Your name:

Joanna Newman

Your organisation (if applicable):

Archives and Records Association of New Zealand

Your role in organisation (if applicable):

Vice President

Contact email address:

jonewman@xtra.co.nz

Contact phone number:

XXXXXXX

I am making this submission:

as an individual

on behalf of my organisation X

General Feedback: Please Evaluate the Standard against its Goals

agree

disagree

1

2

3

4

5

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

X

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

X

The standard will enable assessment of storage facilities, including commercial facilities.

X

ARANZ is of the view that on the whole this is an excellent standard and its requirements should be mandatory. It has a concern, however, that many organisations are not going to be able to meet this mandatory standard at July 2007. Archives NZ needs to understand that many organisations will not be able to do, and will require assistance to do so – monetary or otherwise.

The standard will support and improve government recordkeeping in NZ – Possibly in the case of larger institutions. However, the requirements set out in some parts of the standard will represent such a huge leap for some small local authorities and DHBs that it is possible the response to the standard will be to totally ignore it and continue doing what they have always done. Archives NZ needs to think through much more carefully how it is going to work with communities to help them improve the manner in which they manage their records, and in particular their archives. The omission of schools from the standard suggests that Archives NZ understands that there are some communities who will not be able to reach this standard. However, this goes wider than just schools.

The standard clearly specifies minimum requirements for storage…. – No, there are inconsistencies in this respect. This is particularly evident in Principle 4 Environmental Control where the requirements for storage of paper are spelt out in precise detail; however storage requirements for other formats are vague, e.g. Requirement 19. Most organisations which do not have an archive attached will not know what environment is “appropriate” to the format of a variety of different types of records – this information needs to be supplied in the standard for at least all of the formats most commonly held.

The standard will enable assessment of storage facilities…. There is a concern that this may not be possible as there is a great deal which is open to interpretation, and may be interpreted differently by different people. ARANZ questions how much influence Archives NZ will really have over some commercial companies and over organisations’ decisions to outsource storage.

Intro

4

Paragraph 3 includes the sentence “Local authority records which are identified as having long-term value and which are no longer in current use, and all local authority records over 25 years old, become local authority archives.” This presumably is incorrect because it implies that all these records become archives without having been appraised.

Final paragraph includes the sentence “The approval of repositories to hold public archives under section 26 of the Public Records Act 2005 will normally be dependent on progress towards meeting this standard.” This suggests that the standard won’t be fully enforced for approved repositories, though it will be for everybody else. If this is so, what is the rationale for this if they all hold public archives?

Needs rewording to clarify.

Clarify

3

10

The term “treat” risks is used. This is not the usual term for this, and not all risks can be ‘cured’ (i.e. eliminated), which this implies.

Use “mitigation” instead

4

13

Requirement 5 “or moved to an off-site storage facility if that is more cost effective” has nothing to do with the fact that records which are not in active use must be stored in a dedicated storage area. It is redundant, since an off-site storage facility (as intended in this sense) is “a dedicated storage area”. Also, if readers do not assume the off-site storage facility intended here is a specialist store, there is the risk that this implicitly gives permission to store in any shed or warehouse off-site that is more cost-efficient.

Delete “or moved to an off-site storage facility if that is more cost-efficient”.

4

13

The standard says, on page 5, that it covers active records. There is nothing here, however, covering requirements for storage of active records.

Include a requirement to store active records in suitable conditions e.g. Appropriate housing should be provided for records in current use to ensure that they are protected from damage and unauthorised access and accessible.

4

17

Requirement 16 should be broadened to included other records which have access restrictions. Building consent records, for instance, may have restrictions placed on them.

Change wording to “Security-classified records and other records with access restrictions must be identified and protected from unauthorised access. (“in accordance with the publication Security in the Government Sector” is not necessary under the requirement column, because it is repeated in the explanation)

4

18

Requirement 17 wording is a little odd: “Storage areas must be kept clean . . . to keep the area free of food”

Delete “to keep the area free of food” under the requirement. Food is already mentioned in the explanation, but if you want to emphasise it you could add a sentence saying “Food should not be kept in storage areas. Dirt, dust and food encourage . . . “

4

19-20

Requirements 20-23. It is likely that this will not be achievable for many organisations. There is a risk that such organisations will simply ignore the standard and take no action to improve their records storage.

Archives NZ will need to address how it is going to help organisations achieve this standard, since it is mandatory.

4

20

Requirement 24 under Examples of Risk – “inability to access” is a bit unclear when we are talking about environmental conditions for records of short-term value.

Suggest changing to “Damage to records stored in unsuitable conditions”

4

21

Requirement 26 Does this refer to only temperature and humidity? The use of the term “environmental conditions” suggests it is broader; however, the explanation only refers to temperature and humidity.

Either clarify that it is only temperature and humidity, or change the explanation to clarify what is meant by environmental conditons

4

23

Requirement 29 This says that records should be stored as far as possible from natural hazards and then, in the Explanation, says that “Much of New Zealand is vulnerable to earthquakes” etc. Without further explanation, this could be read as though no records should be stored in Wellington, or that one is irresponsible to store records in Wellington. Given that this is a mandatory standard, further explanation is required.

Suggest adding a sentence after the first one to the effect that “Natural-hazard areas which can be reasonably avoided, such as flood planes, should be avoided and every reasonable precaution taken in other areas, such as earthquake-risk areas.”

4

23

Requirement 31 This can be read as meaning that staff should be able to protect and salvage records. This is unlikely for small organisations without specialist staff.

Suggest rewording so that it is clear that they should have a current disaster management plan, know how to put it into action, know basics of disaster recovery but, more particularly, know where to get professional assistance.