Records Management and Archiving Policy

Status

Next review
Tue, 31 July 2029

This Records Management and Archiving Policy is necessary to ensure the safety, security and confidentiality of its student and financial and operational records.  It addresses Higher Education Standard 7.3, privacy principles and other legislative requirements.

Public
Visibility
Approved on: 31 Jul 2026
Review cycle: 3 Years
Owned by
Academic Standards And Risk Committee
Approved by
Operations
Category: Operations

Policy Contact:

Chief Operations Officer

Background:

This policy has been developed to ensure the appropriate maintenance of its student and financial and operational records, including archiving and destruction. It is also intended to recognise the statutory requirements which relate to records maintenance, particularly as they relate to the period of retention of records required by its regulatory and compliance agencies.

Purpose:

This Records Management and Archiving Policy is necessary to ensure the safety, security and confidentiality of its student and financial and operational records.  It addresses Higher Education Standard 7.3, privacy principles and other legislative requirements.

Scope:

This policy applies to the Chief Operations Officer and the Director of Academic Administration and Quality Assurance and the personnel that they manage.

Statement:

The College is committed to maintaining the safety and security of all its records and ensuring that private and confidential records are viewed only by the personnel authorised to access them on a need-to-know basis. The current records of the College may be categorised as follows:

  • Student Records
  • Finance and Operational Records

1 Access to Student Records

Student records may be accessed by the following College personnel:

  1. a) The person whose responsibilities include collection, collation and processing of the record (“the Record Keeper”);
  2. b) the Director of Academic Administration and Quality Assurance;
  3. c) other officers authorised by the College to collect, collate, record and maintain records of personal and academic history of students;
  4. d) Student Support Officer and Dean of Students.

1.1 Nature and purpose of student records

Student records may be in hard copy form, or electronic form, but frequently in both forms. The student records currently maintained by the College are described in the following table:

(At present, all student records are kept indefinitely. Records referenced with * are completed anonymously and individual students cannot be identified. Records referenced with ^ are directly accessible to students currently enrolled in the relevant course of study.)

Information typically collected about students Authorised Access by Purpose for which information is collected Archival Period
Application Form (a) (b) (c) (d) (e) Provides personal information necessary to assess student eligibility for enrolment and ongoing student contact Indefinitely
Change of Course (a) (b) (c) (d) Records a students’ request to change course  Indefinitely
Commonwealth Higher Education Student Support Number (CHESSN) (a) (b) (c) Records the unique national student identifier allocated to students who receive Commonwealth FEE-HELP or HECS-HELP assistance  Indefinitely
Commonwealth Assistance Notice (CAN) (a) (b) (c) Records the loan assistance that is provided to students through the Fee-Help loan arrangements  Indefinitely
Confidential Interview Form (a) (b) (c) (d) (e) Records information collected during an initial interview with a faculty member or Academic Administrator  Indefinitely
Course Deferral / Withdrawal form (a) (b) (c) (d) Records request by student to defer or withdraw from a course of study  Indefinitely
Declaration by Editor (a) (b) (c) (d) (e) Records declaration by person providing editorial assistance with an assessment task submitted by student whose first language is not English  
Unit Development and Improvement Survey* (a) (b) (c) (d) Evaluates student’s perception of the usefulness of the subject unit guide  Indefinitely

 

Student Satisfaction Survey* (a) (b) (c) (d) Evaluates student’s learning experience in College and possible future life direction.  This is done each semester by the Dean of Studies.  Indefinitely
Graduation Ceremony Survey* (a) (b) (c) Records feedback from graduands regarding their graduation ceremony experience  
Graduate Destination Survey* (a) (b) (c) (d) Records feedback from graduates regarding study experience and “achievements” after graduation.  This is done through QLT Surveys and internal reporting and internal reporting  Indefinitely
Apology for Absence (no longer used) (a) (b) (c) (d) Used in validation of student’s attendance record, to determine that attendance requirements have been met #
Minister’s  Christian Character Confidential Reference Form (a) (b) (c) (d) Minister’s Christian Character Reference is considered in assessing student eligibility for enrolment  Indefinitely
       
Miscellaneous Correspondence: College Initiated (a) (b) (c) Records letters, emails and notes initiated by College Staff into either the CRM or SMS that the college uses  Indefinitely
Miscellaneous Correspondence: Student Initiated (a) (b) (c) Records letters, emails and notes initiated by students into the CRM or SMS that the college uses.  Indefinitely
Recognition of Prior Learning/Credit Transfer Application (a) (b) (c) (d) Records application details for Recognition of Prior Learning/Credit Transfer  Indefinitely
Register of RPL/Credit Transfer Applications and Approvals (a) (b) (c) (d) Records application and approval details for Recognition of Prior Learning/Credit Transfer  Indefinitely
Request for Assignment Extension (a) (b) (c) (d) Records approval/non approval to lodge assessment tasks after due date Indefinitely
Request for Special Arrangement (a) (b) (c) (d) (e) Records approval/non approval to lodge assessment tasks after due date or if there are exceptional circumstances beyond normal extensions  
Request for FEE-HELP Assistance (a) (b) (c) Records a request for FEE-HELP Loan assistance from the Commonwealth Government via application form or enrolment form  
Request for HECS-HELP Assistance (a) (b) (c) Records a request for HECS-HELP Loan assistance from the Commonwealth Government via application form or enrolment form  Indefinitely
Enrolment Variation Form (a) (b) (c) (d) Historical Records application from student to change semester subjects #
Enrolment Form (a) (b) (c) Records students’ subject selection each semester and provides details for calculation of tuition fees  Indefinitely
Unit  Withdrawal Form (a) (b) (c) Records students’ withdrawal from subject and provides details for calculation of fee refunds  Indefinitely
 

Unit  Assessment Task Submissions

(a) (b) (c) (d)

 

 

Copies of Student’s submitted work eg  Assignments, Project Reports.  These are kept in the Online Learning Platform currently used by the college

 

^ 10 years
Grievance and Complaints Record (a) (b) Records a students’ complaint or grievance and provides details of investigation and resolution  Indefinitely
Register of Disabilities and Interventions (a) (b) (d) Records details of students’ learning disabilities and interventions  Indefinitely
 

Unit Guides

 

(a) (b) (c) (d) (e) Records detailed information about courses, such as assessments, learning outcomes and credit points 10 years
Tax File Number and / or Certificate of Application for a Tax File Number (a) (c) Records TFN, in the current SMS, the vehicle by which HECS-HELP and FEE-HELP debt records are maintained by the Australian Tax Office on advice from the College  Indefinitely
Unique Student Identifier (a)    (b) (c) (e) The USI is the student’s individual education number for life, for all courses undertaken in Australia Indefinitely

1.2 Students rights

Students have the right to request a statement describing the information held in their personal files. On receipt of such a request, the College has the obligation to supply in a timely manner, a statement which describes:-

  • the nature of the information held;
  • the main purposes for which the information is used; and
  • how individuals may go about getting access to personal information which relates to themselves.

Students (including past students) who wish to access their personal records are required to notify the College and arrange an appointment to view their records. In extenuating circumstances a student may delegate this authority in writing on the approval and verification of the Dean of Students. Students will be provided with access to their records, in particular hard copy records and printed versions of softcopy records but the following limitations would apply:-

  • students who access their records would be supervised, that is, the Record Keeper would be present while the record is being viewed.
  • students may request, and be supplied with, photocopies of any documents in the student’s personal record;
  • students would not be permitted to remove any documents from the record; however,
  • students may request that incorrect or out of date information in their personal records be removed or updated. The Record Keeper shall be responsible for taking this action.
  • students who are in dispute with the Record Keeper over any matter regarding their records, shall have the right to take action according to the College’s Complaints & Grievance Procedures (non-academic).

2 Financial and Operational Records

The current finance and operational records maintained by the College may be categorised as:

  • Staff personal details and remuneration;
  • Donors and donations;
  • Income and expenditure;
  • Finance and Audits;
  • Minutes of Meetings-Board, Sub-Committees, Staff;
  • Commercial Relationships – Agreements, Memorandums of Understanding, Partnerships

2.1 Access to financial and operational records

The financial and operational records of the College may be accessed by the following College Personnel on a need-to-know basis:

  1. a) The Principal;
    b) Chief Operations Officer;
    c) Finance Officer/CFO, and delegate;

    e) Director of Academic Administration and Quality Assurance or Delegate; and
    f) Governing Board members, including sub-committee members.

2.2 Nature and purpose of financial and operational records

The financial and operational records may be in hard copy form, or electronic form, but frequently in both forms. The financial and operational records currently maintained by the College are described in the following table:

Information typically collected with respect to Finance and Operations Authorised Access by Purpose for which information is collected Archival Period
New Employee Details Form (a) (b) (c) Records details of name, address, contact details, disabilities, allergies, emergency contact Records TFN, Bank Account Details, Superannuation Fund Details 7 years
Staff Employment Contract (b) (c) Records individual employment contract details 7 Years
Donor Details [electronic storage-Reckon, CiViCRM] (b) (c) (d) Records personal details of financial supporters 7 years
Donations [electronic storage-Reckon, CiViCRM] (a) (b) (c) (d) (f) Records donations from supporters or confidential donors 7 years
Accounts Receivable (b) (c) (f) Records receipts for services rendered 7 years
Accounts Payable  

(b) (c) (f)

 

Records invoices for services rendered 7 years
Institution Payment Summary (b) (c) (f) Records Income from FEE-HELP, HECS-HELP, CSPs 7 years
Student Fees [Electronic storage-Reckon, Paradigm] (b) (c) (d) (f) Records student’s personal payments for tuition fees, etc. 7 years
Active Direct Debit Authorities (b) (c) (d) Records current, active Direct Debit Authorities 7 years
Approved Annual Budgets (a) (b) (c) (f) Records budget preparation documents and final approved budget details 10 years
Monthly Cash Flow Reports (a) (b) (c) (f) Records actual income and expenditure, and budget comparisons 10 years
Audited Annual Financial Statements (a) (b) (c) (f) Records details of the Audited Annual Financial Statements #
Partnership Proposals – related Parties (a) (b) (e) (f) Records details negotiations with respect to proposed educational partnerships of alliances 10 years
Agreements, Memorandums of Understanding (a) (b) (c) (e) (f) Records details of agreements and MOU’s with respect to educational partnerships and alliances #

(# Records referenced with # are kept indefinitely.)

3. Archival Policy

As the College is a small educational institution, all student records shall be kept permanently. This arrangement exceeds the minimum retention period (30 years) required by accreditation and registration agencies with respect to students’ educational records. Financial Records shall generally be kept for seven (7) years. This arrangement exceeds the minimum retention period (5 years) required by Audit and Government Regulatory Agencies and the Australian Taxation Office.

Other budget, cash flow and Partnership agreement records shall be maintained for a period of ten (10) years.

Destruction of records after the required retention period shall be supervised by the Director of Academic Administration and Quality Assurance with respect to student records, and by the Chief Operations Officer with respect to all financial and operational records. Records identified for destruction shall be secured in locked “confidential wheelie bins” and collected by a corporate records destruction company which guarantees their confidential destruction.

4. Our disclosure practices

We disclose personal information about our students to:

  • education providers to administer cross-institution enrolments (where you are a cross-institution student or student enrolled with the College and another provider under an approved arrangement)
  • education providers to verify academic information or transcripts
  • scholarship providers and student sponsors where there is a written agreement between the student and the provider or sponsor.

The College discloses whether a graduate has completed an award to any member of the general public via requests for verification of qualifications.
The College is required by law to provide personal information about our students to:

  • the Commonwealth Department of Education (routinely, statistical information about student enrolment, educational background, etc)
  • the Australian Taxation Office (in relation to HECS-HELP, FEE-HELP and other loan schemes where students may defer fee payments through the taxation system)
  • the Commonwealth Government on student request for Commonwealth support or financial assistance, and particularly if you request financial assistance by submitting an electronic or paper Commonwealth Assistance Form. You will be asked to consent to personal, identifying data, including your Tax File Number, being provided to the Australian Government for the allocation of a unique identifier and the management of your Commonwealth assistance notice
  • Centrelink (which requires the College to provide information to monitor domestic student entitlements to Centrelink benefits)
  • other governments and private loan schemes where students are granted approved loans
  • the Victorian Institute of Teaching for students graduating in relevant education awards.

We also make class lists available to other students enrolled in the same unit.

Disclosure without consent or prior notification
In very limited circumstances, privacy principles permit disclosure without consent or prior notification, for example, if we are asked for the information in connection with a police investigation; if we receive a writ, subpoena or similar document legally requiring us to disclose the information; or if disclosing the information will prevent or lessen a serious and imminent threat to a person’s life or health. These circumstances are extremely rare.