Te hopu i te Urupare ki te KOWHEORI-19

Documenting the COVID-19 Response

Since the start of the COVID-19 response the public sector has had to deal with multiple lockdowns, changes in how we work and where we work, and new recordkeeping challenges, such as holding registers to assist in contact tracing. The move to the COVID-19 Protection Framework (traffic light system) offers an opportunity to review what this means for your ongoing management of Covid-19 related records.

Throughout this time the core Public Records Act 2005 obligation to create and maintain full and accurate records in accordance with prudent business practice has remained more important than ever. As we continue to develop our approaches and adapt to new ways of working it is important to reflect on the following questions:

• Has accountability for decisions and actions been recorded and made easily accessible in this rapidly changing environment?

• How has your organisation ensured that adequate information management support is provided for remote working environments? Do you have a plan in place to control and capture records created outside your core business systems?

• How has the adoption of new applications and tools to manage your organisation’s work impacted on information management? For example, has adequate information management support been provided for remote working environments?

• How has information handover been managed for staff who are being cycled through shifts and assignments? Has maintaining a complete and accurate record been supported by system design?

Since the start of the pandemic public offices have created records to assist in managing the spread of COVID-19. The most common are those that track visitors through contact tracing registers and evidence of their vaccination status. These records were covered under General Disposal Authority 6 (GDA6) with the introduction of class 9.1.1 in July 2021.

This authority allows this new class of records to be destroyed when all legislative have been met and they are administratively no longer required. The purpose of class 9.1.1 is to provide public offices with a class to effectively manage records that contain personal information of everyone that visits a public office, collected for the purposes of tracking people’s movements during a pandemic, epidemic, or other similar public health related emergency.

With the introduction of the vaccination passport, this class is being clarified to ensure that the tracing records include vaccine checks for visitors and contractors as well. We are always seeking feedback on the performance of the GDAs, please reach out to us if you have any comments.

Use cases for GDA6 class 9.1.1

• Did your organisation collect information of staff, students and visitors providing proof of vaccination in order to access sites and facilities?

• Did your organisation keep an aggregated record of this information?

If you answer yes to both of these questions, then the aggregated record that was created falls under this class.

Another significant class of records now being created are those registering the vaccination status of staff. These records are covered under GDA6 class 3 Human Resources Management, subclass 3.5.7 (Employee Health, Safety & Welfare), and may be destroyed seven years after the last information entry date.

Prudent business practice encourages retaining records relating to health, safety & welfare administration for future reference, to assist in dispute resolution or provide evidence of business decisions. For this reason, the minimum retention period of seven years is appropriate.

Use cases for GDA6 class 3.5.7

• Did your organisation institute a policy or public health order that required staff to provide proof of vaccination as a condition of their ongoing employment?

• Did your organisation keep an aggregated record of proof that this condition was met?

If you answer yes to both of these questions, then the aggregated record that was created falls under this class.

The GDAs and agency specific disposal authorities are designed to be as broad as possible to keep them resilient in the face of significant events. They should be sufficient to assist you in managing your records related to COVID-19.

If you are creating records related to COVID-19 and are not sure what class they fit into, or your use cases do not fit the criteria described above, contact us to discuss how best to manage those records.

Archives New Zealand staff are available to provide advice and to work with you if any issues arise regarding recordkeeping, disposal or the implementation of existing authorities.

Email: rkadvice@dia.govt.nz.