Monitoring activities

Who the guidelines are for

The guidelines will be useful for records managers, other staff with responsibility for managing the records management program, or those responsible for implementing a monitoring program for recordkeeping.

Monitoring should be scalable to your organisation’s needs and resources. If necessary, prioritise areas of concern such as high-risk business unit/s, or high-risk recordkeeping processes, such as disposal or capturing of records. 

Compliance monitoring

Compliance is adhering to the requirements of laws, industry and organisational standards and codes, principles of good governance and accepted community and ethical standards (AS 3806 - 2006: Compliance Programs, section 1.3.3).

Compliance monitoring and compliance auditing aim to establish whether a process or procedure is carried out in conformance with relevant external requirements, whether set through legislation, regulations or directions. It involves examining, at a fairly straightforward level, how organisations 'do something' and confirming 'compliance' with criteria (CB029 – 2003, The Audit Skills Handbook, section 1.8).

Public offices should regularly assess their conformity with the obligations of the State Records Act 1998 and the associated standards and codes of best practice to ensure that the organisation is compliant and that issues of non-compliance are corrected.

Types of compliance monitoring

Compliance monitoring activities can range from:

• assessing compliance with obligations in the State Records Act
• assessing the records management program
• assessing recordkeeping
• assessing the management of records
• assessing records management system and business systems that create and capture records.

Documenting compliance monitoring activities is an important component in demonstrating the organisation's compliance with the State Records Act and associated standards and codes of best practice. Public offices may be asked about their monitoring activities by State Records NSW when investigating recordkeeping issues.

They may also be asked about their monitoring of recordkeeping activities by other organisations with an interest in good records management, such as the Information and Privacy Commission, the Independent Commission Against Corruption, and The Audit Office of NSW.

Accurate, up-to-date records of the organization's compliance activities should be maintained to assist in the monitoring and review process and demonstrate conformity with the [compliance] program (Section 5.2.1 of the Australian Standard AS 3806 – 2006: Compliance Programs).

Ways to monitor compliance

Organisations can monitor their compliance by:

• using the Records Management Assessment Tool
• assessing compliance against the requirements of each standard issued by State Records NSW
• benchmarking against previous records management self-assessment surveys or audit results to assess improvements or to identify issues of non-compliance
• undertaking a compliance audit using internal auditors or an external party to provide an independent assessment of the organisation's records management program, practices and systems.

Public offices may consider using the services of a consultant, internal or external auditors to conduct compliance monitoring activities.

Performance monitoring

Performance monitoring involves an in-depth analysis of a process or project, to determine whether it is efficient and effective. It involves developing criteria, conducting interviews and examining documentation to determine how the process or project is conducted. This type of monitoring is also referred to as a process audit (CB029 – 2003, The Audit Skills Handbook, section 1.8).

Organisations typically measure performance to determine if a process or practice is effective and whether objectives or targets are being met.

Measuring performance allows the organisation to not just measure whether an outcome is being achieved, but how well or the degree of satisfaction of the outcome – it is a 'qualitative' form of measurement.

Performance measurement can also assist the organisation in determining how capable it is and whether the organisation’s capability can be extended to new practices or processes.

Regular assessment

Public offices should regularly assess the effectiveness and efficiency of their recordkeeping systems and processes to:

• ensure that they are satisfactory and meet the public office's business needs
• support continuous improvement in line with the organisation’s business objectives
• identify achievements and successes
• comply with standards issued by State Records NSW
• plan for new services or upgrades to existing tools and services.

This type of monitoring can be undertaken as part of an internal audit process or in cases where there are suspicions of maladministration or fraud.

Types of performance monitoring

Performance monitoring activities can range from monitoring:

• overall performance of the organisation's records management program
• recordkeeping by business units, workgroups or individuals
• records management processes
• records management systems
• delivery of records management services by service providers, and
• assessing the records management capability of the organisation.

Performance monitoring can also include targeted assessments of recordkeeping. For example, assessing high risk business areas to ensure that:

• records are being created and captured
• those records are adequate for providing evidence of the business of the organisation.

The starting point for some performance monitoring activities may be the identification of a business issue/problem. The organisation can analyse the problem using the relevant tool and develop a solution which may involve updating processes or developing new processes.

Ways to monitor performance

Organisations can monitor their performance by:

• conducting assessments using the plans, goals and objectives of the records management program
• assessing feedback from clients of the services provided by the records management program
• benchmarking against standards such as AS/ISO 15489 and standards issued by NSW State Records NSW
• assessing the level of understanding and use of records management policies and procedures by staff
• assessing progress against the organisation's storage and disposal plan
• conducting an internal audit of recordkeeping and/or management of records
• using the Records Management Assessment Tool
• conducting detailed reviews of high-risk business areas to confirm that records are being created and captured into the recordkeeping system.

Organisations may also seek independent or external performance monitoring of their recordkeeping and management of records for example, auditors can undertake both performance and compliance monitoring of recordkeeping processes and systems.

Ensuring monitoring is useful

Monitoring will only be useful if a number of criteria are met. These are:

• clearly defined objectives
• adequate resources to carry out the monitoring
• appropriate performance measures
• senior management support for using results to improve performance
• regular review of objectives and indicators to make sure they remain relevant.