Policy Drafting, Review and Approval 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

To provide guidance to Responsible Officers and other staff involved in initiating, drafting, reviewing and overseeing University policy.

These guidelines should be read in conjunction with the Policy Framework, which provides details on the University's overarching approach to policy.

Organisational scope

These guidelines apply to all University-level Policies, Procedures, Guidelines and Codes of Practice.  Advice in these guidelines may also be applied to policy documents produced at Divisional or departmental level.

Definitions

Legislation

Statutes enacted by the New Zealand Parliament and Statutory Regulations made pursuant to those Statutes, and enforced by law.

Statutes and Regulations

High-level rules that cover the formal expectations and processes of the University concerning academic and other matters. Statutes and Regulations are established by the University Council under the authority of the Education and Training Act 2020 and are legally binding.

Policy

A Policy sets out the University's position on a specific matter and requires a certain line of action to be taken, although it does not necessarily detail that line of action. Compliance is mandatory.

Procedure

A Procedure sets out, often in a step-by-step manner, the way in which the University undertakes appropriate or best practice. Procedures sometimes elaborate on, and give effect to, a Statute, Regulation or Policy. Compliance is mandatory.

Guidelines

Guidelines embody the University's current view of appropriate or best practice. They are not necessarily set out in a step-by-step fashion, though they are sometimes associated with, and give effect to a Statute or Policy. Compliance is expected in normal circumstances and any departure from a Guideline needs to be justifiable.

Code of Practice

A Code of Practice sets out minimum expectations and best practice. Compliance is mandatory.

Policy Documents

For the purposes of this Framework, refers to Policies, Procedures, Guidelines or Codes of Practice.

Policy Library

The University's searchable, online policy repository, containing the current versions of approved policy documents.

Approval Body

The relevant position or body that has authority to approve policy documents in accordance with the requirements of this Policy Framework.

Policy Management Group

A group convened by the Registrar and Secretary to the Council that considers policy strategy and oversees policy development and review across the University.

Sponsor/s

The senior staff member who advocates for a policy document and supports its development, approval and continuing existence. A Sponsor must be a member of the Senior Leadership Team or a Director in a Service Division.

Responsible Officer

The staff member with responsibility for developing, seeking approval for, coordinating implementation of, and maintaining and reviewing a policy document. The Responsible Officer should not normally be the Sponsor.

Content

1. The policy document template

1. A succinct and descriptive title is required for each policy document.  This should normally include the name of the type of policy document (e.g. Academic Integrity Policy, Accounts Receivable Procedure).  To aid in alphabetical listing of policy documents in the Policy Library, it is preferred that the type of policy document follow the rest of the title (e.g. Academic Integrity Policy rather than Policy on Academic Integrity).
2. Header information includes:

   Policy document headers
   Header	Description	Example
   Category	The broad area the policy document relates to.	Administration and Management
   Type	The type of policy document	Procedures
   Approved by	The body that initially approved the policy document, with the date of approval. This will be entered when the policy document is approved.	Vice-Chancellor, 10 March 2013
   Date Policy Took Effect	The date the policy came into effect. This may be specified as later than the approval date in some cases, but will otherwise default to the approval date.	April 2013
   Last Approved Revision	The date the policy was last significantly updated. This may be blank and will be updated when a change to the policy document is approved.	14 April 2015
   Sponsor	The policy document Sponsor.	Registrar and Secretary to the Council
   Responsible Officer	The policy document Responsible Officer.	Manager, Policy and Compliance
   Review Date	The date of the next scheduled review of the policy document. This will be updated following review.	15 April 2020

3. Purpose succinctly describes the reason for the policy document. It should not provide commentary on the importance of the matter addressed, nor a justification for approving the policy document (these matters can be addressed in a covering memorandum when approval is sought).
4. Scope describes the people, areas or processes the policy document applies to (e.g. “University-wide”, “these procedures apply to all staff of the University”, “this policy applies to all final examinations at the University”).
5. Definitions cover technical terms, terms which are used in a specific way within the policy document and/or acronyms used in the policy document.  Terms not used in the policy document and commonly understood terms (defined in the normal way) should not be included in the definitions.  Where possible definitions should match definitions in other policy documents, on the University terminology webpage, or in other existing documents. It may be helpful to decide on terms to include in the definitions section after content is drafted.
6. Content contains the main contents of the policy document, normally divided into clauses and sub-clauses, and formatted as specified in clause 2 below.
7. Contact provides the position that may be contacted for more information on the policy document.  This is normally the Responsible Officer, but in some cases may be another staff member whose work is related to the matter covered.  Where possible, a role-based email address should be used for contact, rather than a name-based email address.
8. Related policies, procedures and forms provides links to University policies and any other internal or external documents that may be relevant to the users of the policy (please include hyperlinks to all related documents available on the web). Documents which are unlikely to be helpful and/or accessed should not be included.  If the list of related documents is long, this can be divided into sections (e.g. University policies and procedures, Other University resources, External resources, etc.)
9. Consultation should list all parties formally consulted with in preparing or reviewing the policy document.  Parties that have been given the chance to comment but have not provided feedback should also normally be listed.  These details are for the information of the Approval Body and are not included when the policy document is published in the Policy Library.
10. Keywords should include several words relating to the policy to assist with internet searches.  These will be used as metadata when the policy document is published in the Policy Library.
11. All new or significantly amended policy documents must contain an Implementation and Communication plan, including:
    1. Person responsible, who will coordinate the Implementation and Communication Plan (often the Responsible Officer).
    2. Communication strategy for communicating the policy to the wider University and other interested parties.
    3. Other actions/tasks to allow implementation of the policy (e.g. upgrading IT systems).
    4. Resources, including any monetary costs, in order to implement the policy.
    5. Completion date for completing implementation and communication.
       The date of the policy coming into effect can be delayed after approval to allow implementation activities to be completed (see clause 1(b) – “Date Policy Took Effect” – above).

2. Drafting policy documents

1. Policy documents should be written in clear, concise and unambiguous language, and formatted so as to be easily readable.  For policies and procedures, policy writers should aim to say what needs to be said with the minimum amount of text necessary (guidelines may include more detail).  Jargon should be avoided.
2. Policy writers should consult and apply the University Writing Style Guide.
3. Policy writers should use template or sample policy documents available in the Policy Resources section on the Policy Library webpage.
4. The contents of a policy document should be organised into numbered (e.g. 1, 2, 3) clauses or sections.  Sections should be labelled to allow users to easily find the information they are looking for.
5. Within each section, sub-clauses should be represented by letters (e.g. (a), (b), (c)).  Each sub-clause should relate to a single idea and link to the topic of the section concerned.
6. Where necessary, additional points can be listed under a sub-clause using small roman numerals (e.g. i, ii, iii).  Bullet points may be used for clear lists of items, but the use of roman numerals is normally preferable.  See also the University Writing Style Guide on bullet points/lists.
7. For referencing purposes, text which is not in a numbered or lettered clause or sub-clause (as per sub-clauses 2(d) to (f) above) should be avoided.
8. Consistent spacing and tabbing should be applied to enhance readability.
9. Once drafting is complete, spelling and grammar checks should be run and the policy document manually proofread for errors and unclear or ambiguous language.

3. Initiating new policy

1. Before initiating a new policy document consideration should be given as to whether a formal University-level policy is needed.  The proposed policy Sponsor should be involved in these discussions.  Questions that might be considered include:
   1. Is the matter addressed of University-wide significance?  More local issues can be dealt with by departmental or Divisional policy.
   2. Is the matter addressed likely to be of ongoing significance? Policy should not normally be used to address transitory matters.
   3. Will a policy document have some tangible impact?  Policies which have little real impact are discouraged.
   4. Will a policy document only describe operational processes?  Unless they need to be formally communicated and established across the University, operational processes should not normally be expressed via University policy documents.
   5. Is there another more appropriate way to address the matter at hand, e.g. via communication with relevant parties, operational changes, etc.
   6. If a policy document is appropriate, is there any existing policy that could be amended to deal with the matter at hand, or is a new policy document needed?
2. Different approaches may be appropriate for determining the initial content of a policy document:
   1. For technical policy documents, or policy documents arising from clear legislative or regulatory requirements, it may be appropriate for a single staff member to determine the initial policy content.
   2. Where the initial direction of a policy document is clear, but input from a range of areas is needed in the initial stages, a single staff member may work in informal consultation with a range of relevant staff.
   3. For matters which require expertise from a number of areas and/or where the initial direction of the policy document is not clear, a formal working group to determine content may be appropriate. For consistency and efficiency a single member of the working group should take primary responsibility for drafting initial content.
3. Consideration should be given to whether a policy document should be classified as Policy, Procedures, Guidelines or a Code of Practice.  In addition to taking into account the definitions of each of these types of document (see “Definitions” above) the following may be considered:
   1. Policy is considered the highest level of the policy documents and is most appropriate for expressing a University position on a matter and/or detailing responsibilities of various parties (e.g. Heads of Departments).
   2. Procedures are particularly appropriate when detailing a specific course of action or process.
   3. Guidelines are appropriate for providing advice and/or for outlining a more general course of action.  Compliance with guidelines is expected, but in exceptional circumstances justifiable variations from guidelines are permitted.
   4. Codes of Practice, which are less common, provide expected standards which must be complied with and normally relate to a specific domain (e.g. Responsible Practice in Research).
   A final determination on the right classification for a policy document may be made after initial content is drafted (content may help guide the classification).
4. Where drafted policy content has a combination of policy, procedure and guideline aspects, a decision may be made on whether multiple documents are needed (e.g. a policy and associated guidelines) or whether a single document will suffice.
   1. Ease of use by those accessing the policy document(s) should guide this decision.
   2. A single document is often preferable for simplicity, unless this makes the document too long or complex.
   3. It is acceptable to have a policy which also includes procedural details and/or associated guidance.

4. Review of policy documents

1. Policy review should consider:
   1. whether the policy is achieving its purpose and is still needed
   2. whether the policy reflects the current University context and/or current University practice
   3. any lessons learnt since the policy was initiated or last reviewed
   4. any changes to related policies, regulations, statutes, legislation or other documents
   5. whether the policy is well understood, and
   6. whether the policy is clearly written and formatted in accordance with these guidelines.
2. Policy review should be supported by objective evidence where possible, which may include feedback sought and received from policy document users, and statistics on access to the policy document within the Policy Library (contact policy@otago.ac.nz for this information).
3. Where policy review leads to significant changes to a policy document, consultation on the amended document should take place as per clause 6 below.
4. Completed policy reviews should be sent to the Policy Management Group, regardless of whether the review recommends changes to the existing policy document or not.  This should be accompanied by a completed Policy Review Coversheet, available in the Policy Resources section on the Policy Library webpage
5. Additional information on policy review is available in clause 5 of the Policy Framework.

5. Amendment of policy outside of formal reviews

1. For editorial amendments and administrative amendments which are required outside of a scheduled policy review, Responsible Officers should contact policy@otago.ac.nz with an explanation of the reason for the change and the amendment required.  Such changes can be approved under clauses 4(a) and (b) of the Policy Framework.
2. Minor amendments which are required outside of a scheduled policy review should be sent to the Policy Management Group for approval, with an explanation as to why the changes are required. Consultation should take place as appropriate to the extent of the changes (see clause 6 below).
3. Where major amendments are required outside of a scheduled policy review, thought should be given to fully reviewing the policy at that point. For major changes consultation (clause 6) is strongly recommended and formal approval (clause 7) is required regardless of whether a full review is conducted.
4. Minor and major amendments outside of a scheduled policy review should only take place where there is a reasonable case for making the changes immediately. Otherwise, they should be deferred until the next policy review.

6. Consultation

1. Consultation allows the policy writer to test for broad acceptance and understanding of the proposed new or amended document and to identify any relevant matters which may have been overlooked in initial drafting.
2. Groups to consult with will vary depending on the matters addressed, but could include:
   1. Academic Divisions
   2. other University campuses
   3. specialist academic areas (e.g. Summer School, Distance Learning)
   4. groups that can offer specialist advice on relevant matters (e.g. Planning and Funding, Human Resources, the University Library)
   5. staff
   6. students (often via OUSA )
   7. external stakeholders
   8. Māori
   9. equity groups
   10. relevant committees, and
   11. relevant senior managers, and
   12. those with operational responsibilities under the policy document (e.g. ITS , administrative units).
3. It is usually preferable to consult widely for new and significantly amended policy documents, but consulting with groups with little connection to the matters being addressed should be avoided.
4. Consultation materials should include a covering memorandum or equivalent communication explaining the reason for the policy document, highlighting any important points and, in the case of amended policy, detailing key changes.
5. Where an existing policy document has been amended, changes should be clearly indicated:
   1. for less extensive amendments, the use of tracked changes is recommended
   2. for more extensive but still limited changes, highlighting amended text and including the current policy for comparison is recommended, or
   3. for comprehensively rewritten text, presenting both the amended and current policy document is recommended, with key changes highlighted in a covering memorandum.
6. Sufficient time should be given for parties to respond to consultation requests (four to six weeks is standard).
7. Where consultation produces significantly different viewpoints, a focused meeting with key parties may be an effective way to choose an appropriate approach.

7. Approval of new and amended policy documents

1. New and significantly amended policy documents being sent for final approval must (in order):
   1. be sent to the policy Sponsor for endorsement
   2. be sent to the Policy Management Group for endorsement, and then
   3. be sent to the appropriate Approval Body for final approval.
2. Responsible Officers should take account of relevant committee meeting dates in planning for implementation of a policy document.
3. Materials sent for approval should include a covering memorandum explaining the reason for the policy document, highlighting any important points and, in the case of amended policy, detailing key changes (this may be based on the consultation memorandum – see clause 6(d) above).
4. Following step 7(a)ii above, the covering memorandum should also note that the policy document has been seen and endorsed by the Policy Management Group.  Where the Policy Management Group has recommended amendments it should be noted that the Group's recommendation(s) have been incorporated (for which no explanation is required) and/or detail any substantive recommendations that have not been incorporated, with a brief explanation as to why not.
5. Where an existing policy document has been amended, changes should be clearly indicated:
   1. for less extensive amendment, the use of tracked changes is recommended
   2. for more extensive but still limited changes, highlighting amended text and including the current policy for comparison is recommended, or
   3. for comprehensively rewritten text, presenting both the amended and current policy document is recommended, with key changes highlighted in a covering memorandum.
6. The Responsible Officer should be prepared to attend any relevant committee meeting to speak to the proposed policy document and answer any questions.
7. Following approval the Responsible Officer must:
   1. make any changes required by the Approval Body
   2. provide the Secretary of the Policy Management Group with the finalised copy of the policy document (email policy@otago.ac.nz) (the Secretary will coordinate the updating of the Policy Library), and
   3. ensure completion of the Implementation and Communication Plan (see 1(k) above).

Related policies, procedures and forms

• Policy Framework
• Policy Library (including Policy Resources)
• University Writing Style Guide

Contact for further information

If you have any queries regarding the content of this policy or need further clarification, contact:

Email policy@otago.ac.nz