Destroying records as a normal administrative practice
What is a normal administrative practice?
Section 24 of the Archives Act 1983 provides that Commonwealth records can be destroyed:
- as required by a specific law
- with the permission of the Archives using a Records Authority
- or in accordance with a normal administrative practice (NAP).
NAP allows staff to routinely destroy records that are not needed as evidence of their agency’s business and that do not need to form part of its corporate records.
Destroying records as a normal administrative practice is sensible administration. Some records are not needed to document business decisions nor are they significant records of an agency’s business.
Key points to consider in developing your approach to applying a NAP are:
- What is a normal administrative practice for one agency may not be a normal practice for another.
- Deciding what records to destroy using NAP should be done with an understanding of the business context of the records and risks associated with that business.
What is the role of the Archives?
The Archives does not have a responsibility under the Act to approve the destruction of agency records as a normal administrative practice, but it may disapprove agency practices that result in the destruction of records that should have been retained to meet agency business needs.
The Archives recognises that it is vital for agencies to be able to manage their records efficiently as well as accountably, and NAP is an important tool in that process.
The Archives will:
- provide information on the sections of the Archives Act that cover the retention and destruction of records
- produce practical guidelines on ways that the NAP provision can be used by agencies in their ongoing records management
- provide advice to agencies on the development of their own procedures for identifying appropriate normal administrative practice, and on the implementation of these procedures
- ensure that NAA advice and guidelines are reviewed regularly
- provide updates on records management issues that affect the use of NAP.
What is your agency’s role?
Decide and document your policy on using a NAP to destroy records.
Agencies are subject to scrutiny about decisions they make concerning their records. Clearly documented, authorised and readily available policies and procedures assist agencies to explain their actions.These policies and procedures should be endorsed at a senior management level, be issued formally to staff and agencies should provide appropriate training in their use.
Your agency’s procedures on NAP should:
- be consistent with the Archives Act and National Archives guidelines
- be developed with an understanding of the business that the records support and the associated business risks
- integrate with your agency’s business and records management policies
- distinguish between agency records covered by records authorities and those covered by a NAP
- identify, as specifically as possible, the kinds of records to which a NAP can apply in your agency and include examples
- give advice on minimum retention periods
- cover records in all formats including paper and electronic records in all locations within your records environment
- allocate responsibility for the decision to destroy a record using NAP to the individual acting in accordance with the policy and procedures
What kinds of records can an agency apply a NAP to?
Records created and received as part of agency business that are not covered and don’t need to be covered under a Records Authority can be considered for destruction using a NAP.
Records that are or need to be covered by a Records Authority are those that are required:
- for accountability purposes
- to support the ongoing efficient administration of agency business and are linked to community expectations about records providing rights and entitlements
- because they are considered as having cultural or known historical value for your agency.
A gap in your agency’s disposal coverage is not an indicator to use a NAP. Records in the categories listed above that have no disposal coverage must be retained until disposal coverage for them is approved by the NAA under a Records Authority.
Records that are not needed to document your agency’s business and are not in these three categories can considered for destruction as a NAP. They may be duplicate records, or records of a short term, facilitative or transitory nature. Facilitative and transitory records are those that help an action or a process move forward in a specific period of time, but don’t in themselves have any long term value and are not needed to understand the action or process.
Records considered for destruction using a NAP can be arranged into five broad groups. Examples of some specific types of records are listed under each group. Your agency might create or acquire other types of records that fit these groups. These examples apply to records in all formats.
Facilitative, transitory or short term items
- appointment diaries, calendars (excluding diaries used to record important matters or belonging to people holding high level positions, for example an agency head)
- informal communications which do not support, or contribute to the business of the organisation, such as with compliments slips, personal emails, listserv messages
- circulation copies of agency instructions, circulars, internal newsletters, other than master copies
- unsolicited letters offering goods or services
- email in email storage systems (personal or shared drives, email folders for example) that has been captured into a corporate records management system, in either electronic or paper form
- emails sent to multiple recipients, where another recipient has responsibility for capturing the message into a records management system
- emails capturing a continuing discussion where the final email has been captured into a records management system
- unsolicited email (spam)
- computer backup tapes that duplicate an agency’s electronic business transactions as part of a routine IT process
Rough working papers and/or calculations
- routine or rough calculations
- working papers and background notes that support the development of drafts
- spreadsheets or word processing documents that have been incorporated into correspondence or a separate final document
- system printouts used to verify data, or answer ad hoc queries that are not part of regular reporting procedures and not required for ongoing use
Drafts not intended for further use or reference
- drafts in either paper or electronic form of reports, correspondence, addresses, speeches, planning documents etc. that have minor edits for grammar, spelling etc.,
- do not contain significant or substantial changes or annotations, or
- have been assessed as not required to document business activities
Copies of material retained for reference purposes only
- copies of records made for reference purposes, or to support the development of other documents, including summaries or extracts of records held in the agency’s records management system
- duplicates of agency procedures, manuals, guidelines, plans etc., other than master or authorised copies
Published material which does not form an integral part of an agency’s record
- promotional or advertising material received by an agency
- external publications
The NAP checklist is a practical tool that can be used to develop your agency’s procedures on NAP. It provides guidance on specific questions you can ask about a record to help identify if it has any agency business, accountability or cultural value.
Any decision to destroy a record as NAP should be made after considering the context of the business activity that it supports. With this in mind, ask yourself the following questions about the record:
Is the record covered by a specific law or a Records Authority issued by the National Archives?
If not, is the record:
- needed to clarify, support or give context to an existing record?
- needed to show how the agency business was carried out?
- needed to show how a decision was made?
- needed to show when or where an event happened?
- needed because it indicates who made the decision or gave the advice?
- needed because it contains information on the rights or obligations of government or private individuals?
- a formal draft of a Cabinet submission?
- a draft of an agreement or legal document?
- likely to form part of a record that will be needed to support legal proceedings?
If the answer to all these questions is no, then you can consider destroying the record as a normal administrative practice. If the answer to any question is yes, the record should be retained so that appropriate coverage under a Records Authority can be developed.
How do you decide when to use a NAP?
The following flowchart illustrates the process of deciding when you can destroy a record using a NAP.