COVID-19: Disposal authorisation for response records
COVID-19 and the Government's response to it represents a singular event in our nation's collective experience. The records which are now being created will be invaluable in ensuring that the government response is effective, and that government can be held accountable now and over the long term for its decision making. Many of the records will be of long-term historical interest.
As public offices and local authorities seek to operate under the restrictions imposed by the various levels of the COVID-19 lockdown, the information that is potentially being created in makeshift systems and through altered workflows will still need to be properly managed in accordance with the Information and records management standard (16/S1) and current disposal authorities. It is imperative that all reasonable measures are taken to ensure that this information is identified, preserved and classified to support appropriate disposal in the future.
The Association of Local Government Information Management (ALGIM) has also released a statement for local authorities.
Current disposal authorisation
Your organisation’s current disposal coverage will be provided for through the:
Disposal Authorities (DAs) issued for specific public offices
General Disposal Authorities (GDAs) which can be applied across government, or
disposal schedules that have been adopted by individual local authorities.
If an organisation has records that are not covered by one of these authorities or schedules, then those records must be retained.
The GDAs and their classes have an intentionally broad scope, which allows them to be applied to records created under a wide range of circumstances. The classes and disposal actions outlined in GDA 6 ‘Common Corporate Services Public Records’ (PDF 509KB) are particularly relevant to the information being gathered and the records being created during the COVID-19 pandemic. GDA 6 provides clear disposal actions for records relating to policy, agency planning and reporting, discussion and decision making, as well as internal and external messaging. These are all areas where the retention of COVID-19 related records will be particularly important.
If you have any uncertainty regarding how your organisation should apply any disposal actions to the records being created within this new COVID-19 environment, our Disposal and Acquisition team are available to help you. Please do not hesitate to contact the team .
Implementing disposal authorities
Although the disposal actions authorised through the existing DAs and GDAs allow public offices to make decisions in line with the Public Records Act 2005, this should always happen with proper consideration of the context or circumstances a public office or local authority is faced with. This extends to the unique challenges posed by the COVID-19 pandemic and the Government’s response.
Similarly, it would be advisable for local authorities to account for these same considerations when making their own disposal decisions. Some key principles to keep in mind are:
Retention periods and triggers
These are minimum requirements. An organisation is prohibited from destroying or transferring records before this date but is permitted to retain them for longer if it considers that there are business, legal or other reasons for doing so. COVID-19 related records are likely to meet some, if not all, of these considerations.
Applying DA classes
Each DA and GDA class description will provide examples of the types of records that they apply to. These are only representative of record types and are not intended to be exhaustive. In the wake of the COVID-19 response you are likely to be faced with records which do not match these, or any of your own pre-established examples. In this case it will be necessary to map these new records to an appropriate class. If this is not possible, then they cannot be disposed of and will need to be retained. Such records will need to be identified, appraised and provided with appropriate disposal coverage as soon as practicable.
Inappropriate disposal actions
If you think that records marked for destruction ought to be preserved permanently, do not destroy them. Contact our Disposal and Acquisition team to discuss a re-appraisal of the records.
If public records are lost or destroyed without authorisation, then you should advise Archives New Zealand as soon as possible. We will want to discuss the circumstances of the loss or destruction and to determine the nature of loss.
In these circumstances, and given the significance of the COVID-19 response, we recommend that where there is any uncertainty concerning how and when records should be disposed of, they should be retained. They can be properly appraised or re-appraised at a later date when the appropriate amount of time and consideration can be given to determining the correct course of action.
These are uncertain times and you are likely to be working in an unfamiliar environment and facing a set of new challenges. The information supplied here is intended to provide some guidance to support good information management practices and decision making.
Archives New Zealand is available to answer any questions you may have. Just as importantly, if you have examples which do not easily fit with your existing disposal authorities please share your experience with us. They may prove to be important in helping us support you and others faced with similar circumstances.
Last modified on 30 November 2020