WT67-2
Administration Policy:
Information Management
Classification:
Administration Policy
First Issued:
2023
Dates of Review:
Version Number:
1
Objective ID:
A3211029
Next Review Due:
2028
Applicable Legislation:
State Records Act 1997 (SA)
Freedom of Information Act 1991 (SA)
Local Government Act 1999 (SA)
Evidence Act 1929 (SA)
Copyright Act 1968 (Cth)
Libraries Act 1982 (SA)
Privacy (Tax File Number) Rule 2015 (Cth)
Archives Act 1983 (Cth)
State Records Information Management Strategy
State Records Information Management Standard
State Records Information Governance Guideline
State Records Minimum recordkeeping metadata
requirements standard
State Records Transfer of Official Records Standard General Disposal Schedule for Local Government (
GDS40)
General Disposal Schedule for Local Government (
GDS21)
Related Policies or
Customer Complaints Policy
Corporate Documents:
Employee Code of Behaviour
Elected Members Records Management Policy
Libraries Policy
Information Technology and Its Use Policy
Associated Forms:
Note:
Responsible Manager:
Manager Information Services
Confirmed by General
General Manager
Date
23 February 2024
Manager:
Corporate and Compliance
Approved by Executive:
Date
11 June 2024
City of West Torrens Administration Policy – Information Management
Administration Policy – Information Management
Table of Contents
1.
Introduction................................................................................................................... 3
2.
Purpose.........................................................................................................................3
3.
Scope............................................................................................................................ 3
4.
Definitions..................................................................................................................... 3
5.
Principles.......................................................................................................................5
6.
Roles and responsibilities............................................................................................. 7
7.
Information management.............................................................................................. 8
Objective ID A3211029
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City of West Torrens Administration Policy – Information Management
1.
Introduction
1.1
The City of West Torrens (CWT) is committed to applying a consistent approach to the
provision of corporate information to the right person at the right time and in a usable form
to facilitate situational understanding and informed decisionmaking and to meet regulatory
reporting requirements.
1.2
The CWT values information as a core strategic asset and wil govern and manage it
throughout its lifecycle so that it contributes to better performance of business activities,
improved customer service and risk mitigation.
1.3
This policy reflects the approach that State Records of South Australia takes to managing
information, in that the focus is on treating information as an asset and ensuring that it is
trusted, authentic, reliable and accessible.
2.
Purpose
2.1
This policy establishes the principles and behaviours expected in managing the CWT's
information assets to achieve business objectives and to meet legislation and policy
obligations.
2.2
The appropriate management and control of information assets is crucial for the effective
delivery of the CWT's functions and services. Good information management practices
support evidencebased decisionmaking and accountability.
2.3
Effective management of information assets supports innovation and service delivery,
enabling the community to transact with the CWT and stay informed of Council decisions.
3.
Scope
3.1
This policy applies to al CWT employees, volunteers, workexperience students, students
on placement, contractors who access the CWT's information assets and agency staff who
provide services to the CWT.
3.2
This policy applies to al information assets that are col ected, processed, used, stored and
disposed of in the conduct of official business.
4.
Definitions
4.1
Access refers, in the context of this policy, to the ability to view, inspect or obtain a copy of
an information asset.
4.2
Archives refers to information that is no longer required for current use but is being
retained permanently because of its historical or significant value.
4.3
Collection includes gathering, acquiring or obtaining personal or sensitive information from
any source and by any means. This can include col ecting information inadvertently.
4.4
Consent means voluntary agreement to an act, practice or purpose.
4.5
Copyright refers to the exclusive right that an owner of intel ectual property has over
material that they have created. It protects written works, computer programs, dramatic,
artistic or musical works, sound recordings or broadcasts. It does not protect ideas,
concepts, styles or techniques.
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City of West Torrens Administration Policy – Information Management
4.6
Disclosure relates to providing information to an external person, organisation or
stakeholder. It does not include providing an individual with information about themselves.
4.7
Disposal, in the context of an official record,
means to:
destroy or abandon the record;
carry out an act or process as a result of which it is no longer possible or reasonably
practicable to reproduce the whole or a part of the information contained in the record;
or
transfer or deliver ownership or possession of or sel the record, or purport to do so.
Disposal must occur in accordance with a relevant disposal determination. Disposal does
not include the transfer or delivery of the record to State Records or between the CWT and
another agency.
4.8
Disposal determination is a decision made or direction given by State Records about
whether, when or how official records can be disposed of. General disposal schedules are
an example of a disposal determination.
4.9
EDRMS means Electronic Document Records Management System.
4.10
Information asset refers to information, data and records in any format (whether digital or
hard copy) that is created or received through the conduct of council business.
4.11
Information Management refers to the CWT’s Information Management team.
4.12
Metadata means
details that accompany a record such as its date, author, document
number, description and responsible officer. Metadata maintains the authenticity, integrity
and reliability of records by uniquely identifying them and giving them context and structure.
4.13
Official record means a record made or received by the CWT in the conduct of its
business, but does not include:
a. a record made or received by the CWT for delivery or transmission to another
person or body (other than an agency) and so delivered or transmitted; or
b. a record made by the CWT as a draft only and not for further use or reference; or
c. a record received into or made for the col ection of a library, museum or art gal ery
and not otherwise associated with the business of the CWT; or
d. a Commonwealth record as defined by the
Archives Act 1983 (Cth), as amended
from time to time, or an Act of the Commonwealth enacted in substitution for that
Act; or
e. a record that has been transferred to the Commonwealth.
4.14
Personal information means information or an opinion (including that which forms part of
a database), whether true or not, and whether recorded in a material form or not, about an
individual whose identity is apparent, or can reasonably be ascertained, from the
information or opinion.
Personal information can include:
written records about a person,
photographs or images of a person,
information about a person that is not written but is under the CWT's control.
Personal information does not include:
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City of West Torrens Administration Policy – Information Management
publications that are general y available to the public,
materials kept in public records and archives (such as State Archives),
anything kept in a library, art gal ery or museum for the purpose of reference, study or
exhibition.
This policy notes that the CWT, as a local government authority, is exempt from
responsibilities under the Australian Privacy Principles set out in the
Privacy Act 1988 (Cth).
4.15
Record means:
a. written, graphic or pictorial matter; or
b. a disk, tape, film or other object that contains information or from which information
may be reproduced (with or without the aid of another object or device).
4.16
Records management means the efficient and systematic control and maintenance of
records, including the safeguarding of their integrity, authenticity and useability, and
includes the manner in which records are created.
4.17
Registration refers to capturing or recording an information asset in a repository (such as
an information asset register or corporate records system).
4.18
Sensitive information can include any information or an opinion about an individual's:
race or ethnicity,
political opinions,
memberships, including those of a political association, professional or trade
association or a trade union,
religion, beliefs or affirmations,
philosophical beliefs,
sexual preferences or practices,
criminal record,
health,
genetics.
4.19
Source record refers to an original hardcopy document.
4.20
State Records means the Office of State Records established under the
State Records Act
1997 (SA).
5.
Principles
5.1
The management of the CWT's information assets is based on five principles:
Principle 1: The value of information is known
5.1.1 Information is treated as an asset; its value to enable business activities and
functions, both current and future, is determined, understood and leveraged to
improve business outcomes.
5.1.2 The CWT wil endeavour to:
identify and document what its information assets are, where they are stored
and who is responsible for their management;
understand and document how its information assets support its business
objectives and operations or compliance obligations;
ensure information assets are linked to business functions and activities;
induct and train employees in the value of information and in their
informationmanagement responsibilities; and
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City of West Torrens Administration Policy – Information Management
foster an organisational culture that values and manages information as
anasset that supports business objectives and activities.
Principle 2: Information assets are created and managed appropriate to risk
5.1.3 The CWT understands what information needs to be created and kept to support
business objectives, meet compliance obligations and mitigate risk.
5.1.4 The CWT wil endeavour to:
analyse and document what information assets must be created andmanaged
applicable to the regulatory environment in which it operates;
develop and issue policies and procedures outlining how information
assetswil be managed;
assess the risks of not creating or managing information assets where thereis
a legal, evidential, or business need to do so;
manage information assets digital y unless there are specific reasons
forkeeping hard copies;
design and implement systems according to relevant standards so that
theysupport the effective management and disposal of information assets;
manage and store information assets appropriately to ensure they
remainaccessible for as long as required;
only destroy information assets when they are no longer required and in
accordance with current, approved disposal determinations issued by State
Records;
review and audit how wel its information management policies and practices
support its business; and
monitor, report and improve employee adherence to internal information
management policies.
Principle 3: Ownership of information assets is assigned
5.1.5 Responsibility for the governance of information assets is assigned appropriately in
order to ensure that they are managed for the best outcomes of the CWT, its
customers and broader community.
5.1.6 The CWT wil endeavour to:
ensure responsibility for information assets is assigned;
ensure that people responsible for information assets are aware of their
responsibilities and accountabilities for managing those assets;
ensure that roles and responsibilities relating to the management of
information assets are clearly defined in policy or other internal documents;
and
ensure that responsibility and accountability for information assets are
managed consistently through a governance structure.
Principle 4: Information assets can be relied upon
5.1.7 Policies, practices and systems are implemented that ensure information assets can
be relied upon as trusted and authentic evidence of decisions made and actions
taken.
5.1.8 The CWT wil endeavour to:
create and keep ful and accurate information assets appropriate to its
business processes, regulatory environment and risk and accountability
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City of West Torrens Administration Policy – Information Management
requirements;
ensure information assets are saved quickly into systems that meet relevant
standards and CWT security frameworks to ensure they are protected from
compromise;
record relevant details (metadata) in systems so that the business context
ofinformation can be readily understood;
use established definitions for information assets, where possible, so that
there is consistency across the CWT; and
implement practices and systems that ensure information assets' quality and
authenticity.
Principle 5: Information assets are available as required
5.1.9 Information assets are accessible for as long as needed and are shared
appropriately (subject to access and security rules) within a protected and trusted
environment.
5.1.10 The CWT wil endeavour to:
implement information security classifications and requirements that are
applicable to the sensitivity of the information identified;
review access restrictions on information and amend them as sensitivity alters;
migrate digital information assets as systems, software and media are
upgraded or become obsolete to ensure they remain accessible for as long as
they are required;
identify requirements for retaining information assets not covered by general
disposal schedules and seek a disposal determination for these information
assets;
ensure that no information asset is destroyed except in accordance with
current, approved disposal determinations;
col ect, use, disclose, store, and dispose of personal information in
accordance with the South Australian Government's information privacy
principles;
share information as appropriate or where authorised;
proactively publish information in line with legislation and government policy;
and
not sel , abandon or donate information assets to external parties where such
action would result in the CWT losing access to that information and without
authorisation in the form of a disposal determination.
6.
Roles and responsibilities
6.1
Executives and Managers: Ensure that records required under any legislation are
properly kept and maintained.
6.2
Information Management: Set the strategic focus for recordkeeping and the management
of information assets. Ensure the efficient management of records, both source (paper
based) and digital, within the EDRMS. Advise and help al CWT employees in fulfil ing their
recordkeeping and information management responsibilities.
6.3
Employees: Register al official records and otherwise comply with this policy. Not
intentional y damage, alter, dispose of or remove official records without authorisation to do
so. Col ect and manage information to:
support the conduct of their business activities;
comply with bestpractice standards and procedures;
access only the records that they are authorised to access;
handle records with a view to prolonging their life span.
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City of West Torrens Administration Policy – Information Management
7.
Information management
7.1
Personal information
7.1.1 The CWT wil endeavour to only col ect personal information for fair and lawful
purposes directly related to its functions or powers in accordance with the
Local
Government Act 1999 and other Acts under which the CWT is authorised or required
to exercise duties and powers.
7.1.2 The type of personal information col ected wil depend on why the information is
col ected and may include (but is not limited to):
contact details, telephone numbers, email addresses;
name and addresses (including postal and residential);
age and/or date of birth;
property ownership and/or occupier details;
pet ownership;
pensioner or concession information;
history of various types of payments (such as rates or fees and charges);
financial, rental or income details;
details of land valuation;
details of employment;
insurance details.
7.1.3
The CWT wil take reasonable steps to ensure that the information it col ects is up to
date and complete.
7.1.4 A person’s name and/or address may be suppressed from the CWT's assessment
book or voters rol if the CEO is satisfied that including those details in either
document would place the safety of that person, a member of their family or any
other person at risk (and those details must be supressed if they are supressed from
the state electoral rol ).
7.2
Sensitive information
7.2.1 If the CWT col ects sensitive information about an individual, it wil endeavour to
take reasonable steps to remove any identifying information before disclosing it to a
third party (to the extent permissible by law).
7.3
Tax file numbers
7.3.1 Al col ection, storage, use, disclosure, security and disposal of tax file numbers wil
be in accordance with
Privacy (Tax File Number) Rule 2015 (Cth)
.
7.3.2 The CWT wil comply with its obligations pursuant to the
Privacy Act 1988 (Cth) in
the event of any eligible data breaches involving tax file number information (as
defined in the
Privacy Act 1988 (Cth)).
7.4
Creating and capturing records
7.4.1 Al official records wil be maintained within an appropriate corporate business
system along with any data that provides context to that record.
7.4.2 Employees must register al official records in the CWT's EDRMS or other business
systems, specifical y incoming and outgoing correspondence, emails and
documents that support decisionmaking processes. Source records that have been
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City of West Torrens Administration Policy – Information Management
digitised must be forwarded to Information Management for appropriate retention or
destruction.
7.4.3 A record is not required to be registered if it is not an official record, for example:
unsolicited product or advertising information (junk mail, brochures,
pamphlets);
a duplicate copy used for reference purposes;
personal communication in no way related to Council business.
7.5
Using information
7.5.1 Where personal information is col ected for a particular purpose, the CWT wil
endeavour not to use or disclose this information for any other purpose, unless:
it takes reasonable steps to obtain the consent of the individual prior to the
information being used;
it believes, on reasonable grounds, that the use of the information for another
purpose is necessary to prevent or lessen a serious or imminent threat to the
life or health of any person;
the alternative use of that information is required or authorised by law;
use of the information for that other purpose is reasonably necessary for the
enforcement of law or penalty;
the alternative use is directly related to the purpose for which it was col ected.
7.6
Copyright
7.6.1 Unless otherwise indicated, the CWT claims copyright over al records it creates.
7.6.2 Materials that are publicly available, such as on the CWT website, can be used for
personal, noncommercial use. Approval to use CWT material for commercial
purposes must be sought from the CEO.
7.7
Control and management
7.7.1 Al information, irrespective of format, created or received by CWT employees in the
course of their duties is the property of the CWT and subject to its control.
7.7.2 Information registered in the EDRMS wil be control ed using bestpractice security
and access provisions, stored with tracking abilities and managed against the
relevant disposal schedule.
7.7.3 Official records should not be stored on network drives that are impractical to protect
and where the information is not accessible across the CWT.
7.7.4 Software to protect the CWT's corporate business systems from network infiltration
wil be instal ed and regularly maintained.
7.7.5 The CWT uses metadata to provide evidence about the processes a record may
have undergone such as accessing, viewing, editing, distributing and printing.
7.7.6 The CWT wil ensure that position descriptions refer to expectations with respect to
information management, where relevant.
7.7.7 Appropriately skil ed employees are engaged by the CWT to develop, implement
and maintain the information management aspects of corporate business systems.
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City of West Torrens Administration Policy – Information Management
7.8
Confidentiality, security and storage
7.8.1 Records of a sensitive or confidential nature should be registered in the CWT’s
EDRMS. Confidential records should have access restrictions applied to them to
secure the content and restrict access to authorised personnel.
7.8.2 Source records that must remain confidential should be stored appropriately, such
as in Information Management’s locked storage room, in the Finance team's
strongroom, or off site at the approved storage provider’s facilities.
7.8.3 The CWT wil endeavour to store source records in a firesafe environment
(recommended minimum of twohour fire rating). They wil not be exposed to
elements (water, wind, sunlight) and wil be free from any conditions that may
damage or alter the integrity of the information (stored away from chemicals, rodents
or pests).
7.8.4 Records wil be retained as long as required to meet legal requirements and
administrative efficiency. Routine administrative records wil be retained and
archived according to the relevant disposal schedule.
7.8.5 The CWT wil take reasonable steps to:
protect personal information from misuse or loss from unauthorised access,
modification or disclosure;
maintain its corporate business systems to ensure that al personal information
col ected is up to date, accurate and complete;
ensure that any person who uses or discloses personal information on behalf
of the CWT is authorised to do so.
7.8.6 Official records wil be stored in accordance with the best practices of the
State
Records Act 1997 and the appropriate Australian standard. Information may be
accessed, viewed or manipulated by those personnel with predetermined rights.
7.8.7 Electronic records wil be stored in an open and enduring format to ensure their long
term preservation.
7.8.8 Employees are responsible for the safe custody of any historic source records that
are al ocated to them. When the work has been completed, the documents must be
returned to Information Management for storage.
7.9
Accessibility of records
7.9.1 The CWT may have a legal obligation to provide access to records under the
Freedom of Information Act 1991 and for legal processes such as discovery and
subpoenas. The Ombudsman, royal commissions, the courts or auditors may also
require access to records.
7.9.2 Records must be accessible by employees to fulfil CWT business only.
7.9.3 The CWT wil ensure that records, irrespective of format, remain accessible for the
duration of the designated retention period.
7.10
Disposal and destruction of records
7.10.1 CWT employees must not dispose of, destroy or delete any official CWT records
unless they are appropriately delegated to do so. Al source records must be
forwarded to Information Management for appropriate retention or destruction.
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7.10.2 Where the CWT is aware that records may be required for use in litigation, reviews,
investigations, inquests, royal commissions, inquiries or audits of processes and
practices, those records may only be destroyed after the retention period set out in
the applicable disposal determination has passed, noting that in some cases State
Records may implement disposal freezes, which override the disposal
determination. Employees should contact Information Management for further
assistance if they are unsure about the appropriate retention period.
7.10.3 Records that the CWT no longer requires and that lack longterm value to the
community or other stakeholders, as expressed in the relevant disposal schedule,
wil be destroyed.
7.10.4 Transitory or ephemeral records, or records that are personal or private in nature,
may be destroyed in accordance with normal administrative practice.
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