You need to identify and think about:
- what records are involved in the machinery-of-government (MOG) or administrative change
- how the records are stored
- how they are to be transferred
- the format they are in
- if specific software, hardware or equipment are required to access the records
- if business systems need to be split, merged, or transferred to ensure that all records remain usable
- any issues impacting on what records can be transferred and how, including differences between recordkeeping practices
- how records will continue to be managed.
Discuss potential challenges or considerations with the team leading the change.
Table of contents
To identify the records, look at the legislation or legal instrument enabling the change to find out what functions are involved, and instructions for the transfer of specific records.
Note: Under the Public Records Act 2002, if legislation specifies the transfer of functions between public authorities, the records must be transferred as well.
Identify the core records that document the function being transferred and requirements for their continuing management.
Also consider administrative or supporting records associated with the function.
If your agency is closing or amalgamating with another, all of your records will need to be identified.
- hardcopy, physical and paper-based records
- digital records stored on a shared drive or within an eDRMS, business system or database, including emails–you will need to identify all components of digital records
- inactive, closed and legacy records
- administrative records such as finance, payroll or personnel records associated with the function that may be required, particularly if the function is going to be continued by another authority
- records in other formats (e.g. plans, photos, microfilm, contacts databases)
- records held in secondary or off-site storage, or at QSA–the receiving agency will need to know they will become responsible for these records even though the actual records are not transferred
- websites or documents on websites managed by your agency that relate to the function(s) involved
- latest backups of digital records or databases
- control records (e.g. indexes, registers) and any metadata that ensures the continuity of the record over time and documents their administrative history
Note: Control records and metadata about the records may be stored with the records or separately.
You will also need to consider and identify:
- which records are required for the continuation of business (e.g. vital and core records) will need to be transferred first
- equipment, hardware or business systems needed to manage, access and use records
- the classification scheme and retention and disposal schedule associated with the records
- any specific storage requirements for the records (e.g. storage space, environmental controls)
- the retention periods that apply and any sentencing information, particularly if their retention period has expired and they can be destroyed
- any issues preventing the transfer of records and which records are impacted.
Use your agency’s business classification scheme and retention and disposal schedules to identify all the records involved. You can also do a business process analysis of functions to see what records are created and used in their delivery.
Consult with your records manager, the relevant business unit managers, data owners and IT people to make sure you identify all relevant records.
Your agency’s legal team can help you confirm that the records identified fall within the scope of changes described by the legislation or legal instrument enabling the change.
Find out what to do if records can’t be transferred.
Ensure records can continue to be usable and accessible for their full retention period, both during and after the change.
Moving records increases the risk of records, metadata and control information being lost, damaged, and/or corrupted.
If records are to be migrated, you should include risk mitigation in the migration plan.
You can include provisions in the agreement to ensure records are transferred, managed and stored in a manner that preserves their usability and accessibility.
Find out about checking records post-transfer.
Usability of physical records:
Check with the receiving agency that the filing system, filing structures, control records and any metadata that goes with the records can be transferred with minimal risk.
The receiving agency should also have appropriate storage for the records and the ability to manage them appropriately. They will need to be able to ensure records remain complete and reliable post-transfer.
Keeping digital records usable
Digital records rely on various systems, software, and metadata/control records to be usable.
Involve the IT teams of both your agency and the receiving agency when planning the transfer to ensure digital records will remain usable post-transfer.
You will need strong quality assurance processes in place to ensure all information can be and is transferred.
To identify potential issues, ask:
- Is there any technology, applications, software, hardware, equipment, or business system you need to access or use the records? Does the receiving agency have a compatible operating system to support the required system, including licenses?
- Can records be exported or extracted from business systems or are they reliant on that system to remain usable?
- Is there anything connected to the records, or business systems, that influences their usability? Will this also be available in the new agency’s IT environment?
- Are there any specific or unique file formats that need special support or software? Are these formats already in use by the receiving agency? Does a conversion need to be done before transfer?
The receiving agency will need to consider where and how the records are going to be stored and managed post-transfer.
Identify why records cannot be transferred completely or at all. This may include:
- technological issues
- differences in recordkeeping systems
- the inability to split or separate records of a particular function from others
- the type of MOG or administrative change.
Records may not be able to be transferred if they are in a database with records of other functions and can’t be exported or extracted to be transferred, or the receiving agency is unable to take a copy of the database because they don’t have compatible technology to support it.
All attempts should be made to ensure records can be transferred to the successor agency, either at the time of the change or later when issues have been rectified.
While legal responsibility for records may transfer, the management of the records can be outsourced back to your agency until the records can be transferred, legally destroyed or transferred to QSA. Make sure suitable access arrangements and delegations are in place.
Discuss with the receiving agency what to do with the records that can’t be transferred, including the resulting custody, responsibility and access issues. Make sure decisions are documented and included in the agreement.
Find out about custody, ownership and responsibility for records.
Note: If your agency is closing or amalgamating with another agency, all records must be transferred.
If any records involved are in the custody of QSA, you may need to determine:
- who needs access to these records
- if responsibility for these records is changing.
If responsibility for these records is changing, you need to:
- notify QSA who the responsible public authority for those records will be
- let the successor public authority know they will be inheriting these records.
Identify any records related to the function in off-site or secondary storage.
If multiple organisations need records in off-site storage, consider what access arrangements need to be in place to allow that.
If responsibility is changing and records need to be transferred, you can:
- retrieve the records to be checked and prepared for transfer
- ask the storage provider to pack and transfer the records for you
- arrange with the receiving agencies and the off-site storage provider to amend or change the existing arrangements so responsibility and associated costs are transferred.
Note: If records are not retrieved first, consider if you need the storage provider to check the records for you before transfer.
You may need to sentence records before transfer.
Find out if the records involved are covered by a current authorised retention and disposal schedule.
Records covered by a schedule should be sentenced to determine their retention status (permanent or temporary) and how long they need to be kept. If possible, do this before they’re transferred and include this information in the transfer list.
Note: If records have already been sentenced, decide if you need to check the sentencing information or re-sentence, particularly if the relevant schedule has changed.
Permanent records should not be transferred to a private entity indefinitely. Consider options to allow access to permanent value records.
Find out how long temporary records need to be kept and how long they have left of their retention period.
If records have reached the end of their retention period, consider destroying them before transfer to reduce the number of records. You will still need to conduct standard pre-destruction checks and keep destruction documentation.
Consider providing copies of this destruction documentation to the successor public authority, especially if they’re taking on the associated function.
Note: If responsibility for the records has transferred to the new receiving or successor public authority, you will need endorsement from their CEO or delegate to destroy records.
A transfer list is a detailed list of the public records that are to be transferred.
You can create the transfer list from the information gathered when identifying the records involved.
- file title or description of the records–this can be each series or records of a particular activity
- format (e.g. paper or digital, microfilm, images, maps, plans)
- volume (e.g. how many or how much space)
- date range for that series
- where they are stored (e.g. off-site with a storage provider or at your agency)
- sentencing information (e.g. disposal action, retention period), if applicable.
The relevant business unit managers or data owners will need to sign off on the transfer list to confirm it is correct, that all records are included and that the records relate to the function(s) involved.
Your agency’s CEO or authorised delegate will need to endorse the transfer of records. This can be done through the transfer list and the sample transfer memo .
Provide a copy of the list to the receiving organisation to help them plan for the transfer, and make sure all records are received.
Keep a copy for your own accountability and to document the disposal of records.
See our Records transfer list template that you can use to create your own transfer list.
Records should be closed before transfer.
Make a note of the change in the metadata–this is part of documenting the history of the record and establishes a clear delineation between your agency and the new one.
Note: If the function is continuing, new files can be created and linked to the closed files to maintain the records’ history.
Physical records should be securely packed in labelled boxes with contents lists included.
Ask your IT team for help to transfer any digital records, associated metadata, business systems, equipment and software.
If business or IT systems are being decommissioned or transferred between agencies, see our advice on managing public records when decommissioning business systems. You may also need to contact QGCIO to discuss this.
- Store, protect and care for records
- Digital record formats
- Migrate digital records
- Manage records when decommissioning business systems
- Provide access to records during a MOG or administrative change
- Custody, ownership and responsibility for records
- Successor public authority