Information and Records Destruction Guidelines

Please note that compliance with University Guidelines is expected in normal circumstances, and any deviation from Guidelines – which should only be in exceptional circumstances – needs to be justifiable.

Purpose

This document outlines the responsibilities of staff when destroying University information and records.

Organisational scope

Corporate Records Services supports information management at the University. These guidelines apply to all public records created within the University, but the principles of records destruction and the methods of destruction are best practice advice for all types of information and records created by the University.

Custodians are expected to work with Corporate Records Services and other areas that have specialist information portfolio responsibilities who can provide advice and assist them with meeting their responsibilities.

Definitions

Custodian

University information is owned or controlled by the University as a whole, for the benefit and functioning of the University. However, to assist with the operational management of information, certain types of information are managed by assigned Custodians of that information. Custodians are normally members of University Senior Management. Please find a full table at the end of the document.

Content

1. Principles of Records Destruction

   1. Authorised

      The New Zealand Universities Disposal Authority (DA) is our legal authority to dispose of our public records at the end of the appropriate retention period and when they are no longer required by the University. Note that the DA applies to all information regardless of format. While the GDA sets out the minimum period for retention, staff also need to ensure that there is no administrative, business or legal need to keep the information and record before commencing destruction (see Information and Records Disposal Process below for more information on the delegated authority framework for approving the disposal of information and records).

   2. Appropriate

      Any destruction of information and records ought to be irreversible and complete to prevent the information being recovered again and to ensure that there is no risk of accidental or unauthorised access to the records. Appropriately managed destruction should also consider the environment, and where possible information and records should be destroyed in an environmentally friendly manner, such as recycling both paper and microforms (see Methods of Destruction below).

   3. Secure/Confidential

      Information and records should always be disposed of with the same level of security that was applied during their lifetime. Security during the disposal process can include the use of securely locked document destruction bins and a contractor who transports the records in a totally enclosed and locked vehicle. It may also be appropriate for particularly sensitive records to have an extra level of security applied to them at the disposal stage such as in-house shredding before being collected by a contractor for destruction.

   4. Timely

      Although timely destruction ought to be balanced by the organisation's desire to retain information and records for longer than the minimum retention period in certain circumstances, it is important not to keep records for longer than is necessary. The timely destruction of information and records helps to aid retrieval efficiency and minimise storage costs, and it enables the University to focus on information and records of greater value. For information and records where a decision has been made to retain for longer than the minimum retention period, reasons for the decision should be documented to assist in their later disposal.

   5. Documented

      Because proof of destruction may be required during the course of an investigation, or in response to an information access request, or as part of a recordkeeping audit, the destruction of all information and records must be documented. A certificate of destruction should also be obtained from the contractor and placed on a file together with any other destruction documentation. The type of information to be captured includes:

      • The date when the disposal took place;
      • The disposal authority that applies;
      • Which information and records were destroyed; and
      • Who took the action and their authorisation.

2. Methods of destruction

   Archives New Zealand recommends the following destruction methods:

   1. For paper:
      • Shredding: this method reduces paper documents to fine ribbons;
      • Pulping: this method reduces paper to its constituent fibres, and if often recycled;
      • Burning: this method should only be undertaken only in an industrial facility operating an enclosed incinerator and is not the most environmentally friendly option; and
      • Dry maceration: this method reduces materials to fine particles.
      Note: Burying or dumping paper records are not appropriate methods of destruction. Paper may take months or years to break down and may be uncovered at any time.
      • Destroying sensitive information: If available - both pulping and dry maceration are most appropriate for highly sensitive material. Shredding is appropriate, but where possible cross-shredding should be used for sensitive documents. Densely packed paper does not burn well so burning ought to be a last resort for this type of material.
   2. For digital information:
      • Delete documents from the digital system or application they are stored in.
      • Identify other systems or applications where duplicate copies may exist. For example, a document in your shared drive, Microsoft Teams, or email.
      • Ensure that any documents you have deleted have also been deleted from your computer’s recycle bin.

3. Information and Records Disposal Process

   1. If you are carrying out a destruction process, please contact Corporate Records Services for advice about the correct approach for this.
      1. Corporate Records will assist you to identify information and records due for disposal Using the New Zealand Universities Disposal Authority (DA)
      2. If necessary, Corporate Records Services may ask you to complete the Request for Approval to Destroy Form (PDF)
      3. Please note that the information and records must not be the subject of a current or pending investigation or access request.
      4. Please ensure that the University no longer requires the information and records and they are not required under any other legislation.
      5. When correct destruction has been carried out this will be documented by Corporate Records Services.
   2. It is not necessary to document the process of disposing of your low-level, routine administration records, such as those records outlined in the Managing Routine Business Information in the Office guidelines.

4. List of information Custodians who have overall responsibility for information under their management

   1. Custodians are expected to work with Corporate Records Services and other areas that have specialist information portfolio responsibilities who can provide advice and assist them with meeting their responsibilities.
   2. Please see the below list of Information Custodians, as noted in the University of Otago Information Framework.

      Information Type	Custodian	Standing Delegation(s)
      Academic Board (Senate and Committees) Information	Vice-Chancellor	Manager, Academic Committees and Services
      Alumni Information	Deputy Vice-Chancellor (External Engagement)	Director, Development and Alumni Relations
      Archived University Records and Historic Material	Registrar and Secretary to the Council	Head, Corporate Records Services
      Business Intelligence Information not otherwise captured in this table	Director, Strategy, Analytics and Reporting	-
      Council and Council Committee Information	Registrar and Secretary to the Council	-
      Emails held on University Services	Chief Operating Officer	Chief Digital Officer
      Financial Information	Chief Financial Officer	Financial Controller
      Graduate Research Student Information not covered by general student information as shown below	Deputy Vice-Chancellor (Research and Enterprise)	Dean, Graduate Research School
      Health Information held in Academic Divisions	Pro-Vice-Chancellors	-
      International Partnership Information	Deputy Vice-Chancellor (External Engagement)	Director, International
      IT Systems Information	Chief Operating Officer	Chief Digital Officer
      Library Information	Deputy Vice-Chancellor (Academic)	University Librarian
      Māori Information (information specific to Māori, including mātauranga Māori, and not otherwise covered by sections in this table)	Director of Māori Development	-
      Pacific Peoples Information (information specific to Pacific Peoples, including oral information, and not otherwise covered by sections in this table)	Director of Pacific Development	-
      Projects and project information	Project Sponsors Project Steering Committees	Project Managers
      Property and Campus Information (new and proposed)	Chief Operating Officer	Director, Campus Development
      Property and Campus Information (existing)	Chief Operating Officer	Director, Property Services
      Research Contract and Management Information	Deputy Vice-Chancellor (Research and Enterprise)	Director, Research and Enterprise
      Research Ethics Information	Deputy Vice-Chancellor (Research and Enterprise)	Manager, Academic Committees and Services
      Staff Employment Information	Director, Human Resources	-
      Statutes, Regulations, Policies, Procedures, Guidelines and Codes of Practice (at the University level)	Registrar and Secretary to the Council	Responsible Officers for individual Policies, Procedures, Guidelines and Codes of Practice
      Student Academic Records	Registrar and Secretary to the Council	Director of Student Experience
      Student Accommodation Information	Chief Operating Officer	Director, Campus and Collegiate Life Services
      Student Discipline Information	Vice-Chancellor	Various (as per the Discipline Statute)
      Student Enrolment and Study Information	Deputy Vice-Chancellor (Academic)	Director of Student Experience
      Student Health Information	Chief Operating Officer	Manager, Student Health Services
      University Archives in the Hocken Collections	Registrar and Secretary to the Council	Hocken Librarian
      Information held in individual schools or departments and not otherwise captured above, including teaching and learning materials	Pro-Vice-Chancellors and Heads of Service Divisions	Normally Heads/Managers of the individual departments concerned
      Research Information (specific to research outputs)	Unless otherwise determined by contract, is the responsibility of individual researchers

Related policies, procedures and forms

• Information and Records Management Policy
• University of Otago Information Framework (PDF)
• New Zealand Universities Disposal Authority (PDF)
• Request for Approval to Destroy Form (PDF)

Contact for further information

If you have any queries regarding the content of these guidelines or require further information, please contact:

Corporate Records Services
Email corporate.records@otago.ac.nz