managing social media as records a best practice guide for

March 2020

Managing Social Media as Records A Best Practice Guide for

New Zealand Local Authorities

Managing Social Media as Records: Best Practice Guide for Local Government

© ALGIM Association of Local Government Information Management 1

Contents 1 Executive Summary ......................................................................................................................... 3

2 Introduction .................................................................................................................................... 4

2.1 Purpose ................................................................................................................................... 4

2.2 Background ............................................................................................................................. 4

2.3 Understanding the challenge facing Local Authorities ........................................................... 4

2.4 Scope of these guidelines ....................................................................................................... 6

3 Information Management Requirements ....................................................................................... 7

3.1 Social media communications are records ............................................................................. 7

3.2 The Information and Records Management Standard 2016 .................................................. 8

3.3 Publishing versus ongoing management and storage ............................................................ 8

3.4 Determining the value of the posts and responses ................................................................ 9

4 Legislative requirements for the management of social media ................................................... 11

4.1 Public Records Act 2005 ........................................................................................................ 11

4.2 Privacy Act 2020 .................................................................................................................... 12

4.3 Local Government Official Information and Meetings Act 1987 .......................................... 13

4.4 Contract and Commercial Law Act 2017 ............................................................................... 13

5 Technology requirements to manage social media as records .................................................... 14

5.1 High level assessment of technology tools ........................................................................... 14

5.2 The roles of the different technology tools for managing social media records .................. 14

5.3 Using technology to capture social media ............................................................................ 16

5.4 High level requirements for social media capture and storage tools ................................... 17

6 Social Media Policy and IM/RM Policy .......................................................................................... 19

6.1 Key information management inclusions for your social media policy ................................ 19

6.2 Records management clauses to include in social media policy/procedures ...................... 19

6.2.1 Guidance for policy content .......................................................................................... 19

6.2.2 Guidance for procedures content ................................................................................. 20

7 Education requirements for staff using and managing social media ........................................... 21

7.1 Core requirements for educating personnel managing social media records...................... 21

7.2 Roles of personnel managing social media archiving ........................................................... 21

7.3 Training and induction outline .............................................................................................. 22

8 Implementation of the guidelines................................................................................................. 22

Appendix 1 – Answers to Frequently Asked Questions ........................................................................ 23

Appendix 2 – Requirements from the Information and Records Management Standard 2016 of Relevance to Managing Social Media ................................................................................................... 25

Appendix 3 – Glossary of terms ............................................................................................................ 28



Appendix 4 – Public Records Act 2005 Requirements .......................................................................... 29

Appendix 5 - Identifying the value of social media content ................................................................. 32

Appendix 6 – FAQs raised from SM Guide presentations to members ................................................ 33

Appendix 7 –Social Media Policy – Sample Template .......................................................................... 36

Version Published: March 2020 Author: This guide was written for ALGIM for its members use. ALGIM engaged Siatiras Consulting Ltd to facilitate the working group and write the guide content. Disclaimer: The content in this guide is intended for the use of ALGIM members including the Digital Local Government Partnership group. The purpose of the best practice guide is to provide guidance to local government on their practices for managing social media as records. This content cannot be used for any other purpose without the permission of ALGIM. Please contact ALGIM for more information: email: [email protected], website: www.algim.org.nz

ALGIM would like to acknowledge and thank the Working Group who assisted with the development of these guidelines, acknowledgement goes to:

Lauren Bennett Marketing and Communications Adviser, New Plymouth District Council Mike Chapman Manager System Strategy and Standards, Archives New Zealand Jacqueline Davidson Corporate Records and Archives Manager, Auckland Council Mandy Evans Digital Services Manager, Marlborough District Council Paul Hayton Marketing Coordinator, Council Communications and Marketing, Dunedin

City Council Kyla Huff Senior Advisor Content and Channels, Kapiti Coast District Council Mike Manson Chief Executive Officer, ALGIM Lesley Officer IM Toolkit Lead, ALGIM Leonie Robinson IM Specialist, Ashburton District Council (formerly) Kerri Siatiras Information and Records Management Consultant, Siatiras Consulting

Limited Suzee Sinclair Programme Coordinator, ALGIM Angus Westgarth Digital Content Coordinator, Timaru District Council

mailto:[email protected]

http://www.algim.org.nz/



1 Executive Summary As part of the Digital Local Government Partnership Programme, ALGIM undertook to provide best practice guidance to Local Authorities on the management of social media as records. The need for this guidance arose from a lack of understanding of what Local Government needs to do to be compliant with the Public Records Act 2005 (PRA). This document provides that guidance.

There are five areas that the ALGIM working party addressed:

1. Information management responsibilities 2. Legislative requirements 3. Technology considerations 4. Policy and procedure requirements 5. Education of the Local Government sector

The best practice approach for Local Government in relation to managing social media as records is to achieve the following outcomes:

These outcomes can be achieved through the:

• Acquisition of appropriate tools that are compliant with information and records management legislation and standards in order to efficiently manage social media posts and responses as local authority records.

• Implementing appropriate practices, policies and procedures and systems to: o retain social media posts and responses deemed to be of archival value in council

recordkeeping systems o dispose of social media posts and responses as per appropriate disposal procedures

as outlined in the guide • Development of training material and provision of training on “managing social media as

records” for all roles involved in social media posts and conversations.

Social Media posts and responses deemed to be of archival value are stored appropriately in the councils recordkeeping systems

An efficient and effective way to retrieve and manage social media posts and responses is provided

There are appropriate personnel with competencies to manage social media as local authority records



2 Introduction 2.1 Purpose The purpose of these guidelines is to provide New Zealand Local Authorities with a set of guidelines for managing social media as records. They have been developed as part of the Digital Local Government Partnership Programme.

The intended audience for these guidelines is Local Authority communications, marketing, information, and records management staff. These guidelines should inform Local Authority social media policy and management practices.

Included in these guidelines are the information management requirements for managing social media posts and responses such as:

• The metadata to collect • Retrieving social media posts and conversations • Determining the archival value • Retention (how long to keep) • Disposal (what to do when you delete or archive)

The guidelines outline the technology considerations to support managing social media as records. They also outline the content required for a social media policy and the education and training requirements for all staff using and managing social media. This includes Information & Records Management and Communications & Marketing personnel working in Local Government.

2.2 Background ALGIM conducts an annual Snapshot Survey of the Web and Digital Sector, across the Local Government sector. Included in this survey are several questions related to social media archiving. Some of the findings of the 2019 survey were:

• approximately 18 Local Authorities do not archive social media, • 20 councils are using Facebook Archiving, • 12 councils use electronic document and records management systems (EDRMS) systems to

archive social media and, • Another 29 councils undertake manual archiving.

(NB. Full survey results of the 2019 ALGIM Snapshot Survey are available from ALGIM).

It is apparent from the survey results that Local Authorities are in different stages of readiness and understanding about the management of social media posts as records. Furthermore, the responses indicate that Local Authorities are not consistently managing their social media posts as records, let alone archiving those that have permanent value.

2.3 Understanding the challenge facing Local Authorities Social media has become an important business communication tool that creates and captures business information. Social media posts that relate to a Local Authority’s business activity are Local Authority records. They need to be captured using appropriate methods to ensure they are accessible and usable for as long as required, i.e. social media posts must be managed like all other business information and records that Local Authorities create and receive.

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There are a number of benefits and risks of using social media as a communication channel.

Each Local Authority may use different social media channels. The list below is not exhaustive but provides examples of channels commonly in use in New Zealand Local Authorities.

• Facebook • Instagram • Council websites • Twitter • YouTube

• Yammer • Slack • LinkedIn • Neighbourly • Antenno

The challenge facing Local Authorities is how to manage social media as records. One way to understand and address this challenge is to answer the questions that Local Authorities commonly have in relation to social media:

• Are all social media posts made on official Local Authority social media channels a Local Authority record?

• If they are Local Authority records, what does that mean? • How long should social media posts (and responses) be retained for? • Are any of the social media posts (and responses) of permanent value? • How do we determine which social media posts have permanent value? • If all social media posts are of short-term value, do we need to do anything? • What are the information management responsibilities around social media posts? • What roles should be involved in setting social media policy? • What training do staff require with regards to use and management of social media? • What tools are available to assist with managing social media? • Which tools provide the necessary functionality to manage social media posts over time (if

that is required)? • What metadata must be captured with any social media post if we need to archive it? • How would you treat elected members’ posts on Social Media? • If the Local Authority is tagged on a post, does that mean that the Local Authority is being

specifically communicated with, or are we just concerned with what is being posted on the Local Authority’s own channels?

The benefits are:• Promotes services• Promotes events• Engages with customers• Increases speed of feedback and input• Promotes transparency• Enhances democracy• Improves customer service• Provides additional channels for customer engagement• Reaches specific audiences• Allows organisation to stay in touch with customers from anywhere at a low cost• Easy to use and it is free

The risks are:• Inaccurate or inappropriate information could be posted creating legal/reputational risk• Some sites may be open to manipulation by interest groups/users • User content may be difficult to check for accuracy• Greater resource requirements for managing social media sites • May not comply with the Public Records Act 2005 or the Privacy Act 2020•Private messages posted by staff or officials will be viewed by the public to be official messages



• How should Local Authorities deal with the disposal of social media records?

These guidelines will assist with addressing the challenge of managing social media as Local Authority records. Please refer to Appendix 1 for answers to the questions posed above. 2.4 Scope of these guidelines The scope of these guidelines covers all social media channels used by New Zealand Local Authorities. In scope:

Out of scope1:

These guidelines have been structured into five areas:

1 NB. ’Out of scope’ for these guidelines however each Local authority should include policy statements in their Social Media Policy covering these circumstances.

Social media tools used by Local Authority's to communicate with external parties

Posts made by all staff, whether the original post or a reply to a comment, on official Local Authority social media channels

Posts by Elected Members published on an official Local Authority social media channel on behalf of the Local Authority

Posts made about, or relating to, the Local Authority, or Elected Members on other private or public social media channels not managed by the Local Authority

Information management

requirements for social media

Technology requirements for managing social

media

Education requirements for

staff managing social media

Policy requirements for managing social

media

Legislative requirements for managing social

media



3 Information Management Requirements 3.1 Social media communications are records Local Authorities create and keep information and records to answer questions, tell a story, protect the Local Authority, and create a sense of identity. They show how council presents itself to the community and how the community is interacting with the council. They also show transparency and accountability. If a Local Authority is creating and keeping records, then they must be able to:

• Find it and use it • Trust it • Know how to find it • Know who can access it (and who has accessed it) • Know of any changes to it

Therefore, searchability and usability are key requirements.

Social media posts and responses (content) are records. They must therefore be managed so they meet legislative and information management requirements.

Requirements for the management of social media as records are in most ways no different to the requirements when managing any other form of Local Government information or records. They involve requirements and best practice actions relating to:

• Creation and control • Maintenance • Access and use • Storage • Disposal (deletion or archiving)

The information management requirements and implications with regards to social media for Local Authorities are:

Social media posts and responses are records.

They must therefore be managed so as to meet the requirements of the mandatory Information and Records Management Standard 2016.

Local Authorities must determine which social media posts have archival value as they will require greater management than those of transitory value.

Posts and responses (made by either the Local Authority or the public on a Local Authority channel), with archival value should be saved into councils’ recordkeeping systems for preservation. This is because social media publishing tools are typically not designed to meet the minimum requirements of the mandatory Standard. So, while they may have functionality that will allow for the capture and storage of social media posts and responses, they are not in fact viable long-term storage options.

Deletion of social media posts and responses must follow set processes and be authorised within an approved disposal schedule for the Local Authority.

The challenge facing Local Authorities is how to manage social media content as records.



Determining how involves understanding the ongoing value of any social media post or response. Local Authorities must determine which social media posts have archival value as they will require greater management than those of transitory value.

That determination of value will then influence which systems, tools, processes, and actions need to be taken to manage the content over time and with appropriate levels of access

3.2 The Information and Records Management Standard 2016 Most information management requirements are listed in the Information and Records Management Standard 2016 (the Standard). This is a mandatory standard that covers what Local Authorities should be doing to manage their information and records, including social media. The Standard provides requirements for the governance, management, creation, use, disposal, and storage of records (whether hard copy or digital). It has three principles:

• Organisations are responsible for managing their information and records • Information and records management supports business • Information and records are well managed

The Standard also has 21 requirements. Appendix 2 provides a list of the requirements from the Standard that have particular relevance to the management of social media.

The starting position from an information management perspective for social media in Local Authorities is that all posts and responses published on Local Authority operated channels are Local Authority records as defined by the Public Records Act.

There are certain standards and practices therefore that must be adhered to with two key information management considerations to address in their management:

1. To differentiate between the publishing of social media posts and responses and the management of the posts and responses over time

2. To ensure that the determination of value of the social media posts and responses is managed practically and appropriately

3.3 Publishing versus ongoing management and storage The Standard is concerned with setting out requirements for the management of records that have more than transitory value. To meet the Standards’ minimum requirements a Local Authority must differentiate between the idea of publishing information and managing information over time. This is of particular importance for social media where the tools used to create and publish posts (e.g. Facebook) are not the same tools that are necessarily appropriate for the long-term storage of posts and responses retained as local authority archives.

However, it is also true that very few social media posts and responses will have long term value. The management of social media posts and responses must be fit for their value over time. This means that posts and/or responses that have archival value should be saved into a recordkeeping repository that will support the minimum requirements of the Standard. As well as the mandatory Standard, Archives New Zealand have recently released Best practice guidance on digital storage and preservation (20/G17) which provides guidance about preserving and storing digital records over time.

https://apc01.safelinks.protection.outlook.com/?url=https%3A%2F%2Farchives.govt.nz%2Fmanage-information%2Fresources-and-guides%2Foperational%2Fbest-practice-guidance-on-digital-storage-and-preservation&data=02%7C01%7Cnzrecords%40lists.vuw.ac.nz%7Cac688d8d9df14f6be45808d7ba3386ff%7Ccfe63e236951427e8683bb84dcf1d20c%7C0%7C0%7C637182602848893716&sdata=xQX%2BbSVUrR8pArl1LJzBF2gkHOSvkiADhkpSLI8LRTI%3D&reserved=0




Organisations must manage metadata associated with information and records. They must do this to meet minimum compliance requirements 2.3, 3.2 and 3.3 of the Standard, see Appendix 2.

When creating social media posts or responses the following mandatory minimum metadata must be captured and retained with the post:

• Unique identifier • Name • Date created • Business activity documented • Creator (person or system) • Name and version of the software application used to create a digital record • Any later actions carried out on, such as accessing, modifying, or disposing • Identification of the persons or systems carrying out those later actions • Dates those actions were carried out

To protect the integrity of the record when the social media post is transferred from its publishing tool into a storage repository the metadata that was generated when it was created must be transferred with it.

The Local Authority may need to assign further metadata in order to:

• Ensure that the record is full and accurate • Establish a complete context • Prove authenticity

3.4 Determining the value of the posts and responses A large part of fulfilling information management requirements can only be achieved if the value of the post and responses over time is understood, as that will dictate the level of management that the Local Authority should place over these records.

With social media we need to identify what posts and responses have long term value:

• What business value does it have? • What archival value does it have? • What community/local interest value does it have?

While social media posts and responses are not classed as protected records as a general ‘type’ of record, certain posts may well be considered to be protected records and therefore cannot be deleted without the approval of the Chief Archivist. They should therefore be treated as local authority archives. For example, if the social media posts and responses are about Council announcing significant spending on a project, which generates significant public response (either in terms of quantity, or content), then the posts and responses should be kept as archives along with all of the other records about that project.

The disposal schedule used by the Local Authority will specify what information and records must be kept as archives. Determination of value is primarily based on context and content. Disposal Schedules approved by the Chief Archivist do not differentiate between formats, so irrespective of whether the record is a social media post, a document or a digital photo, the same disposal action of



archive may be required if it is on a certain topic. For social media, identifying the posts and responses of archival value is a hard task. One way to do this is to carry out a task of working through the disposal schedule and mapping it to the type of content published on each social media channel in use by the Local Authority.

For those posts and responses that are being deleted, metadata must also be generated or captured during the disposal process and retained for as long as required to account for the disposal of records.

When deleting posts and responses the following metadata must be captured to support minimum compliance with requirements 3.1 and 3.4 of the Standard.

• Unique identifier • Name • Date created • Business activity documented • Creator (person or system) • Date of disposal • Authority governing the disposal • Person or role carrying out the disposal A list must also be kept of all information and records deleted by the Local Authority.

Local Authorities should endeavour to ensure that every copy of that information should also be deleted when something is destroyed. For example, if the same announcement was made on three different channels, then all three versions of that announcement should be deleted. In practice the council can delete only the posts under its control.

Please see Appendix 5 for further information about determining the value of social media content.



4 Legislative requirements for the management of social media There are a number of key legislative requirements relating to the management of information and records that are applicable when considering the management of social media. The relevant legislation is:

• Public Records Act 2005 • Privacy Act 2020 • Local Government Official Information and Meetings Act 1987 • Contract and Commercial Law Act 2017

Below is a summary of the legal requirements with regards to managing social media as a record.

4.1 Public Records Act 2005 Public Records Act 2005 The PRA covers the management of information and records created, received, and used by Local Authorities in conducting their business. The act provides legal definitions for record, public record, local authority record, local authority archive and protected record that underpin all requirements and understandings of why we must manage social media as records. Please see the glossary in Appendix 3 for the legal definitions of those terms. There are six key requirements in the Act that are relevant to Local Authorities. Local Authorities must:

• Create and maintain records • Have authority to dispose of protected records • Adhere to mandatory standards issued by the Chief Archivist • Provide adequate protection and preservation of protected records • Classify access status of Local Authority archives • Provide open access to Local Authority archives

A summary of the impact of those requirements on the management of social media as records it outlined below. Six key requirements of the PRA Implications for local government 1. Create and maintain records Social Media posts and responses are records.

Local Authorities must treat social media posts and responses like any other business records and ensure they are managed appropriately.

2. Have authority to dispose of protected records

Local Authorities cannot delete or otherwise dispose of social media posts, or responses to them if they are protected records without approval of the Chief Archivist. The approved disposal schedule used by each Local Authority should identify how long to keep social media posts for – and that will be dictated by the content of the post not the fact that it is a social media post.



3. Adhere to mandatory standards issued by the Chief Archivist

Local Authorities must comply with any mandatory standards that the Chief Archivist releases. At present there is one standard that applies to the management of all information and records, including social media posts and responses. That is, the Information and Records Management Standard (16/S1).

4. Provide adequate protection and preservation of protected records

Local Authorities must provide adequate protection and preservation for protected records (whether in physical or digital format).

5. Classify access status of Local Authority archives

The Local Authority must determine and record the access status of its archives, including social media posts that have been determined to be archives. Social media posts and responses that have become Local Authority archives can only have restricted access if there is good and justifiable reason to do so.

6. Provide open access to Local Authority archives

Local Authorities must be able to produce and make available for viewing (upon request) any social media post and responses that are Local Authority archives, that have open access, free of charge to the requestor.

Appendix 4 provides more details and discussion about PRA requirements and how they impact the management of social media as records.

4.2 Privacy Act 2020 Privacy Act 2020 Requirements under the Privacy Act 2020 The Privacy Act mostly governs personal information about individuals, though the Privacy Commissioner also has a wider ability to consider developments or actions that affect personal privacy. The Act has thirteen information privacy principles. Principle/s: • 1, 2, 3 and 4 govern the collection of

personal information. • 5 governs the way personal information is

stored. • 6 gives individuals the right to access

information about themselves. • 7 gives individuals the right to correct

information about themselves. • 8 ,9, 10 and 11 place restrictions on how

people and organisations can use or disclose personal information.

• 12 governs disclosing of personal information to another organisation outside New Zealand.

The Privacy Act has little impact on social media posts and responses as by their nature they are usually public posts, providing the Local Authority follows clear policy not to post anything private about identifiable individuals. If social media is being used to support submission processes then it needs to be setup to ensure that personal information collected is adequately protected both during the submission process, and afterwards as the record is stored and managed over time. The Local Authority must ensure that any personal information collected is used for the purpose it was collected for. The Local Authority must also ensure that the information is securely disposed of as per the approved disposal schedule, and managed in accordance with both the information and records management policies and the Local



• 13 governs how "unique identifiers" - such as IRD numbers, bank client numbers, driver's licence and passport numbers - can be used.”

Authority’s privacy statement (which should be available on the website and social media channels).

4.3 Local Government Official Information and Meetings Act 1987 Local Government Official Information and Meetings Act 1987

Requirements under the LGOIMA Act 1987

The purpose of LGOIMA is: • To make official information held by Local

Authorities more freely available • To provide for proper access by each

person to official information relating to that person which is held by Local Authorities

• To provide for the admission of the public to meetings of Local Authorities

• To protect official information held by Local Authorities and the deliberations of Local Authorities to the extent consistent with the public interest and the preservation of personal privacy

• To ensure each Local Authority establishes procedures to achieve the points above

Posts and responses made by either the Local Authority or the public on a Local Authority channel, are public when they are first published. If they are removed from the channel, or significantly edited, by the Local Authority the Local Authority must still be able to retrieve them as needed in response to information requests. It is unlikely that a post made by a Local Authority to one of their own social media channels could legally be withheld from access by a member of the public after it had been posted.

4.4 Contract and Commercial Law Act 2017 Contract and Commercial Law Act 2017 Requirements under the CCL Act 2017 The Contract and Commercial Law Act 2017 (which replaced the Electronic Transactions Act 2002) provides that certain paper-based legal requirements may be met by using electronic technology that is functionally equivalent to those legal requirements. In broad terms it sets out that electronic format is acceptable: • if the information is readily accessible so as

to be used for subsequent reference • if the integrity of the information is

maintained

Social media posts and responses can be produced electronically as evidence if required, providing they are readily accessible and that their integrity has been maintained. For the Local Authority to be sure of the integrity of the information it should be stored in the council’s recordkeeping system.



5 Technology requirements to manage social media as records 5.1 High level assessment of technology tools The Working Group identified three types of technology available for managing social media. Considerations were identified based on the implications of the tool managing social media as a record. Summarised below are the key considerations.

Social media channels offer publishing tools. These channels are typically not suitable to meet the information management requirements that local authorities must adhere to.

Social media capture and storage tools available on the market fulfil a useful role in capturing and storing social media posts and responses from multiple channels for short term (1-5 years) use.

Posts and responses of archival value should be saved and managed within council official recordkeeping systems.

Please note: At the time of the writing these guidelines the social media capture and storage tools available on the market are advancing rapidly. Over the past few years, the functional capabilities of these tools are expanding so much so that it is expected in the very near future these tools will meet the requirements of the Information and Records Management Standard 2016. Local Authorities should include Information Management expertise when assessing the purchase of a social media and capture tool for ‘managing social media posts and responses as a record’ for their council.

5.2 The roles of the different technology tools for managing social media records The three types of technologies in use by Local Authorities to manage their social media are:

• The social media publishing channel (for example FaceBook, YouTube, Instagram) • The social media capture/ storage tool (offered by vendors, for example Brolly,

ArchiveSocial, PageFreezer) • The recordkeeping system/tool used by the Local Authority (the electronic document and

records management system, for example Objective, Content Server, TechOne EDRMS)



When considering the technical requirements, the Working Groups key focus was on the social media capture and storage tool.

Explanation and discussion of each technology

Social media publishing channels Social media capture & store Council recordkeeping system • Social media channels offer

their own publishing tools. • A channel cannot be relied

upon to provide ongoing storage/retention of all content published on it.

• It is not designed, nor should it be used for anything other than the actual publishing of content and responses to posts.

• Typically, social media channels are managed by external providers and a Local Authority has little control on what happens to content over time. It is difficult to be sure content is all ‘saved’ and ‘stored’ and done in a way that will meet requirements under the Information and Records Management Standard 2016.

• Vendors typically call this technology “social media archiving”.

• These tools are designed to capture, and store social media posts and responses made by organisations. They can save posts from multiple publishing channels so they can be easily accessed in their original format to support many business needs.

• At present, these capture and storage tools may not have the functionality to manage social media posts and responses that have archival value.

• Very few social media posts will meet the criteria for permanent preservation and require archiving.

• This is the official record keeping system that Local Authorities use, such as their EDRMS.

• These systems must adhere to specific requirements (published by Archives New Zealand) to support compliance with the Information and Records Management Standard 2016. It is these systems that provide appropriate levels of management over time for social media posts and responses that have archival value.

Conclusion: The social media channel should be treated as the publishing tool and not be relied on to store and manage posts and responses from an information management perspective.

Conclusion: Social media capture and store tools are undergoing a period of rapid enhancement. At present they may not meet the information management requirements for the storage and

Conclusion: Store social media posts and responses that have archival value in the council’s official record keeping system.

Capture and storage tool used to save and store social media posts

and responses

Examples are:ArchiveSocial

BrollyPageFreezer

Permanent storage for posts and responses

deemed to be of archival value. Possibly the

electronic document management system in

use at the local authority.

Yammer

FaceBook

Twitter

Web Pages

YouTube

Instagram

Neighbourly

Publishing application/channel Recordkeeping system used to store and manage information to

recordkeeping standards

Designed to meet business requirements for

communications activities

Designed to meet business requirements for storage of

social media content

Designed to meet information and recordkeeping requirements



Social media publishing channels Social media capture & store Council recordkeeping system management of social media records over time or as local authority archives. However, this could well change in the near future. In the meantime, posts or conversations deemed to be of archival value must be stored within a system that meets Archives New Zealand information and recordkeeping requirements i.e. the council’s official recordkeeping system.

The focus of the technology requirements for these guidelines is the “capture and storage tools” that may be offered by vendors i.e. those tools that provide a link between the social channel and the recordkeeping system. This is because the social channels are designed to meet publishing requirements and the long term/archival storage requirements can only be met using a recordkeeping system such as an EDRMS.

5.3 Using technology to capture social media When capturing social media records, it is important that both the content and the context (metadata) of the post are captured. Standardising capture methods can be challenging because not all capture methods are created equal.

Manual methods are not efficient for capturing social media records. Screenshots and ‘copy and paste’ create a picture of content but do not preserve the metadata and original functionality of the content. However, these methods are better than doing nothing at all. Examples of manual methods are:

• Excel spreadsheets manually updated with social media information • Saving a screen shot along with information regarding its metadata as a Word or PDF

document • Copy and paste along with information regarding its metadata as a Word or PDF

document

A more efficient method is an automated application to capture posts. Software and services that offer social media capture include:

• Web crawling or other software to create local versions of sites • Web capture tools to capture social media content and migrate to other formats • Platform specific application programming interfaces (APIs) to pull content • Tools built into some social media platforms to export content • Electronic documents and records management systems that allow for the automated

capture of social media posts

Each Local Authority should evaluate and test the available tools for social media capture to determine if they meet the business needs, budget, and information management requirements.



Many services for capturing and storing social media records require the posts and responses to be stored on a cloud computing system. Local Authorities should follow their council protocols when investigating cloud-based systems and be aware of the legal and privacy implications of storing data in a cloud computing system. Councils ICT departments should be able to provide the necessary guidance. Whatever method chosen the processes and technology implemented must ensure the capture of the complete social media record with the associated metadata.

Note: All social media posts should be captured as soon as possible after posting to ensure they can be easily retrieved as there is no guarantee as to how long they will remain online.

5.4 High level requirements for social media capture and storage tools These tools are designed to capture, and store social media posts and responses made by organisations. They can save posts from multiple publishing channels so they can be easily accessed in their native format to support many business needs such as responding to a LGOIMA request.

There is no requirement for Local Authorities to use technology tools for capture and storage of social media provided by external providers. However, they are a useful effective option for the collection, management and storage of content for the short to medium term (i.e. 1-5 years) so that only those posts and responses deemed archival value need to be subsequently transferred into the council’s recordkeeping system. A range of external suppliers of social media capture and store technologies provide exportable options of content in their original format.

The requirements below should be considered high-level functional requirements for any social media capture and storage tool implemented by the Local Authority. Local Authorities will also have system/technical requirements to ensure that any tool purchased will work within their technology environment. Councils ICT departments should be able to provide the necessary guidance with this.

Requirement Value – Must, Should, Nice to Have Capture and storage processes Automated capture e.g. as a post is published a copy is taken and transferred into the off-platform tool through an API.

Must

Be able to store content from multiple social channels

Must. If the off-platform tool can only work with one channel, then further tools will be required to cover other channels.

Categorisation of content Metadata captured must meet the minimum requirements for the Information and Records Management Standard

Must. Appropriate metadata may not be created/captured automatically. Some manual addition of metadata may be required which is particularly important if the content is of archival value.

Social media content metadata separate but linked to allow capture of the post as a record and import of the metadata into the EDRMS documents property metadata fields as a complete record.

Nice to have

Tagging functionality to enable posts and responses to be automatically tagged using defined metadata and values

Nice to have. It is likely that Local Authorities may want to explore auto-tagging in order to save time and effort of having to manually tag items with things like key words as they are ingested. The ALGIM Terms for Councils in the

https://algim.knack.com/algim-terms-for-councils



Requirement Value – Must, Should, Nice to Have ALGIM IM Toolkit could be used as a base for identifying appropriate terms.

Retrieval of posts/responses Able to search content in order to make information accessible and usable, e.g. Boolean search, metadata search

Must

Advanced search options should provide the ability to filter and sort results

Must

Ability to search across all content, across multiple channels

Must

Transparency tools i.e. a way to make the tool searchable by members of the public

Nice to have

Export processes Data exports options in various formats e.g. PDF, CSV, HTML, JSON, etc.

Must. This supports the need to export certain posts and responses into the EDRMS for permanent retention or to export certain collections in response to LGOIMA requests etc

Ability to set up autorun export reports Must. For example, auto-export of all submissions into the EDRMS

Deletion processes Ability to set retention rules and capture disposal metadata relating to the deletion process.

Must. This supports compliance with the Standard.

Ability to delete all posts and responses captured in the capture and storage tool.

Must. This supports the need to be able to delete records according to the requirements of the Local Authority’s disposal schedule.

In addition to the requirements outlined above there are a number of standard vendor procurement considerations to evaluate. They are:

• Server location and ensuant data sovereignty questions • Data protection / redundancy plans in place • Vendors adherence to social platform privacy policies/restrictions • Bandwidth requirements to archive available data • Retention rules / toolsets available to the customer • Pricing structures – records captured per month vs. number of accounts connected etc. vs.? • Customer resources and additional educational / training opportunities offered

Councils ICT departments should be able to provide the necessary guidance and assist council staff with a full requirements list and assessment of the tools available on the market.



6 Social Media Policy and IM/RM Policy 6.1 Key information management inclusions for your social media policy When writing a social media policy and information and records management policy for your Local Authority the key inclusions in regard to managing social media as records are:

Social media posts and responses should be defined as records within the Information and Records Management Policy.

The Social Media Policy should also define social media posts and responses as records and note the specific management policies surrounding them.

Roles and responsibilities for publishing social media and managing posts and responses over time should be clearly documented in the policy.

6.2 Records management clauses to include in social media policy/procedures Local authorities need to ensure that their internal policies document roles, responsibilities, and expectations with regards to the publishing and management of social media as records.

The two main policies needed to cover this off are the:

• Information and Records Management Policy • Social Media Policy

It is important that the cross over between the two is understood and so that when being updated staff from both teams are involved. This will ensure that appropriate policy and accompanying procedures/business rules are developed, and responsibilities allocated and agreed to.

6.2.1 Guidance for policy content The table below provides examples of the type of clauses required in policies in relation to the management of social media as records.

IM/RM policy Social Media policy Social media posts and responses are records Social media posts and responses are records What social media channels are used and what

each channel is used for

Provided below is a sample clause council could include in their Social Media Policy

Retention of social media posts and responses and the Public Records Act 2005

All communication with council over social media channels is subject to the Public Records Act 2005 as they are considered to be local authority records (as defined in the Act).

To support compliance with requirements under that legislation Council must ensure it:

• Saves all social media posts it makes (including photos, videos, live streams/broadcasts) on its social media channels, and any responses received to those posts



• Collects data about social media activity in real-time and including all activity such as posts, comments, likes, private messages, etc. It also includes removed content such as deleted comments and unlikes

• Retains those items collected and saved for as long as is required by their approved records disposal schedule

Council will:

• Endeavour to respond to all record requests related to its social media content. • Provide access to retained social media posts and responses that are no longer live on the

channel via our usual LGOIMA request process

6.2.2 Guidance for procedures content The table below provides examples of the type of clauses required for procedures in relation to the management of social media as records.

IM/RM procedures Social Media procedures How social media is captured as a record from each channel

Expectations for what gets posted

Retention and disposal rules Who can post to which channel How to deal with privacy issues around social media posts and responses

How to deal with privacy issues around social media posts and responses

What training is required for IM staff to support the management of social media

What training is required prior to publishing anything

Minimum metadata requirements IM Issues and considerations for creating, managing, shifting, and deleting of content.

How social media posts should be deleted or archived

How posts and responses may be subject to LGOIMA

How to deal with IP and copyright issues Disclaimers for ongoing storage of social media

posts Adherence to Legal requirements



7 Education requirements for staff using and managing social media 7.1 Core requirements for educating personnel managing social media records The key education requirements and implications with regards to social media for Local Authorities are:

All staff and contractors, as part of induction, should receive education about the use of social media at their Local Authority. This should include that social media posts and responses are records and should be managed as such.

Information and Records Management staff should receive training in how to use any capture and storage tools used for social media posts. Even if they are not managing that process, they still need to understand the tools being used and how they then work with the councils recordkeeping systems to support appropriate deletion and archiving processes.

Any staff authorised to access Local Authority social media accounts should receive education about how social media posts are managed as records and the systems and processes that are undertaken to ensure records are managed appropriately.

7.2 Roles of personnel managing social media archiving When identifying requirements for education of staff and contractors in relation to Local Authority social media posts and responses it is important to understand which roles are involved and what their purpose is. The table below shows the roles that will likely have some input and involvement with social media.

Role/s Activity Marketing/Communications team members Business owners of the Social Media Policy

(typically) Content drafters/editors Content approvers Content publishers

Customer Service staff Content drafters/editors Content approvers Content publishers

Selected staff in public facing services such as Libraries, Pools, Museums etc

Content drafters/editors Content approvers Content publishers

Teams involved in running consultation processes e.g. Legal team, Policy team

Content drafters/editors Content approvers Content publishers

Information and records management team members (including the Local Authority archivist if it is a separate role)

Business owners of the Information Management Policy Advisors about information and records management requirements and processes EDRMS business owners (typically) Local Authority archives business owners (typically)

IT support team members Technology advisors Technology support



7.3 Training and induction outline As part of the induction and the education of new staff, basic policy training should be delivered covering:

• What social media is used for at the Local Authority? • Which roles develop and publish content and responses • What channels are used for what type of messaging • How they as Council employees should respond to any social media posts in accordance with

the Council’s social media policy • How social media posts and responses are Local Authority records and should be treated as

such

The induction training may be delivered by the Communications team or the Information Management team or both disciplines. Whoever delivers the induction training, the material should be endorsed by the other team to ensure there is an agreed understanding of what new staff are taught about social media with respect to each teams’ activity focus.

Specific training should then be provided to all staff involved with social media throughout its lifecycle – from creation and publishing through to its deletion or archiving depending on their role. For example:

• Information and Records Management staff should receive training in how to use any capture and storage tools use for social media posts. Even if they are not managing that process, they still need to understand the tools being used and how they work with the councils’ record keeping systems to support appropriate deletion and archiving processes.

• Communications and Marketing staff (or any staff who can post to Local Authority social media accounts) should receive education about how social media posts are managed as records and the systems and processes that need to be undertaken to ensure they are managed appropriately.

8 Implementation of the guidelines ALGIM is available to facilitate implementation of these guidelines for local authorities in New Zealand. There is a range of resources being provided through:

• ALGIM’s training academy programme • ALGIM IM Toolkit • ALGIM CX Toolkit • and the members only area of the ALGIM Website

Please contact ALGIM if your council would like assistance. Email: [email protected] Phone: +64 6 351 6330 Website: ALGIM Website.

https://algim.org.nz/AccessIM


mailto:[email protected]




Appendix 1 – Answers to Frequently Asked Questions These questions were identified by the Working Group. They are listed in the Introduction section of these guidelines. The answers to the questions posed by the Working Group are provided below.

Question Answer 1 Are all social media posts made on

official Local Authority Social media channels a Local Authority record?

Yes, as defined by the Public Records Act 2005.

2 If they are Local Authority records, what does that mean?

Local Authority records must be managed according to the requirements of the Public Records Act 2005, the Information and Records Management Standard 2016 and other relevant legislation.

3 How long should social media posts (and responses) be retained for?

They should be retained for a length of time based on the value of their content. Determination of value is documented in the disposal schedules used by each Local Authority (such as the ALGIM IM Toolkit DS).

4 Are any social media posts and conversations of permanent value?

Yes. However which ones have permanent/archival will be determined by the disposal schedule. Examples may be, announcements about or, discussion with the public on significant infrastructure projects taking place in their area where a record showing how the Local Authority interacted with the public about the project.

5 How do we determine which social media posts have permanent value?

Refer to the disposal schedule used by your Local Authority. Information and Records Management staff may be required to provide appropriate interpretation of value.

6 If all the social media posts are of short-term value, do we need to do anything?

Yes. They should be deleted after the agreed time period. If the Local Authority retains the content (instead of deleting it), then it is legally bound to continue to make it accessible or search through it in response to LGOIMA requests, which if it has no value is a waste of time and resources.

7 What are the information management responsibilities around social media posts?

Social media content are records so all information management responsibilities apply. Staff authorised to make posts or responses for their Local Authority should work with the Information and Records Management staff to ensure processes will support good information management practices and fulfil responsibilities.

8 What roles should be involved in setting internal social media policy?

Communications roles, Information and Records Management roles each have a part to play on setting policy.

9 What training do staff require with regards to use and management of social media?

Those authorised to make posts and responses need to be trained in both the communications and the information management aspects of social media.

10 What tools are available to assist with managing social media?

Social media capture and storage tools are available which are separate from the publishing channel and the final record holding tool, the local authorities official record keeping system. Each type of tools/system has its own role as explained in the guide.



Question Answer 11 Which tools provide the necessary

functionality to manage social media posts over time (if that is required)?

The official recordkeeping system of the Local Authority should provide compliance to the Archives New Zealand standards for posts and responses deemed to have archival value. However, most of these tools will require the content to be imported from either the publishing channel or a social media capture and storage tool. Some EDRMS can be set up to capture a copy of each post made into the EDRMS as the post is made. But this only deals with the Local Authority posts, not any responses then received.

12 What metadata must be captured with any social media post if we need to archive it?

The same as with any other kind of information that is a Local Authority record. That is:

• Unique identifier • Name • Date created • Business activity documented • Creator (person or system) • Name and version of the software application

used to create a digital record • Any later actions carried out on, such as

accessing, modifying, or disposing • Identification of the persons or systems

carrying out those later actions • Dates those actions were carried out

13 How would you treat Elected Members’ posts on Social Media?

If they are posting in their official capacity using the Local Authorities social media channels, then the record will be captured using standard processes. If they are using their own personal channel, then it is not the Local Authorities responsibility to capture it as they are not acting on behalf of the Local Authority. However, this distinction is something that needs to be made clear in both policy and education for Elected Members. It is similar to how a Local Authority must grapple with Elected Members using their personal email to comment or conduct Council business.

14 If the Local Authority is tagged on a post, does that mean that the Local Authority is being specifically communicated with, or are we just concerned with what is being posted on the Local Authority’s own channels?

The Local Authority only has the mandate to manage what is posted on its own social media channels.

15 How should Local Authorities deal with the disposal of social media records?

Specific disposal processes must be developed by the Information and Records Management team and Communications team to ensure compliant disposal (whether deletion or archiving for permanent retention) practices are in place. The processes will be largely dependent on what tools/systems the Local Authority is using.



Appendix 2 – Requirements from the Information and Records Management Standard 2016 of Relevance to Managing Social Media Listed below are the requirements from the mandatory Information and Records Management Standard 2016 that are of particular relevance to the management of social media as records:

Minimum Requirements What this means in relation to social media Requirement 1.1 Information and records management must be directed by strategy and policy and reviewed and monitored regularly.

• The information and records management policy must provide statements ensuring that it is clear that social media posts and responses are records.

• Clear responsibilities must be outlined for how such records are to be managed.

• Compliance with the policy must be monitored regularly.

Requirement 1.5 Business owners and business units must be responsible for ensuring that information and records management is integrated into business processes, systems, and services.

• Clear responsibilities must be outlined for how social media posts and responses are to be managed to ensure they are appropriately treated as records.

• The team responsible for managing social media (typically the Communications team) must ensure that the information management aspects of social media publishing and use are incorporated into standard systems and processes used.

Requirement 1.6 Staff and contractors must understand the information and records management responsibilities of their role. They must understand relevant policies and procedures.

• Any staff or contractors using social media on behalf of the Local Authority must clearly understand and adhere to the relevant policies and practices.

Requirement 1.7 Information and records management responsibilities must be identified and addressed in all outsourced and service contracts, instruments, and arrangements.

• Any outsourced service contracts that involve external parties using social media on behalf of the Local Authority must state expectations, policies and practices that must be adhered to in relation to social media

Requirement 2.1 Information and records required to support and meet business needs must be identified.

• The Local Authority must identify and document what social media is used for, what channels are used and how social media posts and responses are used to support business activities.

Requirement 2.4 Information and records must be managed across all operating environments.

• Social media records (posts and responses) must be actively managed to meet information and records management needs.

Requirement 2.5 Information and records management must be designed to safeguard information and records with long-term value.

• Social media records that have long term value must be stored and managed within systems that will safeguard those records for as long as they are needed.

• Note: long term storage may not be within the original publishing system, but rather



Minimum Requirements What this means in relation to social media another tool such as and electronic document and record management system.

Requirement 2.6 Information and records must be maintained through systems and service transitions by strategies and processes specifically designed to support business continuity and accountability.

• Social media records (posts and responses) that need to be maintained in the medium to long term should be stored in repositories that meet the requirements for recordkeeping.

• Migrate information, records, and metadata from one system to another using a managed process that results in records that people can access easily and records of trustworthy information.

Requirement 3.1 Information and records must be routinely created and managed as part of normal business practice.

• Social media policy, business rules and procedures accurately document staff requirements and responsibilities for creating, capturing, and managing information and records of business processes.

Requirement 3.2 Information and records must be reliable and trustworthy.

• Social media posts and responses must be saved with appropriate minimum metadata so that the meaning and context are associated with the relevant information and records, and that it is correct.

Requirement 3.3 Information and records must be identifiable, retrievable, accessible, and usable for as long as they are required.

• Local Authorities must be able to verify that the system being used to store and manage social media posts and responses can locate and produce information and records that are viewable and understandable.

• Minimum metadata must be in place so that social media posts and responses are identifiable, accessible, and usable.

Requirement 3.4 Information and records must be protected from unauthorised or unlawful access, alteration, loss, deletion and/or destruction.

• Social media posts and responses stored in recordkeeping systems must be protected from unauthorised access.

• Social media posts and responses stored in recordkeeping systems must be protected from unauthorised deletion.

• Permissions must be able to be applied to social media posts and responses that are stored in recordkeeping systems.

Requirement 3.5 Access to, use of and sharing of information and records must be managed appropriately in line with legal and business requirements.

• Access to social media posts and responses must be controlled through access rights in line with business and legal requirements.

• Documentation must be created and kept of who has had access to social media posts in order to support the integrity of the record.

Requirement 3.6 • Social media posts and responses must be managed according to their value. i.e. those



Minimum Requirements What this means in relation to social media Information and records must be kept for as long as needed for business, legal and accountability requirements.

of medium to long term value should be retained in such a way that they can be kept for as long as needed – that includes any social media records that should become Local Authority archives.

• Policy and procedures must be in place to enable the sentencing of social media posts and responses (i.e. the decision-making on which ones get kept as archives and which ones can be deleted and at which point, they can be deleted).

• Local Authorities must have in place systems and processes to transfer social media posts and response of archival value into the Local Authority archive.

Requirement 3.7 Information and records must be systematically disposed of when authorised and legally appropriate to do so.

• Social media posts and responses must be disposed of according to the approved disposal schedule for the Local Authority.

• Records must be retained of any social media posts and responses disposed of.



Appendix 3 – Glossary of terms Term Definition Local Authority record PRA Part 1, Section 4 - Interpretation

‘means a record or a class of records, in any form, in whole or in part, created or received (whether before or after the commencement of this Act) by a Local Authority in the conduct of its affairs’ Note: The only records excluded are voting documents and materials received in accordance with the Local Electoral Act.

Local Authority archive PRA Part 1, Section 4 - Interpretation

(a) means a Local Authority record that: (i) is no longer in use by the controlling authority; or (ii) has been in existence for 25 years or more (whether or not in current use); and

(b) includes: (i) a protected record; or

(ii) a Local Authority record that the controlling authority resolves is worth permanent preservation

Permanent value Information and records (including social media content) that has archival value and therefore needs to be retained permanently by the Local Authority as a Local Authority archive.

Protected record ‘means a Local Authority record declared under section 40 to be protected records for the purposes of this Act.’

There are 17 classes of records that have been declared as “protected” by the Chief Archivist. Social media posts are not identified as a specific class but may come under any one of the other classes depended on their subject matter and context.

Public Record PRA Part 1, Section 4 - Interpretation

(a) ‘means a record or class of records, in any form, in whole or in part, created or received (whether before or after the commencement of this Act) by a public office in the conduct of its affairs; and (b) includes (i) a record or a class of records declared under section 5(1)(a)(ii) to be a public record for the purposes of this Act’

Record PRA Part 1, Section 4 - Interpretation

‘record means information, whether in its original form or otherwise, including (without limitation) a document, a signature, a seal, text, images, sound, speech, or data compiled, recorded, or stored, as the case may be:

(a) in written form on any material; or (b) on film, negative, tape, or other medium so as to be capable of being reproduced; or

(c) by means of any recording device or process, computer, or other electronic device or process’

Short term, medium term, long term

Short term = 1-2 years Medium term = 2 – 10 years Long term = greater than 10 years Theses time periods are indicators only.



Appendix 4 – Public Records Act 2005 Requirements

There are six key requirements in the Public Records Act (2005) that are specific to Local Authorities. Local Authorities must:

• Create and maintain records • Have authority to dispose of records • Adhere to mandatory standards issued by the Chief Archivist • Provide adequate protection and preservation of protected records • Classify access status of Local Authority archives • Provide open access to Local Authority archives

Create and maintain records

Section 17 of the PRA outlines how Local Authorities must create and maintain “full and accurate records” of their affairs as part of normal prudent business practice. The intent is to state specifically that the Local Authority must create records of what it does. The definitions given of records, and then Local Authority records, make it clear that social media posts and responses are considered to be records.

Creation of full and accurate records also includes records of anything contracted out. For example, if your Local Authority contracts out a service such as garbage collection or parking services then the PRA applies to those companies and the records they are creating on your behalf as well. In practice that must be dealt with as part of the contracts – ensuring there are appropriate clauses in the contract about how the records must be maintained, what happen to them when the contract ceases, how their disposal should be managed etc.

Section 17 also requires that any records must be maintained in accessible form. In effect, Local Authorities must know what it is, where it is, can find it and then use it regardless of how long it needs to be retained for.

In relation to social media, this requirement means that Local Authorities must treat social media posts and responses like any other business records and ensure they are managed appropriately.

Have authority to dispose of records

Under the PRA, "disposal, in relation to a public record or Local Authority record, means:

a) the transfer of control of a record; or b) the sale, alteration, destruction, or discharge of a record."2

Section 18 of the PRA states that no person may dispose of or authorise the disposal of public records or protected records except with the authority of the Chief Archivist. This means that Local Authorities must have the approval of the Chief Archivist before they delete any protected records, including social media posts and responses that are deemed to be protected records.

2 Public Records Act 2005 Part 1, Section 4 - Interpretation



In practice, approval for disposal (whether archiving or deletion) is typically provided through the use of approved ongoing disposal schedules. Most New Zealand Local Authorities have signed up to use the disposal schedule developed by ALGIM which is available in the ALGIM IM Toolkit. The disposal schedule provides rules for what information and records should be retained and for how long. It identifies the information and records that have permanent value (based on the List of Protected Records released by the Chief Archivist), so must be retained as archives, and after what period all other information and records can be destroyed/deleted. This includes social media posts and responses.

In relation to social media, this requirement means that Local Authorities must have approved rules for the disposal of posts and responses that are protected records. These rules are typically documented within an approved disposal schedule that applies to all information and records of the Local Authority.

Adhere to mandatory standards

Sections 27 and 28 of the PRA cover how the Chief Archivist will release standards, and how Local Authorities are expected to comply with those standards. The standards outline how Local Authorities must create and maintain records and can be either mandatory or discretionary. At present there is one standard that applies to the management of all information and records, including social media posts and responses. That is, the Information and Records Management Standard 20163. The standard specifies certain requirements for the management of all information and records, regardless of format. Local Authorities are expected to audit themselves against compliance with the standard. It is understood that Archives New Zealand may explore options for auditing Local Authorities for compliance directly.

This means that Local Authorities must ensure that their social media posts and responses are managed according to the requirements of that standard, and any other standards that the Chief Archivist may release as mandatory standards. Please see more detail about the Information and Records Management Standard 2016 in section 2.6 of these guidelines.

In relation to social media, this requirement means that Local Authorities must comply with any mandatory standards that the Chief Archivist releases. At present there is one standard that applies to the management of all information and records, including social media posts and responses. That is, the Information and Records Management Standard 2016.

Provide adequate protection and preservation of protected records

Section 40 of the PRA covers preservation and protection.

“A Local Authority must provide for the adequate protection and preservation of a protected record it holds, in accordance with any applicable standards or instructions issued by the Chief Archivist”4.

This means that Local Authorities must comply with the protection and preservation requirements in the Information and Records Management Standard 2016. Additionally, the Chief Archivist has

3 https://www.archives.govt.nz/manage-information/resources-and-guides/statutory/information-and-records-management-standard accessed 5/11/2019 4 Public Records Act 2004 Section 40 (2)

https://www.archives.govt.nz/manage-information/resources-and-guides/statutory/information-and-records-management-standard

https://www.archives.govt.nz/manage-information/resources-and-guides/statutory/information-and-records-management-standard



released an instruction to Local Authorities for the ‘Protection and Preservation of Protected Records’. However, the instruction only applies to physical information and records, not digital, which social media posts and responses typically are. Archives New Zealand have recently released Best practice guidance on digital storage and preservation (20/G17) which provides guidance about preserving and storing digital records over time.

In relation to social media, this requirement means that Local Authorities must provide adequate protection and preservation for social media posts and responses that are protected records.

Classify access status

Sections 45 and 46 of the PRA cover access status. That is, determining whether Local Authority archives are open access or require enforcement of restricted access due to the nature of the content.

Local Authorities must declare whether the archives they hold are open access or restricted – usually easily achieved through the registers or catalogues used to control the archive collection. Access to archives can be restricted if there are “good reasons”. Sections 6 and 7 of the Local Government Official Information and Meetings Act 1987 provides justifiable responses for restricting access. Typically, such restrictions would apply to information and records containing personal details, information of commercial sensitivity etc.

Given that social media posts are typically made in openly accessible social media communities, it is unlikely that any social media post that is transferred into the Local Authority archives would need to be restricted, or indeed could reasonably be justified as being restricted.

In relation to social media this requirement means that Local Authorities social media posts and responses that have become Local Authorities’ archives can only have restricted access if there is good and justifiable reason to do so.

Provide open access

Section 47 of the PRA is about providing open access. It states that “…open access records must be made available for public inspection free of charge as soon as is reasonably practicable after a request is received…”

What this means is that if someone requests to view a record (or social media post) that has open access (i.e. no need for restricted access) then they must be able to do so free of charge, and within a reasonable timeframe. This clause is regardless of format, storage location or ‘type’ of record.

Local Authorities can however charge for other ‘value-added’ services consistent with their powers under the Local Government Act 2002, such as providing copies of records.

In practice, this means that if social media posts are removed from their native application at some point (e.g. moved from Instagram, to become an item/document in the Local Authorities’ EDRMS), the record must still be accessible and made available for viewing if requested.

In relation to social media, this requirement means that Local Authorities must be able to produce and make available for viewing (upon request) any social media post and responses that have open access free of charge to the requestor.




Appendix 5 - Identifying the value of social media content The ALGIM Disposal Schedule provides the ‘rules’ about what value any information and records within local authorities have. What this means is that decisions about what value something may have are already determined and documented with approval from the Chief Archivist. For social media therefore, it is a matter of working out which disposal rule to use for specific social media content. Outlined below is a high-level process diagram to assist with determining the value of social media posts and responses.

Once the time retention period has been established one of two actions should be taken:

• Do nothing – that is because the time period established is something like “keep for three years then destroy” so it makes sense not to go to the effort of transferring the content to any other system

• Copy/transfer the content to another longer-term storage tool – that is because the time period established is “keep for 10 years then archive”

If the local authority is using some form of social media capture and storage tool, then it may be that all posts and responses are kept within that tool and the determination and assigning of value sits within that tool. Depending on the tool, certain “tags” may be able to be applied (manually or automatically) to attribute the appropriate disposal class, time period and action on each post or response. So that, when it is time to implement the disposal actions, there is a simple report that can be run showing all items due for destruction and items that must be archived.

It should be noted however, that anything with an “archive” value must be retained in a recordkeeping system that complies with the Information and Records Management Standard 2016 and guidelines released by Archives New Zealand for the protection and preservation of digital records.

Identify the function

•Using the ALGIM Disposal Schedule examine the list of record classes and determine which one the social media content relates to•For example, submissions, rates, licencing, parks etc

Locate the correct class

•Locate the correct class and sub-class within the ALGIM Retention and Disposal Schedule that relates to that actvitiy. There are be a number of sub-classes under each functional class•For example Rates administration records, Rates enquiries

Identify the disposal action

•Using the rule noted for the sub-class you have located, identify the disposal action•For example, should the social media content become an archive, or can it be destroyed/deleted?

Calculate the time period

•Calculate the disposal date•This is the time period the content is considered active plus the time period the content is considered inactive



Appendix 6 – FAQs raised from SM Guide presentations to members

Published May 2020

These questions were identified by the attendees of the presentations introducing the guide for managing social media as records. The answers to the questions posed by ALGIM members are provided below.

Question Answer 1 If a poster deletes their response

where does the responsibility lie? The council cannot be responsible for a post made by someone else if the original poster decides to delete it. However, depending on when they deleted it the council may already have taken a copy of it and have that stored which is why it is important on social media channels to have the appropriate disclaimers about how councils may keep copies of posts made.

2 If a staff member has the approval to delete a post because it was deemed by the council to be inappropriate how does the council stand if they delete this?

There is no issue here providing the council social media policy and advice provided publicly for each channel is clear that that is what will happen to a post if it is deemed inappropriate. It also needs to define what is considered to be inappropriate.

3 Currently, interactions we have with users you can store against your customer records, however with social media a lot of correspondence is anonymous, what does that mean in its status of who you are interacting with?

The council cannot control what usernames those who may post responses use. So, unless they are using their real names then the post has to stay as “anonymous”. It is still a record though.

4 Have you tested those requirements against those social media tools out on the market?

The three shortlisted products in the guide are in use in NZ councils presently. ALGIM is currently arranging demos of these tools to occur later in May.

5 Could you manually go through and say those posts have archival value and leave the rest in the system?

Yes – a number of councils are doing this according to the results of the survey from 2019. It may be somewhat time-intensive to do it retrospectively, so to be most efficient with this approach building in the evaluation of value at the time of posting would make it easier to capture only those of archival value into the recordkeeping system.

6 If 90% of our posts are linking through to other communications channels and it is just another way of funnelling demand to other areas, that the actual value of the post is minor provided that you manage the actual communication

Correct. There are likely very few posts that are going to have archival value. Probably a few more however that may have medium-term value.



Question Answer which is usually published on your council website – correct?

7 Can you comment on what makes an acceptable record for a tool-specialised piece of content? For example, video, meta-data like advertising targeting, 3D photos, Instagram Live?

To be an acceptable record it must meet the minimum metadata requirements listed in the Information and Records Management Standard 2016 – linked to the guide. And must be managed as a record. It’s also worth noting that if specialist formats are being used and if the record is of archival value then planning for migration to other formats will likely be necessary over time.

8 How about messages between staff using internal social media tools?

These should be treated the same as emails so if they contain significant discussions, decisions, etc they need to be filed within your recordkeeping systems.

9 Are there any councils doing this well at the moment?

ALGIM has not assessed all councils on how they manage these records. However ALGIM does include this check in their IM Health Check.

10 Barriers such as costs associated with storage of large data files i.e. audio/video of council meetings and technological costs would be considered a valid reason why Councils would not retain these types of large data files and would choose to delete instead. With this, I acknowledge we have to have set processes around that.

See also question 12. When the council makes decisions to invest or use such tools consideration should be given as part of planning around the information management requirements so that full understanding of the implications is understood. For example, if a council decides it wants to start videoing council meetings then the Information Management should be part of the decision to ensure that costs and requirements for storage, migration across platforms over time, and retention needs are understood.

11 Should Private Messages through Facebook be kept as records?

Yes, they have the same status as emails or letters sent to the Council, so if they are of significance then they should certainly be retained as records. The disposal schedule should identify how long they will need to be retained – based on the topic/content rather than the format.

12 I do have some reservations around the cost associated with data storage particularly if Councils were required to hold duplicate and even triplicate information of the same data. By way of example, I will use Council meetings. Formal Minutes are recorded and typed up and

There is no need for the council to keep anything other than the official signed minutes as that is the formal record. Other formats are considered to be duplicates. So, for the digital recording of Council meetings, we would expect it was getting destroyed as soon as the minutes had been signed off as the purpose of the recording was to aid in the production of the minutes.

https://algim.org.nz/IM-Health-Check



Question Answer signed off by the Chair as the official record of the meeting. Then a digital audiotape of the meeting is recorded to help draft the minutes and subsequently stored. Then if the meeting is live-streamed a video and audio recording of the meeting is captured and subsequently stored. The size of the data that is now captured is exponentially growing and now constitutes a Public Record and must be stored on an appropriate site that comes at a cost to the ratepayer. Ratepayers would be quite right to say that the Minutes are the formal record of the meeting and the other two serve a purpose that should be time-bound and are subsequently destroyed. Thoughts?

With regard to any live-streamed meetings, the Council may want to retain them long term. Video or audio records of Local Authority meetings could be potentially covered by the list of protected records class LPR16 – ‘Visual and sound records of high informational, accountability, administrative, research or heritage value’, if they are able to meet the criteria of high value records. Archives NZ has advised that if the video records contain ‘high value’ information not captured elsewhere then they could fall under LPR16 – ‘Visual and sound records of high informational, accountability, administrative, research or heritage value’. This ‘high value’ criteria is unlikely to be met if adequate meeting papers were maintained, although, if a meeting covered an event or topic of historic significance, the case could be made for its retention as a Protected Record. The Council disposal schedule should have provisions for the disposal action of these records. As stated, before there is likely only a very small percentage of social media posts and responses that are of long term/archival value.

For enquiries, please contact ALGIM: email: [email protected], website: www.algim.org.nz



Appendix 7 –Social Media Policy – Sample Template

This is a template is provided as a guide for local authorities on the expected content that would be covered in a Social Media Policy for a local authority

<COUNCIL LOGO>

20 May 2020

Sample Template

Social Media Policy: Council Name

1. Purpose/Objectives Type a brief description here for an example:

This policy document outlines the requirements for acceptable use and behaviour surrounding the social media accounts of [COUNCIL NAME].

Social media platforms have become invaluable tools for communicating with large audiences—and the organisation encourages the use of social media to communicate with constituents—but it is important to keep in mind that social media posts and comments constitute official communication, so they must align with the larger communication policies and strategies of the organisation. It is therefore crucial that this document is used in conjunction with other relevant communication documents.

2. Principles or Values Type a brief description here of what should typically be described here, for example:

Accuracy contain accurate content and authorised content Transparency be honest about errors, correct mistakes in a separate update or comment Respect show appreciation for community efforts and congratulate success Professionalism use of correct grammar and spelling Using caution approach controversial issues with caution

3. Scope Who is in scope and who is not for example: does this apply to councillors? Yes, if they are posting something onto a council channel

What is in scope

the channels, the audience (e.g. managers, content creators, moderators of channels, private use )



What is out of scope

e.g. the posts made about or relating to, the Local Authority, or Elected Members on other private or public social media channels not managed by the Local Authority

4. Policy Ownership Who is responsible for the management and administration of

the social channels Account creation/approvals process

How does this process work

Breaches of Policy What the process is and how it aligns with the staff conduct guide or disciplinary procedures that your organisation has

Acceptable uses of social (e.g. PageFreezer)

Stating that trained staff are able to use these tools

Content Management • Content creator responsibilities – define the roles of the content creators in your council

• Attribution and acknowledgment – if councils publish something that is not their own the council needs to attribute/acknowledge the source of that information

• Response times – define the times e.g. we will get to the customer within this timeframe on weeks days on this channel….

• Acceptable content to be published – more detailed than what is in and out of scope e.g. only put out material that is in the public domain, put out information that you are knowledgeable and authoritative to speak to

Personal Use

Mention what is acceptable • use of social media by staff at work • about staff using personal social media accounts outside of

work. The latter could cover such points as not referring to confidential matters or documents which are not available to the public etc. along with the info about managing the personal and professional aspects of an online presence, perhaps providing options to deal with that etc.

Records and Retention

• The Policy

As per the ALGIM guidelines ‘Managing Social Media as Records’ All communication with the council over social media channels is subject to the Public Records Act 2005 as they are considered to be local authority records (as defined in the Act). To support compliance with requirements under that legislation Council must ensure it: - Saves all social media posts it makes (including photos,

videos, live streams/broadcasts) on its social media channels, and any responses received to those posts

- Collects data about social media activity in real-time and including all activities such as posts, comments, likes, private messages, etc. It also includes removed content such as deleted comments and unlikes



- Retains those items collected and saved for as long as is required by their approved records disposal schedule

Council will: - Endeavour to respond to all record requests related to its

social media content. - Provide access to retained social media posts and responses

that are no longer live on the channel via our usual LGOIMA request process

• The Process – include the tools being used, where

responsibility lies, the process for managing these records, etc

Legislation Legislation that is related to this policy for example: • Privacy Act 2020 • Local Government Official Information and Meetings Act

1987 • Public Records Act 2005 • Local Government Act 2002 • Contracts and Commercial Law Act 2017 • Copyright Act (including the Copyright (new

Technologies) Amendment 2008) • Major Events Management Act 2007 • Human Rights Act 1993 • Employment Relations Act 2000 • Harmful Digital Communications Act 2015

Other considerations: Local authorities may also wish to develop a guideline document to support this policy. The guidelines would be a more informative document, such as advising the staff what social media is and what to consider when using these channels. For example:

• Tips for responding to posts • Tips for dealing with conflict: e.g. customer responses to posts • FAQs • New social media channels – things you need to consider when starting a new channel

http://www.legislation.govt.nz/act/public/2015/0063/latest/whole.html

managing social media as records a best practice guide for

Documents