Insights from practitioners in Information Management

To destroy or not, who makes the decisions? by Shirley R Cowcher

I read an article in the Weekend West of 18-19 August 2012(1) about a former State secretary of the Australian Workers Union who could “…still recall his decision to box up and lock away hundreds of documents in the late 1990’s knowing that the stench of the financial dealings would one day return.” 

Of course this article is referring to the alleged frauds of union officials which were investigated in 1995 and 1996.  I found the caption under the picture of the former State secretary a little concerning as it stated “…he has documents in storage that may hold clues to the alleged frauds”.  I realise that there may be some journalistic licence in this report but the points I want to raise here are associated with whose responsibility it is to determine whether to keep or destroy documents and the ownership of the documents.

Firstly, let me address the matter of who decides whether documents should be kept or not.  Every organisation, whether public, private, Not-For-Profit or a Registered Organisation must adhere to the law. In some cases legislation that is applicable to an organisation will indicate, either directly or by implication, that documents must be kept.  The legislation may even indicate how long the documents must be kept but in many cases this is not stated.  If the period of retention for the documents is not stated then the organisation must be aware of the broader legislative requirements relating to statutes of limitations and laws of evidence which may be applicable to the types of documents or the activities to which the documents relate.  It is not for any one individual in any organisation to decide what to keep and what to throw away.  It is the responsibility of the directors, appointed officials or owner of an organisation to develop and adhere to information governance policy, which is an essential part of the overall corporate governance of an organisation.  The implementation of an information governance policy framework will ensure that all documents are kept, managed and disposed of in a manner that will provide accountability of, and minimise risk to, the organisation.  A retention schedule is an integral part of the information governance policy framework and is structured to identify categories of documents and the retention requirements for each category, as specified by legislative requirements.  Unfortunately, it has been my experience for the past 26 years that few organisations fully meet requirements with regard to information governance and many directors, appointed officials and business owners are ignorant of their responsibilities.

On the matter of documents being held by the former State secretary, I would hope that this is a case of inaccurate reporting.  All documents created or received by appointed officials or employees of an organisation belong to the organisation!  At no point should any organisation allow its documents to be removed and held by former employees, directors or appointed officials.  Documents are created and held as proof of activities undertaken and decisions made in the course of operations.  They are an information asset of the organisation and provide a means of accountability and risk minimisation.  In addition, they provide information to the organisation that may be referenced and interpreted in a way that will bring additional value to the organisation.  If they are mismanaged and removed from the organisation they may also become a liability in that they are likely to be read out of context or may even divulge information that is confidential or contains personal details.

I am passing no judgement in the matter referred to by the West Australian, however, I am expressing some concern that it would appear, if we are to believe what has been reported, that the union had no information governance policy framework in place and was allowing individuals to manage documents as if they were the personal property of those individuals rather than a valuable asset of the organisation.  Should we be concerned?  Yes, if what has been reported here is correct then this is just one example of an organisation not managing its information in a responsible way to ensure corporate governance.

(1) Push to relaunch fraud probe, Gary Adshead and Sean Cowan, The Weekend West, 18-19 August 2012, p7