Records Management and Personal Information Procedures

1. Governing policy

These procedures give effect to the Records Management Policy and the Privacy Policy. They describe the retention timeframes and areas of responsibility for formal records at the Institution.

2. Scope

These procedures apply to the access, retention and disposal of records across all business operations.

3. Procedures

Access
3.1. The Institution recognises its obligations under privacy legislation and therefore facilitates access to a person’s records and their personal information on request and in a timely manner.

3.2. Individuals who require access to their records are required to contact Student Services (students) or the Vice President (People and Training) (employees) via email who then seeks approval from the responsibility outlined in these procedures.

3.3. Access to records and personal information is authorised as per the responsibility outlined in these procedures.

3.4. Access to a person’s record is provided directly to the person concerned and only after identification has been confirmed by photo ID.

Storage
3.5. All records and personal information created and collected after 2019 are stored in electronic format.

3.6. Records and personal information created and collected prior to 2019 may be stored in hard copy format or electronic format.

3.7. All hard copy material is secured using locked filing systems or office security. All electronic material is secured using secure access controls.

Retention and disposal

3.8. The tables 1-6 below outline minimum retention periods by record category. Records that exceed specified retention periods may be kept longer periods. Otherwise they are disposed of in a secure and confidential manner.

Table 1 – Accreditation and governance – primary responsibility – Chief Quality Officer

Record category	Retention	Responsibility	Compliance requirement / good practice source
Curriculum development and approval
Final approved versions of curricula. Includes: master/authoritative set of descriptions of course requirements, prerequisites, content and outcomes, calendars, faculty handbooks and course guides. master set of approved examination papers if no other course material is available.	Minimum of 10 years	Chief Quality Officer	Good practice source: GA47: The General retention and disposal authority: higher & further education and research (GA47)
Records relating to the development, review and/or approval of the curriculum. Includes correspondence, reference/advisory/industry groups, records of working parties and notes, and committee records.	Minimum of 10 years after superseded	Chief Quality Officer	GA47
Records relating to successful or unsuccessful external accreditation of courses by professional or registration bodies. Includes letter/notification of outcome of accreditation processes.	Minimum of 10 years after expiry of accreditation or until action completed, whichever is longer	Chief Quality Officer	GA47
Records generated to support compliance with agreed accreditation obligations.	Minimum of 5 years after action completed	Chief Quality Officer	GA47
Governance
Final, approved versions of policies, procedures and rules governing the Institution including final approved versions of Governance Charter, Delegations of Authority Schedule and the Quality Assurance Framework	Minimum of 5 years after superseded	Chief Quality Officer	GA47
Records of final formal committee minutes, agendas and papers	Minimum of 30 years	Chief Quality Officer and Vice President (Finance) – for Board of Directors only	GA47
Records relating to the development and review of internal/processes relating to core and administrative functions including processes, manuals, forms etc developed by business units to facilitate day-to-day operations.	Until administrative or reference use ceases	All through governance reporting	GA47
Records relating to the conduct of elections for membership of governing or student bodies, committees, etc. Includes management of electoral rolls, advertising, balloting, nominations, notices, papers, results, scrutineers, tally sheets, etc.	Minimum of 1 year after action completed	Associate Vice President (Student Experience)	GA47
Records relating to human ethics applications, assessment and approval of research.	Minimum of 15 years after action completed, then destroy	Associate Dean (Scholarship)	GA47
Accreditation
Records relating to the registration of the Institution as an education institute.	Minimum of 7 years after the Institution ceases to operate as an institute of higher education.	Chief Quality Officer	GA47

Table 2 – Student records – primary responsibility – Pro Vice Chancellor (PVC) (Employability) and Registrar

Record category	Retention	Responsibility	Compliance requirement / good practice source
Admissions, enrolment and progression
Records relating to the admission (including offers), enrolment and subsequent progress of students (including, for example, special considerations affecting enrolment and progression, variations of courses, advanced standing, withdrawals, etc.)	Minimum of 7 years after completion or discontinuation of course by student	PVC (Employability) and Registrar	Good practice source: GA47: The General retention and disposal authority: higher & further education and research (GA47)
Records applications for admission that were unsuccessful or did not proceed (e.g. offers which were not accepted, or have lapsed, and unsuccessful, incomplete, withdrawn applications, etc.)	Until appeal period has expired or minimum of 1 year after action completed, whichever is longer	PVC (Employability) and Registrar	GA47
Working with children check has been completed for staff and students undertaking studies involving contact with children	Minimum 99 years after action completed	Vice President (People and Training)	GA47
Records of all written agreements as well as receipts of payments made by students under the written agreement.	Minimum 2 years after the person ceases to be an accepted student	PVC (Employability) and Registrar	ESOS/National Code
Records of student details	Minimum 2 years after the person ceases to be an accepted student	PVC (Employability) and Registrar	ESOS
Records of all requests from international students for a release to another institute and the assessment of, and decision regarding, the request.	Minimum 2 years after the person ceases to be an accepted student	PVC (Employability) and Registrar	ESOS/National Code
Records of the written record of acceptance of advanced standing granted to a student	Minimum 2 years after the person ceases to be an accepted student	PVC (Employability) and Registrar	ESOS/National Code
International representatives
Records for each accepted student if their enrolment was facilitated by an International Representative and retain the details as specified in the ESOS Regulations.	Minimum of 2 years after the person ceases to be an accepted student	PVC (Employability) and Registrar	ESOS/National Code
Results and graduation
Records relating to the grading/marking of individual assessment components of a subject or course and determination of final results/grades. Including examiners/assessor’s reports /records for the review of student assessment results / requests for extension of assessment components for a subject / special consideration arrangements.	Minimum of 2 years after the person ceases to be an accepted student	Vice President (Employability) and Registrar	GA47
Records relating to changes to assessment results as a result of moderation, re-marking or appeal by the student.	Minimum of 7 years after action completed (this includes the end of appeal processes and any subsequent appeal rights)	PVC (Employability) and Registrar	GA47
Records confirming the award/receipt of a qualification.	Indefinite	PVC (Employability) and Registrar	GA47
Finalised results obtained by students, where the results are generated as an outcome of some form of assessment.	Minimum of 30 years	PVC (Employability) and Registrar	GA47
Records relating to arrangements for graduation and determination and notification of students of their eligibility to graduate (including, for example, order of proceedings and uncollected testamurs).	Minimum of 1 year	PVC (Employability) and Registrar	GA47
Student exchange / study abroad
Records relating to the processing of applications received for exchange student placements or study abroad.	Minimum of 2 years after action completed	PVC (Employability) and Registrar	GA47
Complaints, appeals and misconduct
Records relating to the management of proven and unproven cases involving allegations of abuse or neglect of children (including, for example, enquiries and investigations, outcomes, and matters referred to external bodies for investigation).	Minimum of 99 years after action completed	Student Success Centre Manager	GA47
Records relating to the management of proven and unproven student complaints, appeals misconduct and disciplinary cases. Including: · enquiries and investigations, outcomes, and matters referred to external bodies for investigation · handling complaints over perceived discrimination, the work/study environment, assessment/assignment organisation or distribution, peers, lecturers, tutors or supervisors, access to equipment, facilities (such as laboratories), tutorials, or other services · disciplinary processes for breaches of policies, procedures and rules and other student disciplinary matters.	Minimum of 7 years after action completed	Chief Operations Officer	GA47
Records relating to preliminary/fact finding investigations that were not formally proceeded with (i.e. the allegations have been found to be unsubstantiated, false, vexatious or misconceived or could not be proven) and the accusation has not involved a child or a young person.	Minimum of 1 year after action completed	Chief Operations Officer	GA47

[1] Refer to the Education Services for Overseas Students Act (21(2)) and the Education Services for Overseas Students Regulations 2019 Regulations for further information on student details.

Table 3 – Learning and teaching and student support – primary responsibility – DVC (Learning and Teaching)

Record category	Retention	Responsibility	Compliance requirement / good practice source
Attendance
Records relating to the management of student attendance for teaching and assessment activities such as examinations, assessment activities, classes, tutorials e.g. attendance lists, sick leave forms and medical certificates.	Until at least until end of appeal period	PVC (Employability) and Registrar	Good practice source: GA47: The General retention and disposal authority: higher & further education and research (GA47)
Course delivery
Records relating to course delivery, including subject resources, material used in course delivery, and quality assurance. Includes: subject outlines study guides readings self assessment exercises audio/visual teaching aides reading lists assignment lists lecture notes timetables, rosters, organising venues, teaching allocations feedback data collection/survey forms assessment of data/feedback on course delivery.	Retain until no longer required for teaching or other purposes	DVC (Learning and Teaching)	GA47
Assessment
Student examination/assessment scripts or items e.g. examination papers completed by students, examination manuscripts and assignments. Includes any work submitted or completed by students for the purposes of assessment or evaluation by examinations (written or oral) /assignments / theses / field work reports / presentation / works of art	Minimum 2 years after the completion date of the subject.	DVC (Learning and Teaching)	GA47
Records relating to the assessment of courses of study such as work integrated learning placements where the number of hours completed and proof of satisfactory performance may be required for accreditation purposes.	Minimum of 50 years after completion of course of study	DVC (Learning and Teaching)	GA47
Assessment committee records and records of reviews of individual assessments	Minimum of 1 year after action completed	DVC (Learning and Teaching)	GA47
Records relating to administrative arrangements for the conduct of examinations and other assessment activities, including supervision, timetabling, eligibility, provision of materials and objections to taking part in an assessment/examination, liaison with placement providers.	Until administrative or reference use ceases	DVC (Learning and Teaching)	GA47
Student examination/assessment scripts or items e.g. examination papers completed by students, examination manuscripts and assignments. Includes any work submitted or completed by students for the purposes of assessment or evaluation by examinations (written or oral) /assignments / theses / field work reports / presentation / works of art	Minimum 2 years after the completion date of the subject.	DVC (Learning and Teaching)	GA47
Student support
Records relating to the establishment, negotiation, maintenance and review of agreements to provide and operate services to students, etc. Records include: correspondence and records of negotiations final, approved versions and significant drafts of agreements reviews of agreements.	Minimum of 7 years after expiry or termination of agreement or after action completed, whichever is later	President and Managing Director (President)	GA47
Records relating to the provision of special needs and accessibility services (e.g. interpreters, reading assistance for sight impaired students, disabled access, etc.,) and other tailored advisory or study support services and assistance to individual students	Minimum of 7 years after a student has completed their course of study	Student Success Manager	GA47
Records relating to unsuccessful applications for student support services.	Minimum of 1 year after action completed	Student Success Manager	GA47
Records relating to the provision and administration of residential accommodation and placement services for students; careers, employment and general services; mentoring, peer networking services, etc.	Retain minimum of 2 years after action completed	Chief Operations Officer	GA47
Records relating to the interaction between the Institution and student associations such as sporting clubs, special interest groups etc.	Retain minimum of 7 years after action completed	AVP Student Experience	GA47
Records relating to liaison between the Institution and service providers where the service is not provided directly by the Institution. For example, student accommodation, medical and dental services.	Retain minimum of 5 years after action completed	Student Success Manager Chief Operations Officer	GA47
Records relating to the provision of counselling by a professional counsellor (including case files).	Retain minimum of 7 years after action completed or until the person reaches the age of 25, whichever is longer	Student Success Manager	GA47
Library
Records relating to the provision of library borrowing and usage rights (including the imposition of fines or other penalties)	Minimum of 1 year after action completed	Library Services Manager	GA47

Table 4 –Finance – primary responsibility – Vice President (Finance)

Record category	Retention	Responsibility	Compliance requirement / good practice source
Commercial activities and services
Records relating to the management of commercial ventures and services. Includes the provision of consultancies and other professional services. Includes: expressions of interest and tenders negotiations, contracts, agreements and other formal arrangements regarding provision of services, commercial ventures, use of intellectual property, etc. records relating to provision of products and services.	Retain minimum of 7 years after provision of services ceased or minimum of 7 years after all terms and conditions of contract are satisfied, whichever is longer	President	GA47
Records relating to commercial ventures and services that did not proceed or where the tender/expression of interest, etc., was unsuccessful.	Minimum of 2 years after action completed	President	GA47
Financial records
Receipts of payments made by a student	Minimum of 2 years after the person ceases to be an accepted student	Vice President (Finance)	ESOS/National Code
Records of each accepted student who has paid tuition fees for a course and retain the details as specified in the ESOS Regulations.	Minimum of 2 years after the person ceases to be an accepted student	Vice President (Finance)	ESOS/National Code
Records relating to the provision of financial assistance services (loans, FEE-HELP/HECS-HELP, bursaries, etc.), to individual students	For FEE-HELP/HECS-HELP, destroy after 7 years after last action. For all other financial assistance records, minimum of 5 years after action completed.	Vice President (Finance)	National Archives and Records Authority- Department of Education, Employment and Workplace Relations
Records documenting the organisation’s financial transactions. Includes revenue, expenditure, debt recovery and deposits.	Retain minimum of 7 years after end of financial year in which transaction was completed.	Vice President (Finance)	Good practice source: GA28: The General retention and disposal authority: administrative records (GA28)
Records relating to the establishment and management of bank accounts. Includes the closure of accounts.	Retain minimum of 7 years after account closed.	Vice President (Finance)	GA28
Records relating to bank guarantees/securities.	Retain until matter completed, then return to applicant or bank.	Vice President (Finance)	GA28
Records relating to the management of incidental benefits received by employees in the course of their official duties.	Retain minimum of 7 years after action completed.	Vice President (Finance)	GA28
Records relating to the assessment and payment of taxation. Includes income tax, fringe benefits tax (FBT), goods and services tax (GST), payroll tax, and pay as you go (PAYG) withholding. Records include: tax assessments business activity statements tax invoices. Note: If the records form the primary record of the organisation’s financial transactions they should be retained for a minimum of 7 years.	Retain minimum of 5 years after end of financial year in which record was created.	Vice President (Finance)	GA28
Records containing sensitive cardholder authentication data captured as part of an electronic financial transaction.	Retain until transaction completed, then destroy.	Vice President (Finance)	GA28
Records containing cardholder data captured as part of an electronic financial transaction including information printed, processed, transmitted or stored in any form on a payment. Information may include, but is not limited to, Primary Account Number (PAN), cardholder name, expiry date, service code.	Retain minimum of 3 months after last business, legal and/or regulatory action, then destroy.	Vice President (Finance)	GA28
Records relating to the establishment, negotiation, maintenance and review of agreements regarding management of the organisation’s financial resources e.g supplier contracts.	Retain minimum of 7 years after expiry or termination of contract or agreement.	Vice President (Finance)	GA28
Registers documenting the assets and/or accountable items in the possession of the organisation.	Retain minimum of 7 years after asset is disposed of.	Vice President (Finance)	GA28
Records relating to audits of the organisation’s accounts or financial management records, systems and processes.	Retain minimum of 6 years after action completed.	Vice President (Finance)	GA28
Records relating to the development and review of budgets.	Retain minimum of 6 years after preparation.	Vice President (Finance)	GA28
Records relating to the organisation’s spending progress or revenue collection against allocations within the budget estimates.	Retain minimum of 2 years after end of financial year in which record was created.	Vice President (Finance)	GA28
Records relating to the organisation’s compliance with mandatory or optional standards or with statutory requirements regarding financial management, e.g. HITS, TPS & PIR.	Retain minimum of 7 years after registration lapses or is superseded, or action completed.	Vice President (Finance)	GA28
Records relating to specific instances of theft, fraud, misappropriation or negligence.	Retain minimum of 10 years after action completed	Vice President (Finance)	GA28
Records relating to the preparation and review of financial statements and summaries. Includes annual statements of assets and liabilities, balance sheets, profit and loss statements, operating statements of financial position and cash flow statements.	Retain minimum of 7 years after end of financial year in which record was created.	Vice President (Finance)	GA28
Periodic interim financial statements and summaries prepared for management on a regular basis, e.g. weekly or monthly.	Retain minimum of 1 year after end of financial year in which record was created.	Vice President (Finance)	GA28
Records relating to the organisation’s policies for the management of financial resources, including policies on treasury management and accounting e.g Refund Policy.	Retain minimum of 7 years after policy is superseded.	Vice President (Finance)	GA28
Records relating to manuals, handbooks, directives etc detailing the organisation’s procedures for the management of financial resources, including procedures for treasury management and accounting.	Retain minimum of 7 years after procedures are superseded.	Vice President (Finance)	GA28
Records relating to reports regarding the management of the organisation’s finances, e.g. yearly premium renewals for insurance policies.	Retain minimum of 7 years after action completed.	Vice President (Finance)	GA28
Records documenting the payment of wages to employees. This includes employee contracts, time sheets and contract variations, leave payments, maternity pay & salary sacrifice records.	Retain minimum of 7 years after end of financial year in which record was created.	Vice President (Finance)	GA28
Records relating to operations, and individual appropriations, borrowings, investments and loans to other organisations or individuals.	Retain minimum of 7 years after end of financial year in which transaction was completed.	Vice President (Finance)	GA28

Table 5 – Scholarships – primary responsibility – Chair of the Aspiring Education Foundation and ICMS Professional Scholarship Program

Record category	Retention	Responsibility	Compliance requirement / good practice source
Scholarships and prizes
Records relating to the management and delivery of scholarships and prizes (including, for example, applications, nominations, acceptances, unsuccessful candidates, rejected or lapsed offers).	Minimum of 7 years after action completed	Chair of the Aspiring Education Foundation and ICMS Professional Scholarship Program	Good practice source: GA47: The General retention and disposal authority: higher & further education and research (GA47)
Summary records of recipients of scholarships and prizes	Minimum of 7 years after action completed	Chair of the Aspiring Education Foundation and ICMS Professional Scholarship Program	GA47
Records relating to the establishment and conditions of scholarships and prizes (including, for example, terms and conditions).	Minimum of 7 years after action completed	Chair of the Aspiring Education Foundation and ICMS Professional Scholarship Program	GA47

Table 6 – Human Resources and Work, Health and Safety – primary responsibility – Vice President (People and Training)

Record category	Retention	Responsibility	Compliance requirement / good practice source
Critical Incidents
Written records of any critical incident and remedial action taken by the Institution	Minimum of 2 years after the person ceases to be an accepted student	Chief Operations Officer	ESOS/National Code
HR and WHS
Records relating to the provision of advice and assistance to employees about employment conditions, career, personal matters, trauma, finances, salaries, superannuation etc. Includes orientation advice for new employees and rehabilitation or return to work assistance not related to a compensation case. Records include notes, reports, etc.	Retain minimum of 7 years after action completed.	Vice President (People & Training)	GA28
Records relating to the implementation of employee assistance/counselling programs or schemes, such as career or trauma counselling programs. Includes program plans and reports.	Retain minimum of 7 years after action completed.	Vice President (People & Training)	GA28
Records documenting formal and informal grievances lodged by an employee, including those referred to an external body. Includes notes of meetings, reports and recommendations.	Retain minimum of 7 years after action completed.	Vice President (People & Training)	GA28
Records relating to the management of instances or allegations of misconduct involving abuse or neglect of children. Records include: advice of allegation and response investigation documentation and reports notifications and referrals of allegations and cases to external bodies records of remedial and/or disciplinary action records of appeals.	Retain minimum of 100 years after action completed.	Vice President (People & Training)	GA28
Records relating to the management of instances or allegations of misconduct (not involving abuse or neglect of children) where an investigation is conducted. Records include: advice of allegation and response investigation documentation and reports referrals to external bodies records of remedial and/or disciplinary action records of appeals.	Retain minimum of 10 years after action completed.	Vice President (People & Training)	GA28
Records relating to the management of instances or allegations of misconduct where no follow-up investigation is conducted.	Retain minimum of 7 years after action completed.	Vice President (People & Training)	GA28
Records relating to the administration and implementation of performance management programs, including recognition schemes for employees. Includes routine or periodic awards to employees in recognition of service.	Retain minimum of 10 years after action completed.	Vice President (People & Training)	GA28
Records relating to the assessment, evaluation and review of an employee’s performance. Includes performance agreements and development plans, reports on performance assessments, evaluations and reviews, performance counselling, etc.	Retain minimum of 3 years after superseded.	Vice President (People & Training)	GA28
Records relating to the filling of vacancies. Includes unsuccessful applications for a position or offers of employment which are not accepted. Includes: applications to fill a vacancy advertisements and details of position, duty statements, selection criteria etc. selection committee records and reports applications received associated checks and approvals eligibility lists notifications to unsuccessful applicants records of appeals.	Retain minimum of 2 years after recruitment finalised.	Vice President (People & Training)	GA28
Records relating to reports regarding the management of personnel, e.g. workforce profile reports e,g Gender Equality Reports	Retain minimum of 5 years after action completed.	Vice President (People & Training)	GA28
Records relating to incidents that result in serious personal injury or incapacity to employees. Records include: incident/injury records, e.g. incident/accident report forms notifications to insurer records of investigation by the organisation into incident details of notifications to WorkCover NSW of incident copies of investigation reports by Police, WorkCover NSW inspectors etc into incident.	Retain minimum of 75 years after action completed.	Vice President (People & Training)	GA28
Records relating to incidents that results in the death of employees. Records include: incident records, e.g. incident/accident report forms notifications to insurer records of investigation by the organisation into incident details of notifications to WorkCover NSW of incident copies of investigation reports by Police, WorkCover NSW inspectors etc into incident.	Retain minimum of 25 years after date of death or minimum of 7 years after action completed, whichever is longer.	Vice President (People & Training)	GA28
Records relating to incidents involving employees that do not result in death, serious personal injury or incapacity to employees. Records include: incident/injury records notifications to insurer records of investigation by organisation/WorkCover NSW into incident.	Retain minimum of 25 years after action completed.	Vice President (People & Training)	GA28
Records relating to incidents involving members of the public, including work experience students and volunteers or other persons who are not employees. Records include: incident/injury records notifications to insurer records of investigation by organisation into incident.	Retain minimum of 15 years after action completed or until expiry of statutory limitation periods, whichever is longer.	Vice President (Finance)	GA28
Copies or details of records of all incidents and/or hazards in an organisation kept or compiled together for occupational health and safety assessment or monitoring purposes.	Retain until administrative or reference use ceases.	Vice President (People & Training)	GA28
Records relating to arrangements for employee attendance on training courses for staff development purposes. Records include: records of confirmation of course attendance records of lodgement of application forms accommodation and transport arrangements.	Retain minimum of 2 years after action completed.	Vice President (People & Training)	GA28
Notices of assessment or examination results of internally conducted training or sent to the organisation by external training providers.	Retain minimum of 7 years after action completed.	Vice President (People & Training)	GA28
Records relating to participant evaluations of internally and externally conducted courses.	Retain minimum of 1 year after action completed.	Vice President (People & Training)	GA28
Final, approved versions of training material for courses run internally by the organisation for their employees, e.g. induction, graduate training, volunteer training. Records include: programs lecture notes handouts.	Retain until course or training material is superseded.	Vice President (People & Training)	GA28
Records relating to the development of training materials for courses run internally by the organisation for their employees.	Retain until administrative or reference use ceases.	Vice President (People & Training)	GA28
Records relating to administrative arrangements for conducting training courses, or attendance at workshops, seminars etc. Records include: records of applications records of confirmation of attendance venue bookings records of equipment hire catering arrangements.	Retain until administrative or reference use ceases.	Vice President (People & Training)	GA28

Approved by EMG on 4 June 2021 (updated by EMG 1 March 2024)