How to identify records for the Disposal Freeze on Records about Children

TASKS

• Identify and document all programs and services of the organisation.
• Do not forget past, present and possible future programs and services.

EXAMPLES

• The organisation does not have any work experience students now, but there were in the past.
• All apprentices currently employed are over 18 but younger apprentices may be employed in the future.
• Child care programs were run by the organisation in the past.

TIPS

• Refer to annual reports, business systems and legislation administered by the organisation.
• Don’t rely only on your organisation’s recordkeeping system.
• Don’t forget any outsourced programs or services.
• Consider the operational and strategic services offered by the organisation both internally (to employees, contractors, volunteers, trainees etc) and externally (to the community, or to other government or private operations).
• Even if the programs and services initially appear to not include any contact or interactions with children, it’s important to document that you excluded some records.

OUTPUT

A list of all programs and services performed by the organisation.

TASK

Look through the list of programs and services developed in Step 1 to identify those that involve, or may involve, contact or interactions with children.

EXAMPLES

• Tours of government facilities, for example, plants, venues.
• Community facilities, for example, libraries, child care.
• Educational facilities, including offsite services, for example, school camps, tours.
• Providers, for example, training, transport.
• Public facilities, for example, hospitals, sports venues, transport, youth justice, residential care.

TIPS

Don’t forget internal programs such as work experience student placements, or visits to or from external organisations such as tradespeople.

OUTPUT

A list of all programs and services performed by the organisation that involve or may involve contact or interactions with children.

TASKS

• Identify the likelihood of high-risk contact and interactions.
• Use this workflow and your organisation’s risk assessment tools to assess the level of risk of your organisation’s contact and interaction with children.

EXAMPLES

The following are high risk contact and interactions:

• A child stays overnight, for example, camp, night in a museum
• A child is alone with an adult or another child, for example, classroom, bus, medical consultation, tour
• Parents or guardians do not remain close by, for example, child and guardian on separate buses

TIPS

• There are various tools that you can use to identify the risk level when contacting or interacting with children.
• The Tasmanian Risk Framework is used by Child Protection Services to assess their clients, and your own organisation may have its own risk assessment framework that could be useful.

OUTPUT

• A list of your programs and services with an assigned risk level that will form part of your risk analysis (see Step 5).

TASK

Identify what is the best evidence to document – the who, what, where, why, when and how. Where possible, keep the best evidence, which might be a summary record of an interaction, rather than any partial records.

EXAMPLE

Evidence of a school class tour conducted by a government organisation:

• Who was involved? For example, timesheets, attendance records, class roll
• What was the interaction? For example, tour outline, handouts
• Where did it take place? For example, transport details, tour map, venue booking
• Why did it take place? For example, curriculum plans
• When did it take place? For example, calendar entries, work diaries, timesheets
• How did it happen? For example, tour program, photos

The best evidence of the tour could be a report sent to the principal by the class teacher. The report should include a list of everyone who took part (who), tour itinerary (what), transport and venue bookings (where), a lesson plan (why), an email thanking the host (when), and photos of the tour (how). If an incident occurred during the tour then incident forms, witness statements, reporting trail and other communications would also need to be kept.

TIPS

Look at the documentation that your employees use, such as record types in your Electronic Document and Records Management System (EDRMS), templates and forms, logbooks etc.

OUTPUT
A searchable register of all your identified records. This could be in the form of an information asset register, added searchable metadata to the records’ properties, or another means.

TASKS

• Use the results from this workflow to decide what evidence is required to document all contact and interaction with children.
• Assess how business processes are documented and if/what changes need to happen to make sure records are created and managed properly.
• Develop or update risk mitigation strategies.

EXAMPLES

Assessment:

• Do they capture enough evidence of your organisation’s contact and interaction with children?
• Is there unnecessary duplication across business systems or units?
• Do you need to add or change methods on how you capture and manage the evidence?

Improving strategies:

• Use your organisation’s risk management process to perform regular health checks
• Undertake periodic reviews to identify performance levels, good recordkeeping practices and areas that need improving
• Ensure your business information systems and processes meet security, policy and best practice standards
• Deliver regular training sessions for employees on the importance of creating and managing complete and reliable records

TIPS

See the OSA Information Management Framework for more strategies on how to properly manage your records.

OUTPUT

A risk assessment report and action plan.