Over-retention of records

Risks of over-retention

Over-retaining records and data goes against the principles and standards set out in information legislation, including the Public Records Act 1973 (Vic) and Privacy and Data Protection Act 2014 (Vic).

Over-retention poses compliance risks, as well as potential legal, monetary and reputational risks to the University. It can contribute to:

• Privacy breaches
• Legal disputes
• Identity theft.

Avoiding over-retention

To eliminate and reduce the risks of over-retention, it is good practice for work units to regularly identify and dispose of University records and data, once they are time-expired and are no longer required for University business, or pending requests.

Any copies or ephemeral records and data can be destroyed as soon as reference or use concludes. Refer to Normal Administrative Practice (NAP) for guidance.

Practical steps to undertake

1. Refer to Retention and disposal for guidance and steps on how to lawfully dispose of University records and data. Refer to NAP for information about destroying copies and ephemeral records and data.
2. Consult the University Records RDA to determine the value and required minimum legal retention periods for University records and data. Records and data should rarely be retained beyond the minimum retention period outlined in the RDA.
3. Carry out disposal action, as outlined in the RDA. The action will be different depending on whether the record/data is temporary or permanent:
   • Once the required minimum legal retention period for temporary records/data is reached and the business has confirmed no further allowable purpose for them, work units should destroy the records/data. Follow guidance outlined in Destruction of temporary records.
   • Records and data of permanent value must be transferred to Records & Information when no longer needed for business purposes - this will ensure they are preserved, protected and access is managed appropriately over time. Follow guidance outlined in Transfer of permanent records.