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Subject:
From:
Glenn Sanders <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 30 Jun 2006 08:32:39 +1000
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Chuck

I suggest you have a look at the NSW Government's "Guide to labeling 
sensitive information"

http://www.oit.nsw.gov.au/pages.asp?CAT=764&ID=779

It focuses not on types of documents but on the potential impact of 
disclosure on the organisation. Not quite what you are after, I know, but 
it helps put things in a perspective. And in spite of the title, the Guide 
contains lots of useful suggestions on access, storage etc. Most 
importantly, it says that there are only three restricted levels (in 
confidence, protected and Highly Protected) so you don't have to figure 
out if 'top secret' is higher or lower than 'highly confidential' and so 
on. It also points out that the classification varies over time. A very 
logical document.

We are a state-owned corporation (energy distribution and retailing 
utility), that is, we operate just like a publicly-listed company, except 
that our shares are 100% owned by the state government (at least this 
month). We are not a government department, but are subject to the NSW 
State Records Act, FOI and Privacy laws.

Privacy legislation has had the biggest impact on us, and it is a bit of a 
moving target. Our legislation focuses again not on type of document, but 
on category of information, and the overall prescription is that we cannot 
reveal information which may reveal someone's identity or address. This 
gets tricky, eg for demographic surveys - if you are the only red headed 
50-yr old with 7 kids in a street or suburb, we can't reveal hair colour 
or family size information if other released details could lead to your 
residence or financial or other details being deduced. But if there are 
thousands of fecund red headed 50 yr olds, we probably can release the 
information. Hovering over all of this is the requirement that we can only 
use information for the purposes for which it was originally collected, so 
we can't use for marketing purposes, or reveal, an address originally 
acquired for the purposes of doing an electrical installation.

So our answer is, it depends on purpose and context, and it changes 
according to circumstance and over time. But overall I think you have a 
pretty comprehensive list to start from. 

I did raise my right eyebrow at your last item - if in doubt, assume it's 
confidential. NSW State Records have an official attitude that says 'if in 
doubt let it out', as do the FOI people. They have a hard time pushing 
this line against 300 yrs of "public service" tradition that assumes 
everything is by default confidential except under the greatest and most 
exceptional duress. But if you are not subject to FOI or State Records 
Acts, you are responsible only to your shareholders, so do whatever is 
appropriate.

Oh, and we do of course restrict access to anything (plans, photos etc) 
which might be of interest to terrorists or anyone wishing to get details 
of our physical infrastructure (buildings, substations, transmission 
lines). I think the phrase we used is "likely to cause death or injury to 
our staff or members of the public". NSW State Records has a rule that all 
documents over 30 yrs old are by default freely available, even if still 
in current use, and you can see a list of exceptions (Access Regulations) 
at

http://www.records.nsw.gov.au/recordkeeping/access_regulation_5341.asp

And before anyone asks why we have currently active documents over 30 
years old, construction projects, plans, contracts etc are retained for 
life of asset plus 7. How long does a substation last?

Cheers

Glenn

Glenn Sanders MRMA
[log in to unmask]
[log in to unmask]
Australia

These views are mine alone. They may or may not be those of any
previous or present employers or clients. I don't know. If I'd asked
and they'd agreed, I would have signed it "Harry Peck and Co and
Glenn". Or whatever. But I haven't, so I didn't.



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