Our focus over the last year has been to develop a work programme ensuring that our regulatory approach is fit for purpose in an increasingly digital environment.  In 2018 we shared some of our initial thinking of what this might look like through our engagement on the Regulatory Programme. Findings from this engagement supported looking at a new approach for disposal authorisation.

Why do we need a new approach?

Disposal authorities (DAs) are usually agency specific and agencies develop their own DA with support from us. Many agencies share common functions and create similar records like the District Health Boards (DHBs) and Crown Research Institutes (CRIs). Sometimes this creates inconsistency in assessing the value of records of the same function such as varied retention periods and disposal actions for the same type of records.

Development of a DA often takes one to two years and it is not unusual to be drawn out over several years, depending on available resources in agencies and in our organisation.  To make this easier we are exploring ways of streamlining to create a more sustainable process for agencies and ourselves.  A functional disposal authority concept is our current thinking and we are piloting this new approach.

What is a functional disposal authority?

Functional disposal authorities (FDAs), are based on functions and activities of Government. The intention is that FDAs cover high level functions carried out by and/or common to more than one agency, but not all-of-Government. Agencies will be able to construct their disposal coverage by selecting from a range of FDAs and if needed still create an agency specific disposal authority for example for functions unique to their agency.

In developing a new approach, we needed to test the feasibility of FDAs. A pilot with the DHBs was initiated to test this.

The DHB pilot

We approached DHBs and the Ministry of Health to form a working group for a pilot project. By working collaboratively, the group aims to transform the concept of FDAs into a viable form.

Together, by analysing the DHB’s disposal authority (DA262), issues and gaps were identified that needed to be resolved and improved for practical implementation. The working group also identified that the authority needed to be more inclusive and flexible for easier implementation. If a set of record classes fulfilled the same function, had the same minimum retention period and the same disposal action they were joined up as a single class. This process has produced three functional disposal authorities: FDA1 – Personal Health Information; FDA2 – Health Administration; FDA3 – Population Health and Wellbeing.

Each FDA encompasses several classes which together capture the records related to that broad function e.g. health administration. Although each of the DHBs will sign up to all three of the FDAs, other agencies that maintain similar functions can sign up to any of them if appropriate. For example, agencies dealing with patient information will be encouraged to sign up to FDA1 where others carrying out medical research functions can sign up to FDA3.

Our next steps

The working group has completed internal consultation within the DHBs.  We are now planning engagement with external stakeholders which will be in two phases. Firstly, we will ask key agencies with similar or related functions if the FDAs are applicable to their information and records. Secondly, we will ask other agencies in the public sector for their general comments on the new approach and disposal recommendations.

Based on feedback from stakeholders we will use an iterative approach to continue to develop and refine the new FDA concept.

We look forward to sharing the engagement results and further progress with you. If you have any questions or comments please get in touch .