS 4390 was designed and issued as a voluntary code of practice and has no associated certification mechanism of the type used with the ISO 9000 quality systems standards.  While it contains some useful self-assessment tools, notably a ‘Check List for Performance Testing of Records Management  Systems’ (Appendix C to Part 3, Strategies), and can certainly be used as a benchmark, its essential role is to describe best practice.  
Consequently, we place it at the code of best practice level in our pyramid model.  This means that agencies will not be audited for compliance with AS 4390 — in its current form, this would not be a practical possibility in any case — but will be expected to implement it as the basis of records management best practice, just as Government expects agencies to adopt best practice in other aspects of their business and administration.  As I noted above, failure to comply with best practice as described in the Standard would leave an agency open to criticism in an investigation, such as a Royal Commission or ICAC investigation, where recordkeeping practices were an issue.  We will certainly seek evidence from agencies about how and how much AS 4390 is being implemented and used across the Government.
I would also note at this stage that our two draft key standards were developed in parallel with our involvement in the preparation of AS 4390 and were intended from the start to complement it.  As I will discuss further below, much of the guidance we provide in the form of training and are developing through manuals and other materials flows from AS 4390 and is intended to support the implementation of the best practice that it describes.
Giving AS 4390 a formal place in our framework as a code of best practice depends for its authority, like the draft standards, on the passage and proclamation of the new State records legislation.  In the meantime the Archives Authority has endorsed AS 4390 as the benchmark for records management in the New South Wales public sector.  At its February 1996 meeting, the Authority adopted the policy that, pending the issue of standards and codes of best practice under the new legislation, agencies should seek to comply with the Australian Standard.  During this period, agencies should expect their records management performance to be judged against the Standard. 
The other aspect of the Australian Standard that I wish to address is the methodology for designing and implementing recordkeeping systems which appears in Part 3.  This methodology has its origins in a model developed at a workshop, ‘Understanding Recordkeeping Systems’, led by David Bearman at Monash University in May 1993.  The methodology described in the Standard, and summarised in the Figure 2, develops that model considerably and borrows heavily from systems design methods.
The methodology is particularly useful for designing recordkeeping systems in the electronic environment and has been adopted in the policy and strategy approaches developed for electronic recordkeeping in both the Commonwealth and New South Wales Governments.  Nonetheless, it is designed to be applied in paper-based and mixed environments, as much as in the electronic environment.  
In New South Wales, the Archives Authority has used the methodology as a basis for structuring two training courses, the two day Designing and Implementing Recordkeeping Systems (‘DIRKS’) and the five day Introduction to the Management of Recordkeeping Systems (‘MORKS’), which we have run in partnership with the School of Information, Library and Archive Studies at the University of New South Wales.  We have started work on a ‘DIRKS’ manual, fleshing out the methodology, which will tie together much of the practical guidance that we want to provide in support of the standards and codes of best practice.

Figure 2: Summary of methodology for designing and implementing recordkeeping systems described in Part 3 of Australian Standard AS 4390
I would like to focus briefly on two of the stages in the methodology.  The analysis of business activity stage is an important one in providing a basis for much of the rest of the process and, indeed, for a range of records management activities.  The analysis of business activity produces a classification scheme that serves multiple uses: 
•	for the conventional purposes of developing thesauri and titling and indexing records (described in Part 4: Control)
•	for appraising and sentencing records (described in Part 5: Appraisal and Disposal), and
•	for determining what records need to be generated to document different functions and activities (described in Clause 8 of Part 3: Strategies).  This is a part of the concept of appraisal in the Standard.
In New South Wales, the Archives Authority has sought to use this approach in two of our recent projects.  Keyword AAA, our general records management thesaurus is based on common agency functions and activities, not on subjects.  Our General Records Disposal Schedule: Administrative Records, released in 1996, uses Keyword AAA’s function and activity structure and describes the records in terms of the functions and activities that they document.  
In many ways these approaches are not new: records managers and archivists have been appraising and describing records in terms of their functions for many years.  Rather we are now recognising them explicitly and building them systematically into our methodologies and tools.
The identification of recordkeeping requirements stage is also particularly worth noting.  From the systems development point of view, this is where we identify the requirements that the recordkeeping system, and indeed the records themselves, must satisfy. Again there is much that is familiar in records management practice involved in this stage. Thus, determining how long a class of records needs to be retained — the traditional focus of appraisal — is a matter of identifying what requirements, internally and externally driven, exist for their retention.  
At the same time, we identify other recordkeeping requirements —what records need to be generated, what records need to be made accessible, what records need special protection from unauthorised access, vital records requirements — and the sources from the different requirements derive.  The full set of recordkeeping requirements provides the benchmark against which to measure existing information and recordkeeping systems and for designing the new recordkeeping system.
A national perspective
In this paper I have focused on the whole of Government approach to records management that is being taken in the New South Wales public sector, primarily through new legislation and a regime of standards, codes of best practice and supporting documents and services.  I have noted a number of specific developments that have taken place in the same period in other government jurisdictions and have emphasised the collaborative and national nature of much of the work involved.
To finish, I want to highlight evidence from three recent sources which gives an indication of the importance of whole of government approaches to public sector records management in the future.  The following extracts are all from external reviews of government archives programs where the nature of their roles in relation to records management has been a significant issue.
In Victoria, the Public Accounts and Estimates Committee of the Victorian Parliament undertook an inquiry into the Public Record Office during 1995 and 1996, publishing their report in October last year.  Among other recommendations, the Committee recommended that:
‘4.1	the State manage its public records through the development of “best practice” procedures;
4.2 	the Public Record Office develop standards for the care of each record from creation;
4.3 	model records management systems, integrating the standards process, be prepared and released by the Public Record Office;
4.4 	a disposal schedule be agreed between each agency and the Public Record Office as a matter of urgency
4.5 	the government develop, with the Office of Training and Further Education and the Public Record Office, an education program for all public sector records and information managers.  That the program be structured to the broad needs of every government agency, from the largest to the smallest;
4.6 	responsibility for implementing sound records management practices be shared between agencies and the Public Record Office, and
4.7 	each agency be required to appoint a senior officer, skilled in archives and information management, to implement an effective records management system.’
In Western Australia, the Office of the Auditor General undertook a performance examination of the management of public records, releasing its report also in October 1996.  The Report recommends, among other things, that the Government should:
‘revise and update legislation that makes clear provision for the management of public records’
and that agencies should:
‘…develop and promulgate standards for records maintained on electronic media including guidelines for 
•	document naming, reflecting the records’ content
•	security
•	accessibility
•	long term maintenance of media 
•	media obsolescence
•	retention and disposal
•	custodianships’
and:
‘…inform all staff of their responsibilities in respect of public records and provide training where necessary’.
The Australian Law Reform Commission has started a review of the Commonwealth’s Archives Act, 1983.  As a part of this process the Commission released an issues paper in December 1996 which suggest a range of principles on which an effective archives system should be based.  These include the following:
‘(1)	The effective conduct of the affairs of the nation and its citizens will always depend on the creation, maintenance and accessibility of comprehensive records in reliable and enduring systems
(2)	There is a single record-keeping continuum embracing the creation, management and disposal or archiving of records.  This continuum should be sanctioned legislatively.
(3)	At a policy level, management of Commonwealth records should be the responsibility of a single mind capable of taking an informed view of the entire process from creation to disposal or designation as archival records.
(4) 	Clear rules and standards are needed to ensure the creation, management and preservation of accurate and reliable records for as long as they are required for business, social or cultural purposes.’
While I am conscious that I have presented these extracts out of their context and that there are important differences in the purpose and status of each of the documents (and certainly my use of these extracts is not intended to imply criticism of the institutions concerned or of their programs), they reflect many of the themes in the approach that I have described being taken in New South Wales.  In particular they show that important stakeholders outside the recordkeeping professions recognise the need for a whole of government approach — encompassing legislation, standards, guidance, training, tools and the active collaboration of agency records managers and the government records authority — to translate government policy into agency practice.

Bibliography
Australian Standard AS 4390, Records Management, February 1996
David O. Stephens and David Roberts, ‘From Australia: the World’s First National Standard for Records Management’, Records Management Quarterly, Vol. 30, No. 4, October 1996, pp. 3–7, 62
Archives Authority of New South Wales 
(All in ‘Policy and Standards’ section of the Authority’s World Wide Web site at http://www.records.gov.au)
Recordkeeping Best Practice in the Public Sector, June 1995
Documenting the Future: Policy and Strategies for Electronic Recordkeeping in the New South Wales Public Sector, June 1995
Draft Policy on Electronic Recordkeeping (Revised draft, June 1996)
Draft Policy on Electronic Messages as Records (Revised draft, August 1996)
Draft Standard on Full and Accurate Recordkeeping (Exposure draft, May 1996)
Draft Standard on Records Management Programs (Exposure draft, May 1996)
Other organisations
Public Record Office (Western Australia), Policies and Standards Manual: Records Management, 1992 and updates
Australian Council of Archives, Corporate Memory in the Electronic Age: Statement of a Common Position on Electronic Recordkeeping, May 1996 (available from the ACA; also on the World Wide Web at http://www.aa.gov.au/AA_WWW/ProAssn/ACA/ACA.HTM)
Parliament of Victoria – Public Accounts and Estimates Committee, Inquiry into the Public Record Office, Victoria: Report to the Parliament, October 1996
Office of the Auditor General (Western Australia), For the Public Record: Managing the Public Sector’s Records, Report No. 6, October 1996 (available on the World Wide Web at http://www.audit.wa.gov.au)
Australian Law Reform Commission, Issues Paper 19: Review of the Archives Act 1983, December 1996