RIMPA Global's Advocacy Efforts Yield Positive Results in Q4

Effort 1: Data Minimisation and Retention Best Practice Guidance

RIMPA Global played a pivotal role in shaping industry practices by providing feedback on the draft Data Minimisation and Retention Best Practice Guidance put forth by Digital Service Providers Australia and New Zealand (DSPANZ). The document outlines recordkeeping requirements for digital service providers (DSPs) under Australian taxation and employment law.

Key Points from RIMPA Global's Feedback:

• Clarity on Data Roles: Advocated for a clearer distinction between the roles of data custodian and data owner, emphasizing the importance of defining management roles and responsibilities.
• Precision in Language: Cautioned against using the phrase 'maximum retention,' highlighting the potential for misinterpretation and the associated risks of data loss or premature disposal. Recommended the use of 'minimum retention' in alignment with legislative record retention obligations.
• Informed Customer Practices: Emphasized the need to fully inform customers about the implications of retention practices on the performance of aggregated data sets, encouraging longer retention as a catalyst for improved data quality.
• Data Portability Considerations: Raised concerns about the absence of guidance on the retention/deletion of data created during the data portability process, advocating for avoiding 'just in case' retention practices.
• Contractual Safeguards: Recommended the inclusion of data deletion certificates, client acknowledgment, and specific conditions in all contracts, ensuring the clear definition of risks under a Software as a Service (SaaS) model.

Effort 2: Public Records Bill (Qld) 2023

RIMPA Global actively engaged with the Queensland Parliament Community Support and Services Committee to address concerns related to the Public Records Bill 2023.

Key Points from RIMPA Global's Submission:

• Modernized Definition of 'Record': Advocated for an updated definition of a 'record' that comprehensively represents the complexity of record creation in the digital age, encompassing fields, tables, databases, digital workflows, and multiple systems.
• Timely Preservation: Highlighted the necessity for recursive and timely preservation of digital records of long-term temporary value alongside permanent archival records, preventing unintended loss of crucial historical business information.

Effort 3: Proactive Advocacy for APS Records Management Reform

In a proactive move, RIMPA took the initiative to address the long-standing inadequacies in APS records management. A letter was sent to the Prime Minister, advocating for immediate action, highlighting these issues as repeatedly reported in royal commissions, audits, and inquiries.

The response from the office of the Hon Tony Burke was received, offering a high-level response that did not definitively answer specific questions. Instead, it suggested that the data and digital government strategy would overcome any challenges.

RIMPA will continue to advocate for improved information and records management practice in the APS and to better equip those responsible for information with contemporary digital management skills and capabilties. 

RIMPA Global's active involvement in these advocacy efforts demonstrates its commitment to advancing best practices and shaping legislation that aligns with the evolving landscape of data management and recordkeeping.