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Algorithmic Accountability and Recordkeeping

NZ has led the world in issuing its Algorithmic Charter for Aotearoa New Zealand in July this year. The charter is designed to ensure NZ citizens have confidence in how government agencies use algorithms and demonstrating a commitment to transparency and accountability in using data.

Algorithmic accountability has been much on my mind for a while now. I first wrote about this as an emerging issue for recordkeeping in 2016. Since that time, algorithms have been identified as decision making tools in many contexts and are likely to increase in use by organisations as the trends towards datafication of all types of things, not least of which is people.

Many books have been written identifying the inherent bias built into assumptions controlling algorithms; one of the best known of these is Professor Sofiya Noble’s Algorithms of Oppression, but many other scholarly articles have emerged around the use of algorithms. Similarly there has been an expansion of attention to data ethics, following the Snowden revelations about widespread unauthorised data collection by multiple governments and the Cambridge Analytica Facebook scandals of 2015-2016.  Some of the world’s biggest data players are even backing calls for ethical approaches to data use and regulation of AI.

Examples of misintended (we assume) results which severely impact people, are growing. They include the Google facial recognition service that labelled images based on skin colour and the earlier labelling of dark skinned individuals as ‘gorillas’; or more locally the use of AI and predictive technologies in our own home grown Robo-debt scandal linked to the suicide of a number of targeted individuals; and most recently the controversy surrounding the algorithmic grading of UK’s school leaver results in CoVID times. The emergence of the Indigenous Data Sovereignty initiatives reflect just how seriously Indigenous communities regard the appropriation and perpetuation of stereotyping in data use.  Of course there are great benefits, new insights and advantages to also be found in greater activation of data – it’s just that the problem stories show the devastating results of misapplied use of technology.

Recordkeeping and Algorithms

“3D-Printed Algorithm” by tonnerrelombard is licensed under CC BY 2.0

So what is the role of recordkeeping in the process of documenting algorithms which learn and evolve? It’s a big topic, far too big for me to be able to answer and one which needs much more work. The UK Information Commissioner’s Office is doing interesting work in building an AI Auditing Framework which will likely have recordkeeping implications. But what seems likely as a starting point is far more systematic documentation about algorithms, AI and predictive learning. So here is perhaps some beginning thoughts:

  • identify and maintain the data on which the algorithms are trained;
  • document and records all processes in the design of systems and algorithmic development;
  • clear documentation about the intent of the algorithm, and
  • development of a regular, systematic and documented auditing approach to test whether the algorithm is still doing what it set out to do.

All this also brings with it questions of individual consent (and the use of umbrella consent models), social expectations and larger social conversations about consultation, about whether the outcomes are ethical etc.

It’s a big topic – I’m not going to be the one to ‘solve’ it. There is so much to know and find out. But I am actively thinking in this space, and would love to hear from like minded recordkeeping people.

About the Author

Ms Barbara Reed, Director of Recordkeeping Innovation Pty Ltd, has been a consultant in the fields of records, archives and information management since 1985.  She is active in professional arenas, including the teaching and training environments.  She has played a major role in the development of Australian and International standards for records management, digitisation, recordkeeping metadata and others.


Information Governance in Microsoft 365

The Microsoft Office suite is familiar to most organisations today in its longstanding role as an enabler of workplace productivity. As organisations grow and adapt however, there is a need for increasingly mobile and interconnected work environments, leading to the uptake of Microsoft 365 (M365). While use of M365 in organisations is increasing, we are also seeing a steady decline in use of more traditional electronic document and records management systems (EDRMS). Many organisations are decommissioning their EDRMS in favour of native records and information management functionality available in M365.

In order to effectively utilise the M365 suite it is important that organisations understand their business and regulatory information governance requirements for securing, describing, using and managing information assets. With a good understanding of these requirements organisations can explore how native features in M365 can help meet these requirements, and where information governance compliance gaps might exist.

In this series we will look at various M365 features across three key areas:

  • Information management
  • Information security
  • Search and discovery

Information Management – Retention

Microsoft 365 provides centralised management of retention through the Security and Compliance Centre via:

  • Retention Policies – broad retention control
  • Retention Labels – granular retention control

Policies and labels can be used simultaneously within Microsoft 365, with the longest retention period taking precedence.

Retention Policies Retention Labels
Event based retention
Manage SharePoint, OneDrive, Groups and Exchange content
Manage Microsoft Teams (Chats and Channel messages), Skype for Business and Exchange Public Folders content
Manage content as a finalised record
Apply based on sensitive information
Apply based on specific words and phrases
Can be manually applied to specific documents

It is critical that organisations have a clear understanding of the type of information assets that will be captured within the various M365 solutions. Having this understanding will support identification of requirements for retention and defensible disposal of information assets. Understanding these requirements will allow for retention controls to be appropriately planned for at implementation.

In the coming weeks we will be looking at the various aspects of retention in M365 to help you better understand how you can meet your retention requirements:

  • Retention policies
  • Retention labels
  • Retention label policies
  • Event-based retention

About the Author

Adelaide Copland has worked as an information specialist and CM/TRIM application administrator since 2014.  Adelaide has experience in Microsoft 365 implementations, process improvement, records training delivery, development of policies and procedures, strategy and establishing digitisation programs.

Recordkeeping Infrastructures and Microsoft 365

A digital transformation is underway in your organisation.

“Digital Transformation” by Cerillion is licensed under CC BY 2.0

  • An organisational rollout of Microsoft 365 tools and applications.
  • Provision of a user centric environment where staff can work collaboratively, and access and share information easily where ever located, using a standard toolset.
  • Replacing a rigid technology platform with a flexible and agile cloud environment.
  • Decommissioning the electronic document and records management system (EDRMS) because it is not particularly user friendly and/or built on outdated technology.

The above points will be familiar to many as organisations transition to environments that support dynamic collaborations, co-authoring and flexible remote working with complete access to the information needed.

BUT the EDRMS is being decommissioned…

  • what about your recordkeeping requirements?
  • you have obligations to recordkeeping legislation as well as to privacy legislation amongst others?
  • How will compliance be assured?


You are the Information/Records Manager, what must you bring to the transformation project for consideration and what are your challenges:

  • The importance of maintaining the current high level of records management compliance provided by the EDRMS.
  • Management of the migration of records from the EDRMS to ensure that the recordkeeping metadata associated with the records is not lost to maintain the integrity and auditability of the record.
  • The migration of shared drive files and folder structures. Is this just moving an uncontrolled environment to another potentially uncontrolled environment?  How could / should this be done?
  • Information management governance of the collaborative environments to ensure there is a strong understanding of how Microsoft 365 applications will be used and for what types of information.
  • Where will high value / high risk records be captured, so that these records are identified and not captured in sites that are designed for routine or ephemeral information.
  • Management of and access to audit histories in the new environment.
  • Are additional tools required to achieve records management compliance or will M365 meet our requirements out of the box?

About the Author

Adelle Ford is an information and records management professional having worked in this sector since 1979, having been employed in various capacities by both public and private sector organisations. Adelle has extensive experience in strategic planning, development of records and information management frameworks, policy and procedures, business classification schemes and retention authorities for large scale organisations operating in legislatively complex business environments. Adelle has experience in and a sound knowledge of a range of information management systems, the specification of requirements, selection of enterprise content and records management systems to meet business needs, implementation of a broad range of software products and associated change management.

Digital preservation – a what, who, why, when, where, how overview

We are inundated by information and data every day and creating more information than ever before in all aspects of our lives. However, how much of the information created today is actually being preserved for future use? How, as information professionals can we ensure digital preservation of the information and records that are the life blood and the building blocks of our organisations and businesses?

As Information and Records Managers we understand:

  • That many records need to be retained long term.
  • That education and communication with users, stakeholders and other information professionals from different disciplinary backgrounds is invaluable to establishing an information culture.
  • The need to engage with IT and other information areas to make use of existing expertise and knowledge within an organisation.
  • The importance of metadata to ensure access to authentic records and information and that these can be understood in the future.
  • The risks to the organisation if valuable information is lost due to technological obsolescence and media degradation.
  • The need for standard file formats,
  • The need for standards to ensure that the data and information identified for preservation can be transferred to trusted digital repositories.
  • The importance of planning and developing strategies supported by sound policy.

Digital preservation is a complex area and it is often underestimated or even overlooked. It is often challenging convincing senior management that preservation of digital assets is an important initiative.  So how do we go about or even start thinking about the digital records that we need to preserve in perpetuity for our organisations?  How do we convince IT that the backup systems they have in place are not sustainable in ensuring that important records are accessible into the future; that digitisation of physical records is not preservation, much more is needed to ensure that digitised items can be accessed in the years to come.  What are the critical things we should be considering and planning for so we can avoid the loss of valuable information?  What tools are available to us to assist? Where do we go for advice?

We can look to the research data management and cultural heritage world for a wealth of guidance, advice and tools on digital preservation that can be applied to corporate records and information. The Digital Preservation Coalition provides an online handbook that provides good practice in creating, managing and preserving digital materials and provides a range of practical tools to assist.

Another useful tool is the Community Owned Digital Preservation Tool Registry (COPTR).  This site provides a registry of tools to assist practitioners find the right tool for the digital preservation job.  This site also provides an interactive grid to assist with navigating the large number of tools in the registry.

Figure 1: Interactive grid – COPTR

To protect valuable information assets organisations must be planning for digital preservation and engaging with all areas of the business receiving and producing records and information.

Recordkeeping Innovation is company with extensive experience in the information management field. Our team of consultants are experts and have a wealth of experience in development and implementation of information management frameworks, policy and strategy development, digital preservation policy, strategies and planning and development of metadata schemas.  The team at Recordkeeping Innovation can assist in you in planning for digital preservation.  Learn more at

About the Author

Adelle Ford has worked in the information and records management sector since 1979, having been employed in various capacities by both public and private sector organisations. Adelle has developed records management policies, strategic plans and operational procedures for large scale organisations operating in legislatively complex business environments. Adelle has experience in and a sound knowledge of a range of information management systems and has developed information governance frameworks and information inventories.  Adelle has taught records management courses through Sydney Institute (TAFE) and continues to conduct system and records management training for clients.  Adelle is currently completing a Graduate Certificate in Data Management

Protecting privacy and managing consent in e-health records

The health system is undergoing a digital transformation as more health services and practitioners adopt electronic health records. I recently attended a seminar on digital health information held by the International Association of Privacy Professionals, iapp- ANZ, and sponsored by Microsoft, that explored the many benefits, as well as the potential impediments for e-health records.
The panel of experts all acknowledge the benefits of e-health systems, especially for big data analysis supporting better disease recognition, familial tracing and diagnosis and the linking of screening program and treatment data. We are only at the beginning of health system improvements based on digital health records. Researchers are gaining new insights as existing data is enriched, digital images are captured and made accessible for improved or remote diagnosis. Data analytics and new tools can identify disease and treatment patterns in large datasets.

By Intel Free Press

Individuals receive better health care from fully informed practitioners. Practitioners need to know that frail or elderly patients are being prescribed a wide variety of medicines that may interact to cause adverse reactions. Hospitals need timely access to diagnostic test results and avoid the costs incurred when tests have to be duplicated because data cannot be accessed. Complete medical history can be accessed when a patient moves hospitals or to a new provider or is frail or incapacitated. Digital access, flexibility and sharing of data leads to better health outcomes and reduced health system costs. Australian governments are currently making significant investments developing e-health platforms to achieve these benefits.

Trust and privacy protection
How will government win trust so that patients accept e-health records? Can patients ensure that their privacy is protected? Can patients control what information is shared, who can access it, and they can withdraw their consent?
Individuals will only agree to upload and maintain their e-health records when they trust the system, when they trust the government to act as the custodian of their private information. A new regime of documented and specific consent is needed that empowers patients to control their e-health record.

Managing consent: what, how and when

1. Consent for a specific purpose
Legislation requires that e-health data can only be used for the purpose that it was collected, in most cases for individual treatment, unless the patient provides consent that information can be used for a secondary purpose. So we have the situation that data has been collected e.g. for a medical research purpose, and now we could re-use this data for analysis, treatment reviews and modelling using new techniques, but this re-use requires patients consent for a secondary purpose. However, gaining patient consent retrospectively is impractical, and requesting consent for potential and future uses is problematic when these are not yet known. Consent will need to become a more nuanced and updateable record which enables a user to withdraw consent at some future time.
2. Consent must not be a pre-condition for service delivery
Health services will need to ensure that default consent is not required or required as a condition to receiving a service. So when a patient gives permission to share test results, that doesn’t give consent for the data to be shared with others, to be sold or re-used for commercial purposes.
3. Keeping records of consent
Health practitioners and consumers need better awareness about privacy protection and the management of user’s consent. A draft consultation paper from the UK’s Information Commissioner provides guidelines on how to manage patient consent, including advice on the recordkeeping requirements for user consents. The guidance is based on principles and supporting guidelines:

  • Consent should offer genuine choice and control,
  • Requires a positive opt-in, not opt out
  • Explicit consent requires clear and specific statement of consent
  • Make it easy to withdraw consent, and tell people how
  • Keep evidence of consent,
  • Avoid making consent a precondition of a service.
  • Consent should be clear, concise and easy to understand
  • Consent should be separate from other terms and conditions.
  • Health services should provide instructions if the patient wants to withdraw their consent.

Health service providers should keep records of consent, including when and how consent was given, and updated. Health services will need to retain records to show evidence of consent. Although there is an overhead to keep sound records, the long term benefits will be a trusted e-health system.

Without trust, without explicit consent and the confidence that consent is controlled by patients, users are less likely to accept and use e-health systems.

About the Author

Kerry Gordon is a Director and Consultant with Recordkeeping Innovation. She works on digital recordkeeping and archives for clients in Australia and SEAsia.  Kerry delivers regular training programs in records management and managing digital records.  Kerry has a Masters Degree in Information Management from Monash University, Melbourne and has experience in developing large scale strategic studies for digital transition, classification and retention, managing administrative and organisational change, project management and communications supporting information governance.