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Feedback submitted on Archives New Zealand's Create and Maintain Standard

Your name:	Joanna Newman
Your organisation (if applicable):	Archives and Records Association of New Zealand
Your role in organisation (if applicable):	President
Contact email address:	Joanna.newman@wcc.govt.nz
Contact phone number:	XXXXXXXXX
I am making this submission:	as an individual	on behalf of my organisation a

ARANZ Council has collaborated with its President, who is also Wellington City Archivist, in preparing this submission. It supports the comments made in the Wellington City Council submission and therefore endorses the same feedback being presented on behalf of ARANZ Council.

Specific Comments
Section	Page	Your comment	Your recommendation
Overall		Overall, this is an excellent standard and will be helpful to users. It provides clear guidelines at a level appropriate to achievement of the aims of the Public Records Act, without being overly prescriptive about how organisations should manage their records. We support the introduction of this standard. The wording of Risks means that often they are not a real risk to the organisation, or sometimes just a description of the behaviour/action which will create the risk. Given that the aim of this column is presumably to highlight benefits to the businesses of following the standard, I think it is worth making them a bit stronger in some cases. Many comments below relating to Examples of Risk are therefore aimed at making it clearer what the risk is to the organisation. The glossary could have done with more proof-reading before being sent out. There is also some inconsistency in that some definitions are expanded beyond a simple ‘definition’ to cover how to achieve the state defined by the term.
3.2	13	Bullet point 2 says “provide evidence of compliance with current professional standards”. Two issues with this: a) what is “professional” (records mgt, engineering, architectural etc?) and b) it doesn’t accord with the terminology used in the Executive Summary (“jurisdictional”). Given this contradiction, it’s also not clear what point is being made.	Decide what you mean and use either something like “current national records management standards” or “current legal standards”.
4.5	15	Examples of Risk: “performance cannot be measured” – not a major risk an organisation would worry about.	Suggest rewording to make it a real risk e.g. Lack of awareness of potentially damaging failures of poor record-keeping.
4 Principle2	16	Intro: “facilitate the transaction of business for capture into recordkeeping systems” wording implies that records are made etc for the purpose of capture in a recordkeeping system. They’re not; they made to document decisions etc.	Change to: “facilitate the transaction of business and they should be captured in recordkeeping systems”
4.6	16	Examples of Risk: “A business classification scheme is not comprehensive if not aligned to business activities” – not a major risk an organisation would worry about.	Suggest rewording to make it a real risk e.g. Records cannot be located because they are not classified or identified according to business functions.
4.8	17	Explanation: “ensure core business assets” should be clarified to mean information assets.	Suggest rewording e.g. ensure information, which is a core business asset, is retained in a timely manner

Specific Comments Continued
Section	Page	Your comment	Your recommendation
4.9	17	Examples of Risk: “Resources are wasted in unnecessary duplication of effort” – too vague, what does this apply to, where is unnecessary duplication going on in this specific area?	Delete
4.9	17	Examples of Risk: “Employees not able to meet recordkeeping performance measures” – not a major risk an organisation would worry about.	Suggest rewording to make it a real risk e.g. Employees not able to meet recordkeeping compliance requirements.
4 Principle3	18	Intro: “demonstrate integrity” – not a good verb to use for a record	Suggest changing it to “retain their integrity”
4.10	18	Examples of Risk: “Full and accurate records of business activity are not captured” – real risk to the organisation is the consequences of this.	Suggest rewording to make the risk clearer e.g. Records documenting decisions and actions are not available because they were never captured.
4.10	18	Examples of Risk: “Business decision making is not fully informed” – could be strengthened	Suggest rewording to make it stronger e.g. Bad business decisions are made because decision- making is not fully informed or is based on unreliable information.
4.11	18	Requirement: “Records must have reliability and integrity . . .” – all principle 3 requirements are about reliability, so I think this point should focus on integrity.	Delete “reliability and”
4.11	18	Examples of risk : add one from 4.10, because it is also a risk here.	Suggest adding: Bad business decisions are made because decision- making is not fully informed or is based on unreliable information.
4.13	19	Examples of Risk: “Full and accurate records of business activity are not captured” – real risk to the organisation is the consequences of this.	Suggest rewording to make the risk clearer e.g. Records documenting decisions and actions are not available because they were never captured.
4.14	19	Explanation: “. . . level of detail to document an activity fully.” – use of the word “fully” could imply that every tiny detail about an activity must be recorded. Could be clarified.	Suggest rewording e.g. Records must be created to the extent required to document key processes, decisions and actions.
4.15	20	Examples of Risk: “Informational [sic] and records are not managed efficiently or effectively” – real risk to the organisation is the consequences of this.	Suggest rewording to make the risk clearer e.g. Unnecessary costs are incurred through inefficient management of records and information.
4.17	21	Examples of Risk: “Informational [sic] and records are not managed efficiently or effectively” – real risk to the organisation is the consequences of this.	Suggest rewording to make the risk clearer e.g. Unnecessary costs are incurred through inefficient management of records and information.
4.17	21	Examples of Risk: “Business continuity planning is not in place” – real risk to the organisation is the consequences of this.	Suggest rewording to make the risk clearer e.g. Damage to business because business continuity measures are not in place.
4.20	22	Examples of Risk: “Resources are wasted in unnecessary duplication of effort” – too vague, what does this apply to, where is unnecessary duplication going on in this specific area?	Delete
4.20	22	Examples of Risk: “Full and accurate records of important business transactions and activities are not retained” – real risk to the organisation is the consequences of this. (Also similar but slightly-different wording to that used several times earlier – might like to standardise.)	Suggest rewording to make the risk clearer e.g. Records documenting decisions and actions are not available because they were not maintained in an accessible format.

Specific Comments Continued
Section	Page	Your comment	Your recommendation
4.21	23	Examples of risk: Inability to find information necessary to answer official information requests – very similar to the one above, so probably not adding a lot of value. On the other hand, another risk could be added -	Suggest adding: Unmanaged disposal results in high storage costs and retrieval overheads.
App 1	24	Access – definition doesn’t make sense
	24	Classification system: SEE classification	Wrong place – delete. You have both in anyway, so presumably it’s an invalid entry.
	24	Capture – needs a definition; this is a description of the purpose, how to do it etc. Also question whether all the information about how to do it is required here.	Insert something like “The process of ensuring that records are stored in a recordkeeping system”. Reconsider whether all the detail is required.
	24	(Business) classification – do not need “(Business)” in front of it.	Remove {Business)
	25	Classification systems – a) do you need this and the one above? b) if you choose this one, it should be singular like other terms
	25	Comprehensiveness – a) does this need to be covered by a glossary? b) not sure if “comprehensiveness” is used anywhere – have only found “comprehensive” (4.6 pg 16)	Suggest removing
	25	Estray – don’t recall finding mention of estrays	Check and remove if the term is not used in this document.
	25	Integrity – not a definition of integrity; rather a description of how to ensure it.	Like Capture above, requires a definition and consideration of whether this detail about ‘how to’ is included.
	26	Local authority record – “local authority” is defined and “record” is defined, therefore do not need this term.	Delete
	26	Metadata for managing records - Definition includes “creation” therefore term would be better simply as “metadata”; particularly as the term management is used in the definition.	Delete “for managing records”
	26	Migration “SEE conversion” – this term is not in the glossary	Delete
	26	Recordkeeping – this is a definition of good recordkeeping rather than of recordkeeping.	Adjust

General Feedback: Please Evaluate the Standard against its Goals

The standard will support and improve government recordkeeping in New Zealand.

The standard clearly specifies minimum requirements for the creation and maintenance of public records and local authority records under the Public Records Act.

The standard will enable organisations to assess their recordkeeping capability against the Public Records Act requirement to create and maintain full and accurate records.