Âé¶¹Éçmadou

Information Governance Policy

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Information Governance Policy

Purpose

Âé¶¹Éçmadou is committed to:Ìý

  • ethically and responsibly managing , and
  • pursuing best practice in data and Ìý²¹²Ô»åÌý
  • managing data, information and records in a way that meets Âé¶¹Éçmadou’s legal, risk, environmental, business, teaching, learning and research requirements.

The purpose of this policy is to:Ìý

  • provide a comprehensive set of enterprise-wide principles and procedures for the (i) governance and management of data, information and records, and (ii) use of , and or tools
  • ensure Âé¶¹Éçmadou complies with applicable laws, standards, codes, guidelines, ethics approvals and contractual obligations in relation to information governance.Ìý ÌýÌý

Ìý

Scope

This policy applies to:Ìý

  • all information collected, used or generated at Âé¶¹Éçmadou or during Âé¶¹Éçmadou-affiliated research (with the exception of library scholarly information resources procured under a contract or licence), including unpublished , , , , , and records
  • all formats of data, information and records including print, electronic, audiovisual or any other formatÌý
  • (including for example, procured library and scholarly information resources)
  • digital communication platforms/technologies
  • artificial intelligence systems and tools
  • all devices connected to a Âé¶¹Éçmadou network or used to access Âé¶¹Éçmadou information resources.ÌýÌý

This policy applies to , , , and . The procedures that follow the policy may state that a more limited scope applies.Ìý Ìý

Contents
Principles and ObjectivesÌý
Procedures:ÌýData Governance and Management | Records and Information Management | Privacy | Data Breach | Use of Information Resources and Digital Communications Platforms | Use of AI Systems or Tools

Ìý

Principles and objectives

  • 1.1Ìý Ìý Ìý Data is a strategic asset of Âé¶¹Éçmadou. It is therefore critical for Âé¶¹Éçmadou to have appropriate governance for the management and effective use of its data.

    1.2Ìý Ìý Ìý Data is governed and managed throughout its life cycle in compliance with this policy and, where relevant, ethics approvals, codes,Ìý Ìý Ìý guidelines, third-party agreements and applicable legislation.

    1.3Ìý Ìý Ìý Âé¶¹Éçmadou implements robust and effective data governance and management practices to control the integrity, security, quality, use and reuse of data (and metadata).Ìý Ìý

    1.4Ìý Ìý Ìý Data is protected against unintentional and/or unauthorised modification, including unauthorised destruction and misuse, as well as internal and external threats.Ìý Ìý

    1.5Ìý Ìý Ìý Sharing of Âé¶¹Éçmadou data, between Âé¶¹Éçmadou information systems or business units is governed and documented by written approval unless an exemption applies.Ìý Ìý

    1.6Ìý Ìý Ìý Sharing of Âé¶¹Éçmadou data with an external third party is governed and documented by an approved agreement unless an exemption has been granted.Ìý

    1.7Ìý Ìý Ìý Âé¶¹Éçmadou secures, protects and retains data for future use in an accessible, auditable and traceable manner.Ìý Ìý

    1.8Ìý Ìý Ìý Where permissible and possible, research data is shared and disseminated to maximise its value, encourage collaboration and foster research and teaching innovation.Ìý Ìý

    1.9Ìý Ìý Ìý Aboriginal and Torres Strait Islander peoples’ data is governed in accordance with their rights and interests and any relevant ethics approvals, codes, guidelines, third-party agreements and applicable legislation.Ìý

  • 2.1ÌýÌýÌýÌýÌý As a NSW public office, records created by Âé¶¹Éçmadou are governed by the and belong to the State of NSW. Âé¶¹Éçmadou's records:

    • provide evidence of actions and decisions
    • are vital assets that support daily functions and operations
    • protect the interests of Âé¶¹Éçmadou and the rights of the Âé¶¹Éçmadou community and the people of New South Wales
    • help Âé¶¹Éçmadou deliver services consistently and equitably.

    2.2ÌýÌýÌýÌýÌý Âé¶¹Éçmadou’s records are also Âé¶¹Éçmadou’s corporate memory and protect the interests of Âé¶¹Éçmadou and the rights of the Âé¶¹Éçmadou community.

    2.3ÌýÌýÌýÌýÌý Records must always be:

    • created and captured to document Âé¶¹Éçmadou business activity
    • captured to a Âé¶¹Éçmadou System of Record
    • discoverable across Âé¶¹Éçmadou by those with legitimate need and appropriate access for as long as required
    • accurate, up to date and complete, and never destroyed without written approval.

    2.4ÌýÌýÌýÌýÌý Âé¶¹Éçmadou protect records from unauthorised access, alteration, deletion or misuse, and ensure that Âé¶¹Éçmadou records retain value as evidence.

    2.5ÌýÌýÌýÌýÌý Records and information management practices support good decision-making, accountability and transparency to deliver best practice business outcomes.

    2.6ÌýÌýÌýÌýÌý Records and information management are a component of all processes, systems and services, and ownership of records is always defined and allocated.

    2.7ÌýÌýÌýÌýÌý Records are kept for as long as they are needed for business and legal accountability (including in accordance with retention and disposal authorities) and to meet community expectations.

    2.8ÌýÌýÌýÌýÌý Records are always retained according to current State Records NSW retention and disposal authorities which define the minimum periods before records can be destroyed. The prohibits the unauthorised disposal of State records, and a penalty may be imposed for breaches of the disposal provisions of the Act. The does not override any other obligations of an organisation to retain records.

    2.9ÌýÌýÌýÌýÌý Records are disposed of and destroyed according to the Records and Information Management procedure.

  • 3.1ÌýÌýÌýÌýÌý Privacy is embedded into the design of all Âé¶¹Éçmadou systems, services and practices.ÌýÌý

    3.2ÌýÌýÌýÌýÌý Âé¶¹Éçmadou collects, holds, uses and discloses personal and health information by lawful, fair and transparent means in compliance with this policy, the Âé¶¹Éçmadou Privacy Management Plan, relevant Âé¶¹Éçmadou Privacy Statements, and applicable ethics approval, codes, guidelines, third-party agreements and legislation in applicable jurisdictions.ÌýÌý

    3.3ÌýÌýÌýÌýÌý Personal and health information that is held by the University will only be used or disclosed:

    a. for the purposes notified to the individual concerned at the time of collection; or

    b. for a purpose for which the individual concerned has expressly consented to such use or disclosure; or

    c. where required or authorised by law to use or disclose the information.

    3.4ÌýÌýÌýÌýÌý Âé¶¹Éçmadou takes reasonable steps to ensure the personal and health information it holds is up to date, accurate and relevant to the purpose for which it was collected.

    3.5ÌýÌýÌýÌýÌý Personal and health information collected and held by Âé¶¹Éçmadou can, where appropriate, be accessed and, on request, changed by the person to whom the personal and health information relates.

    3.6ÌýÌýÌýÌýÌý Âé¶¹Éçmadou protects the security of personal and health information against internal and external threats through de-identification and by regularly assessing the risk of unauthorised or unlawful use, disclosure, interference, accidental loss and damage.

    3.7ÌýÌýÌýÌýÌý Personal and health information collected and held by Âé¶¹Éçmadou is disposed of in a secure manner in accordance with this policy and applicable legislation.Ìý

    3.8ÌýÌýÌýÌýÌý Privacy breaches are managed in accordance with Âé¶¹Éçmadou’s Privacy Procedure and applicable legislation.ÌýÌý

  • 4.1ÌýÌýÌýÌýÌý Âé¶¹Éçmadou complies with its legislative obligations to protect data, avoid or reduce possible harm to affected individuals and Âé¶¹Éçmadou, and prevent future breaches.

    4.2ÌýÌýÌýÌýÌý The Data Breach Procedure section below includes a Data Breach Management Plan, which Âé¶¹Éçmadou uses to assess and manage data breaches systematically.Ìý

    4.3ÌýÌýÌýÌýÌý The Data Breach Management Procedure outlines the steps the Data Breach Management Committee will take in the event of a data breach, including but not limited to, notification of affected parties, as well as monitoring and reporting procedures. ÌýÌý

    4.4ÌýÌýÌýÌýÌý Âé¶¹Éçmadou notifies individuals and entities affected by a data breach in accordance with legislative obligations.Ìý Ìý

    4.5ÌýÌýÌýÌýÌý Âé¶¹Éçmadou records data breaches and monitors, analyses and reviews the type and severity of suspected data breaches and the effectiveness of its response.Ìý Ìý

  • 5.1ÌýÌýÌýÌýÌý Âé¶¹Éçmadou information resources and digital communications platforms/technologies are used lawfully, ethically and responsibly.ÌýÌý

    5.2ÌýÌýÌýÌýÌý Âé¶¹Éçmadou information resources and digital communication platforms/technologies are used in compliance with this and other Âé¶¹Éçmadou policies and applicable legislation.Ìý

    5.3ÌýÌýÌýÌýÌý Users of Âé¶¹Éçmadou information resources and digital communications platforms/technologies are responsible for their personal Âé¶¹Éçmadou accounts, and other Âé¶¹Éçmadou accounts that they use, as well as any they store, process or transmit using, or while connected to, a Âé¶¹Éçmadou information resource.Ìý

    5.4ÌýÌýÌýÌýÌý Users of Âé¶¹Éçmadou information resources and digital communications platforms/technologies take all reasonable steps to protect Âé¶¹Éçmadou information resources from physical or digital theft, damage or unauthorised use.Ìý

    5.5ÌýÌýÌýÌýÌý Âé¶¹Éçmadou provides access to Âé¶¹Éçmadou information resources and digital communication platforms/technologies for users to perform legitimate work, research or studies at Âé¶¹Éçmadou and all use is consistent with that purpose.

    5.6ÌýÌýÌýÌýÌý Incidental personal use of Âé¶¹Éçmadou information resources is permitted provided such use does not impact the performance of legitimate work, research or studies at Âé¶¹Éçmadou.Ìý

  • 6.1ÌýÌýÌýÌýÌý The use of artificial intelligence (AI) systems or tools has the potential to benefit Âé¶¹Éçmadou, individuals, society and the environment.

    6.2ÌýÌýÌýÌýÌý AI systems or tools are used equitably with respect for human rights and diversity and to foster inclusion and accessibility.

    6.3ÌýÌýÌýÌýÌý AI systems or tools are trustworthy and are used responsibly, safely and reliably in accordance with their intended purpose throughout their life cycle.

    6.4ÌýÌýÌýÌýÌý The use of AI systems or tools are transparent, and people understand when AI is engaging with or affecting them and/or the environment.

    6.5ÌýÌýÌýÌýÌý AI systems or tools used at Âé¶¹Éçmadou are identifiable, explainable, interpretable, accountable and contestable throughout their life cycle.

    6.6ÌýÌýÌýÌýÌý AI systems or tools used at Âé¶¹Éçmadou are secure and resilient throughout their life cycle.

  • 7.1ÌýÌýÌýÌýÌý oversees Âé¶¹Éçmadou-wide information governance and provides oversight and assurance of related strategic initiatives to protect data, information and records across Âé¶¹Éçmadou.

    7.2ÌýÌýÌýÌýÌý The Research Data Governance and Management Committee oversees the governance and management of research data on behalf of the IGSC. Ìý

    7.3ÌýÌýÌýÌýÌý The oversees the governance and management of data on behalf of the IGSC.

    7.4ÌýÌýÌýÌýÌý The University Leadership Team are responsible for:

    • overseeing the management of personal and health information within their respective portfoliosÌý
    • nominating a University Compliance Owner (UCO) for personal and health information held within their portfolio, while remaining responsible for the performance of the UCO’s duties, which are set out in the Privacy procedure section below.

    7.5ÌýÌýÌýÌýÌý The Chief Information Officer has Âé¶¹Éçmadou-wide authority to:Ìý

    • establish mandatory standards and guidelines and determine the consultation process (in accordance with the Âé¶¹Éçmadou Policy Framework Policy) including the authority to expedite changes to facilitate the management of high or extreme cyber security risks
    • decide whether work, use of equipment, or an operation must cease due to identified or perceived cyber security risk, or a major incident caused by that activity
    • assign Âé¶¹Éçmadou-wide management responsibilities for the use of
    • Âé¶¹Éçmadou information resources
    • digital communication platforms/technologies
    • artificial intelligence systems.

    7.6ÌýÌýÌýÌýÌý The Chief Data Officer is responsible for the overall management of Âé¶¹Éçmadou’s data governance and:

    7.7ÌýÌýÌýÌýÌý The Manager, Records & Archives is responsible for the oversight of Âé¶¹Éçmadou records and information, and:

    • overall management of Âé¶¹Éçmadou’s records and information
    • measuring the performance of Âé¶¹Éçmadou against the Records and Information Management procedure section below
    • maintaining the Records and Information Management Procedure and the Information Governance Instruction Manual
    • leading records and information management initiatives
    • collaborating with other relevant stakeholders to ensure best practice records and information practices are embedded across Âé¶¹Éçmadou
    • working with other accountable stakeholders, including auditors, Government Information (Public Access) (GIPA) officers, and executive management to ensure that systems that manage records and information support organisational and public accountability.

    7.8ÌýÌýÌýÌýÌý ÌýPolicy Leads have authority to change the:

  • 8.1ÌýÌýÌýÌýÌý Where a person suspects that serious wrongdoing has occurred, including corrupt conduct, serious maladministration, a government information contravention, a privacy contravention, and/or a serious and substantial waste of public money, they must report this in accordance with the Public Interest Disclosure (Whistleblowing) Policy and Procedure.

    8.2ÌýÌýÌýÌýÌý Researchers must report potential breaches of the .

    8.3ÌýÌýÌýÌýÌý Non-compliance with this policy may constitute a breach of the Âé¶¹Éçmadou Code of Conduct and Values.

    8.4ÌýÌýÌýÌýÌý Failure to manage Âé¶¹Éçmadou records in accordance with the is an offence under section 21 of the Act.Ìý

    Ìý

Effective:Ìý20 May 2025Ìý Ìý Ìý Ìý ÌýÌýResponsible:ÌýProvost, Vice-President, Operations/Chief Assurance and Legal Officer


Section 1: Data Governance and Management Procedure

Scope

This procedure applies to all data collected, used or generated at Âé¶¹Éçmadou or during Âé¶¹Éçmadou affiliated or (with the exception of library scholarly information resources procured under a contract or licence), including unpublished , , , , and

This procedure applies to researchers, research trainees, employees and affiliates.

  • Every must be managed throughout its life cycle, where appropriate, in accordance with ethics approvals, codes, guidelines, third-party agreements and applicable legislation.

    The data management lifecycle is aligned with the Ìýand the .Ìý

    Âé¶¹Éçmadou
  • 1.1ÌýÌýÌýÌýÌý Every data element must be linked to:

    a.ÌýÌýÌýÌýÌýÌý a who is responsible for the oversight and management of the data delegated to them, and

    b.ÌýÌýÌýÌýÌýÌý a who is responsible for the quality and integrity, ethics, implementation and enforcement of data management within their business unit or research project.

    1.2Ìý Ìý Ìý This information must be captured as a record in a .

    1.3ÌýÌýÌýÌýÌý The Data Custodian must assign each data element a .

    1.4ÌýÌýÌýÌýÌý The Data Custodian must create a data management plan for each non-research data domain. The plan must be maintained and adhered to throughout the data management life cycle.

    1.5ÌýÌýÌýÌýÌý For each research activity or project, the researcher must create a r in consultation with the Data Custodian. The plan must be maintained and adhered to throughout the data management life cycle.

    1.6ÌýÌýÌý must be defined and documented in each data management plan by the Data Custodian.

    1.7ÌýÌýÌý Metadata must be described and managed throughout the data management life cycle.

  • Data creation or collection

    2.1ÌýÌýÌýÌýÌý Data should only be created or collected for use in accordance with the data management plan to fulfil the .

    2.2ÌýÌýÌýÌýÌý Data must be accurate, valid and complete at the time of creation or collection.

    2.3ÌýÌýÌýÌýÌý Data Custodians must ensure that any data being created or collected (other than research data) complies with:Ìý

    a.ÌýÌýÌýÌýÌýÌý the Data Ethics Guideline, and

    b.ÌýÌýÌýÌýÌýÌý the Data Quality Guideline set out in Appendix 2: Information Governance Instruction Manual. In accordance with this Guideline, data must be monitored, enhanced and reported.

    2.4ÌýÌýÌýÌýÌý Data should be collected and recorded immediately or in real time, wherever possible.

    2.5ÌýÌýÌýÌýÌý The collection of data outside Australia must comply with the data collection laws of that jurisdiction. For example, personal data collected from European Union citizens must comply with the requirements of the .

    2.6ÌýÌýÌýÌýÌý Data created or collected outside a Âé¶¹Éçmadou campus must be transported to a Âé¶¹Éçmadou campus or transmitted to a Âé¶¹Éçmadou information resource, unless an agreement specifies otherwise.

    2.7ÌýÌýÌýÌýÌý For the types of data listed in the box below, the following additional data collection procedures must be followed:

    Research Data

    Data Custodians must ensure that research data being created or collected complies with ethics approvals; Âé¶¹Éçmadou’s Privacy Management Plan; relevant Âé¶¹Éçmadou Privacy Statements, codes, guidelines and third-party agreements; and the .

    Researchers collecting research data and materials via data entry or surveys should use Âé¶¹Éçmadou approved tools as set out in Appendix 2: Information Governance Instruction Manual, where possible.

    In addition:

    • Human research data

    Human research data must be created or collected in compliance with the Âé¶¹Éçmadou Human Research Ethics Procedure and the .

    Researchers collecting research data from human participants must do so in compliance with the principles of the and applicable legislation and standards.

    • Animal research data

    Research data from animals must be created or collected in compliance with the Âé¶¹Éçmadou Animal Research Ethics Procedure.

    Researchers collecting research data from animals must do so in compliance with the principles of the and applicable legislation and standards.

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    Aboriginal and Torres Strait Islander peoples

    Aboriginal and Torres Strait Islander peoples’ data must be created or collected in compliance with the and the .

    Researchers engaging in fieldwork in areas of significance to Aboriginal and Torres Strait Islander peoples must acknowledge, consult, and engage with the Indigenous owners of the land before commencing fieldwork.

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    Personal and/or health information

    Personal and/or health information must be collected in compliance with Âé¶¹Éçmadou’s Privacy Management Plan and relevant Privacy Statements.


    Data classification and labelling

    2.8ÌýÌýÌýÌýÌý The Data Custodian (in collaboration with the researcher where appropriate) is required to classify each data element for which they are responsible in accordance with the Âé¶¹Éçmadou Data Classification Standard and, where appropriate, any relevant classification requirements stipulated by state/federal legislation, funding bodies and/or external Data Custodians.

    2.9ÌýÌýÌýÌýÌý Once the data element is classified, the Data Custodian (in collaboration with the researcher where appropriate) must assign it a confidentiality risk rating in accordance with the .

    2.10Ìý Following assignment of the confidentiality risk rating the Data Custodian (in collaboration with the researcher where appropriate) must determine the respective label in accordance with the procedures set out in Appendix 2: Information Governance Instruction Manual.

    2.11Ìý Data Custodians must conduct regular audits of data classification and data security compliance.

    2.12Ìý Where a data element’s original classification has changed, it must be re-classified and re-labelled throughout the data management life cycle. The new classification and label must be recorded by the Data Custodian in the relevant .

  • Data cleansing

    3.1ÌýÌýÌýÌýÌý Unnecessary duplication of data across IT services, devices, and storage locations including hard copies, must be avoided.

    3.2ÌýÌýÌýÌýÌý Data cleansing includes detecting and correcting data errors to improve the quality of data.

    3.3ÌýÌýÌýÌýÌý All data (other than research data) must be cleansed routinely via an automated process where possible, in accordance with the Data Quality Guideline as set out in Appendix 2: Information Governance Instruction Manual.

    Data storage

    3.4ÌýÌýÌýÌýÌý Data must be stored in a Âé¶¹Éçmadou approved storage platform in accordance with the Records and Information Management procedure section below.

    3.5ÌýÌýÌýÌýÌý Data storage must be secure, appropriate to the classification and confidentiality risk rating of the data, and comply with legal, ethical and funding requirements.

    3.6ÌýÌýÌýÌýÌý The Data Custodian (in collaboration with the research and/or IT and Cyber where appropriate) must determine the appropriate storage platform for the data in accordance with the .

    3.7 Data in physical format should always be stored securely with appropriate access restrictions.

    3.8 For the types of data listed in the box below, the following additional procedures must be followed:

    Research Data

    Research data must be stored in a Âé¶¹Éçmadou-supported information system, onsite at Âé¶¹Éçmadou or in an approved research system, where possible.

    When an information system not supported by Âé¶¹Éçmadou is used to store research data, the Data Custodian must, in collaboration with the researcher, ensure that the unsupported platform meets Âé¶¹Éçmadou cyber security requirements and the third-party service provider is subject to a legally binding agreement with Âé¶¹Éçmadou to ensure data security and protection from unauthorised access, use or disclosure. A research data risk assessment of the unsupported platform must be undertaken, and a written record of the platform must be documented in the Research Data Management Plan.

    Physical research materials must be stored in the relevant faculty and, where possible, digitised.

    Researchers should consider whether research materials (including specimens or samples) should be retained in research repositories such as a specified museum, Cold Storage, or the Âé¶¹Éçmadou Herbarium in accordance with the procedures set out in Appendix 2: Information Governance Instruction Manual.

    Ìý

    Aboriginal and Torres Strait Islander people’s data

    Aboriginal and Torres Strait Islander peoples’ data must be stored in compliance with the and in consultation with the Aboriginal and Torres Strait Islander owners of the data.

    Prior to data procurement, researchers, community members and partnering organisations should formally document agreement on the storage, dissemination and potential secondary use of data.

    Ìý

    Personal and/or health information

    Personal and/or health information must be stored in compliance with Âé¶¹Éçmadou’s Privacy Management Plan and relevant Privacy Statements.

  • 4.1ÌýÌýÌýÌýÌý The Data Custodian and Data Steward must manage and maintain the data, where appropriate and plausible, throughout its life cycle.

    4.2ÌýÌýÌýÌýÌý Data Stewards must review and revise the accuracy, completeness, consistency, timeliness, integrity and validity of all data (other than research data) on a regular basis in accordance with the Data Quality Guideline and the Data Ethics Guideline.

    4.3ÌýÌýÌýÌýÌý ÌýData Custodians must ensure that are updated and regularly reviewed.

    4.4ÌýÌýÌýÌýÌý Data Stewards must ensure that metadata is appropriately measured, monitored and subject to quality and assurance audits throughout the data management life cycle.

    4.5ÌýÌýÌýÌýÌý ÌýFor the types of data listed in the box below, the following additional procedures must be followed:

    Research Data

    Data Custodians must ensure that the management of data complies, where required, in accordance with the relevant Âé¶¹Éçmadou ethics approval procedure; Âé¶¹Éçmadou’s Privacy Management Plan and relevant Privacy Statements; codes, guidelines, third-party agreements and the Australian Code for the Responsible Conduct of Research.

    Researchers must report any risk of harm to humans, animals or the environment to as soon as possible.

    ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý

    Aboriginal and Torres Strait Islander people’s data

    Aboriginal and Torres Strait Islander peoples’ data must be managed and maintained in compliance with the

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    Personal and/or health information

    Personal and/or health information must be managed and maintained in compliance with Âé¶¹Éçmadou’s Privacy Management Plan and relevant Privacy Statements.

  • Data sharing

    5.1ÌýÌýÌýÌýÌý Âé¶¹Éçmadou data must not be accessed, viewed, shared or used by anyone from outside the business unit that is responsible for managing the data without data sharing approval or other written approval from the relevant Data Custodian, unless an exemption applies or has been granted by the Data Custodian. The sharing of data must accord with the classification of the data.

    5.2ÌýÌýÌýÌýÌý Âé¶¹Éçmadou data must not be accessed, viewed, shared or used by an external third-party (including product vendors and service providers) without the third-party entering into an approved and legally binding agreement with Âé¶¹Éçmadou to ensure data security and protection from unauthorised access, use or disclosure, unless an exemption has been granted by the external Data Custodian.

    5.3ÌýÌýÌýÌýÌý Where appropriate, before any data (other than publicly available data) is shared outside Âé¶¹Éçmadou, the Data Steward must verify the data to ensure its quality, integrity and security will not be compromised.

    5.4ÌýÌýÌýÌýÌý The process for obtaining data sharing approval is set out in Appendix 2: Information Governance Instruction Manual. Further information and resources are located on the .

    5.5ÌýÌýÌýÌýÌý The Data Governance Office may conduct regular reviews of data sharing compliance and take action to address any non-compliance.

    5.6ÌýÌýÌýÌýÌý For the types of data listed in the box below, the following additional procedures must be followed:

    Research Data

    Unpublished research data must not be shared within Âé¶¹Éçmadou or externally without ethics approval or data sharing approval.

    Unpublished research data containing personal information must not be shared within Âé¶¹Éçmadou or externally without the written consent of the individuals concerned and ethics approval or data sharing approval.

    A researcher must not take research data to another university unless a written agreement is in place with the researcher’s new organisation covering ownership, use, storage and disposal of the research data.


    Data transmission

    5.7ÌýÌýÌýÌýÌý Âé¶¹Éçmadou data must only be transmitted in accordance with the and any relevant data sharing approval or other relevant legal instrument.

    5.8ÌýÌýÌýÌýÌý Data that has a ‘medium’ confidentiality risk rating must be encrypted in transit when transmitted through public or untrusted networks in accordance with the algorithms and protocols in the

    5.9ÌýÌýÌýÌýÌý Âé¶¹Éçmadou Legal & Compliance must conduct a Privacy Impact Assessment before data (that is not subject to a data sharing agreement or other binding legal agreement) that contains personal information or health information about an individual is transferred outside New South Wales or to a Commonwealth agency.

    5.10Ìý Before transmission of digital information to non-OECD member countries (including for processing or storage) occurs, the proposed transmission must be referred to the Chief Information Security Officer or their delegate for additional control requirements.

    5.11Ìý Appendix 2: Information Governance Instruction Manual sets out the procedures in relation to the import/export of research data.

    Data access, use and re-use

    5.12 Âé¶¹Éçmadou data is held and controlled by Âé¶¹Éçmadou not by any individuals. This does not however prevent its (re)use. All Âé¶¹Éçmadou records remain the property of the State of NSW in accordance with the State Records Act 1998 (NSW).

    5.13 Data must be used only in accordance with its data and security classification and label and only for the purpose(s) for which it was collected.

    5.14 Access to data must be granted on a least privilege and need to know basis, in accordance with the

    5.15 Personal use of data (other than research data) is prohibited.

    5.16 Access to and the (re)use of data must be recorded in the .

    5.17 For the types of data in the box below, the additional procedures stated must be followed, where relevant:

    Research Data

    Research data is held and controlled by Âé¶¹Éçmadou, unless subject to a third-party licence agreement, research data sharing agreement or in respect of intellectual property as defined by the Intellectual Property Policy and the Research Authorship, Publication and Dissemination Policy.

    Âé¶¹Éçmadou is committed to open access to research data, as a Group of Eight member and signatory of the

    Data Custodians must ensure that the open access requirements of the Âé¶¹Éçmadou Open Access Policy, the and funding bodies including the and the are met.

    Researchers should, in consideration of privacy, copyright, intellectual property, ethics, cultural sensitivities, third-party and data sharing agreements, encourage open access to research data.

    Researchers must make their data available upon request by Âé¶¹Éçmadou e.g. when integrity concerns or staff misconduct arises.

    Researchers using existing unpublished research data to inform their research project must have permission and meet the conditions for re-use, including the retention and disposal requirements. Unless new research data and information is derived, and therefore new retention requirements arise, avoid unnecessary duplication and retention of existing data.

    N.B. Scholarly Information Resources are recorded in the Âé¶¹Éçmadou library system, Alma.

    ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý

    Aboriginal and Torres Strait Islander people’s data

    Aboriginal and Torres Strait Islander peoples have sovereignty and ownership of research data related to their people, culture, and practices, in line with the .

    Access to and the (re)use of Âé¶¹Éçmadou data relating to Aboriginal and Torres Strait Islander people must pertain to what has been ethically approved by the reviewing Human Research Ethics Committee, and in consultation with the Aboriginal and Torres Strait Islander owners of the data.

    ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý

    Personal and/or health information

    Access to and the (re)use of personal and/or health information must comply with Âé¶¹Éçmadou’s Privacy Management Plan and relevant Privacy Statements.

  • 6.1ÌýÌýÌýÌýÌý Data must be retained in accordance with the Records and Information Management Procedure.

  • 7.1ÌýÌýÌýÌýÌý Data must be disposed of and destroyed in accordance with the Records and Information Management procedure.

  • 8.1.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý The Chief Data & Insights Officer

    See the responsibilities section of the Information Governance policy above for the responsibilities and authorities of the Chief Data and Insights Officer, which include enterprise data governance and management activities.

    8.2.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý Information Governance and Assurance Office

    The Information Governance and Assurance Office supports the Chief Data & Insights Officer to maintain and implement the principles and procedures in relation to information governance. The office is responsible for:

    • ensuring that key information governance roles are appointed, inducted and are aware of their responsibilities
    • providing information governance training and deliver awareness initiatives to the Âé¶¹Éçmadou community as required, to improve information literacy and awareness across Âé¶¹Éçmadou
    • responding to information governance legislative and regulatory requirements
    • reporting to committees on information governance assurance and compliance as required
    • undertaking initiatives to enhance data life cycle management at Âé¶¹Éçmadou.

    The Information Governance and Assurance Office can be contacted via email at datagov@unsw.edu.au.

    8.3.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý Data Executives

    Data Executives are senior leaders with planning and decision-making authority for a specific data domain. The role provides high-level oversight of data and data quality for the data domain. It also serves as an escalation point to resolve any matters that are unable to be resolved by the Data Custodians and Data Stewards for a data domain.

    The Data Executives, as a group, are responsible for overseeing the continuous improvement of Âé¶¹Éçmadou’s data governance and management.

    Data Executives are delegated by the Information Governance Steering Committee and in turn delegate day-to-day accountability for the data assigned to them to Data Custodians and Data Stewards.

    A list of the Data Executives at Âé¶¹Éçmadou is set out in the Information Governance Instruction Manual.

    8.4.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý Data Custodians

    Data Custodians are business leaders with day-to-day accountability for oversight and management of one or more data domains delegated to them by a Data Executive. For example, the Head of HR Systems is the Data Custodian for the human resources domain. Heads of Schools, Heads of Research Institutes, Chief Investigators and/or Principal Investigators, and supervisors may be the Data Custodian for the research domain. Heads of Schools (or Chief Investigators or Principal Investigators) are responsible for maintaining a register of confidential information.

    For each assigned domain, the Data Custodian is responsible for:

    • key data management decisions and directions
    • ensuring that specific industry or research requirements (e.g. Australian Code for the Responsible Conduct of Research, Payment Card Industry Data Security Standard) are identified within their assigned domains, and that appropriate controls are implemented
    • reviewing and approving data sharing approvals; and the quality and integrity, ethics, implementation and enforcement of data management.

    Data Custodians are responsible for ensuring research data and materials have continuous custodianship and, when people with a role or responsibility in a research project leave Âé¶¹Éçmadou, should appoint an appropriate replacement (in consultation with the data steward).

    A list of the Data Custodians at Âé¶¹Éçmadou is set out in the Information Governance Instruction Manual. N.B. The list does not include Data Custodians responsible for research at Âé¶¹Éçmadou.

    8.5.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý Data Stewards

    Data Stewards are functional or operational leaders who represent a business unit related to a specific data domain. Every data domain (including research projects) must have one or more Data Stewards. Data Stewards are responsible for the quality and integrity, ethics, implementation and enforcement of data management within their business unit.

    A list of the Data Stewards at Âé¶¹Éçmadou is set out in the Information Governance Instruction Manual. N.B. The list does not include Data Stewards responsible for research at Âé¶¹Éçmadou.

    8.6.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý Data users

    Data users are members of the Âé¶¹Éçmadou community who use data that they have been granted access to for authorised purposes to carry out their day-to-day duties.

    Data users are responsible for:

    • using data in compliance with this policy and relevant legislation
    • using data ethically and securely while respecting confidentiality and privacy
    • ensuring the data they consume is fit for its specific purpose/s, and
    • providing feedback about the quality of data to relevant Data Stewards.

    8.7.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý External data users

    External data users are persons or organisations who access, input, amend, delete, extract, or analyse data and the information created by data in/from a Âé¶¹Éçmadou information resource and are not employees, contractors, consultants or authorised agents of Âé¶¹Éçmadou. For example, vendors of information systems and information services used by Âé¶¹Éçmadou are external data users.

    Ìý

Effective:Ìý20 May 2025Ìý ÌýÌý

Responsible:ÌýProvost, DVC Research and EnterpriseÌý

Leads:ÌýData and InformationÌýGovernanceÌýManager/Executive Director, ResTech


Section 2: Records and Information Management Procedure

Scope

This procedure applies to researchers, research trainees, employees and affiliates.

This procedure applies to records in any format including print, electronic or audiovisual records.Ìý

Recordkeeping process

  • 1.1ÌýÌýÌý Full and accurate records must be created to document Âé¶¹Éçmadou business activity. Any document in any format that provides evidence of the University's business activities is a record.

    1.2ÌýÌýÌý Examples of records might include emails sent or received that document business activity, reports, correspondence, briefing notes, meeting agendas and minutes, file notes of conversations or decisions.

  • Systems

    2.1ÌýÌýÌýÌýÌý All records or business activities must be captured to a Âé¶¹Éçmadou System of Record. These are business systems that have been assessed to ensure the requirements of a record are met.

    2.2ÌýÌýÌýÌýÌý ÌýA Âé¶¹Éçmadou System of Record must be:

    • a system that is managing Âé¶¹Éçmadou records such as (Records and Archives Management System)
    • capable of meeting any legislative requirements for these records
    • able to capture (and return) fixed, complete, authentic, reliable, useable records
    • able to capture (and show) core metadata (description, structure, context, related records, events, retrieval information) during and beyond the life of the record itself
    • secure and able to restrict access to records (and metadata) or groups of records to meet accountability, legislative and business requirements
    • able to prevent deletion of records and metadata unless as part of authorised disposal activity
    • able to capture an audit log of system activity
    • able to support migration and/or controlled disposal of records depending on the period for which records must be retained
    • authorised as a Âé¶¹Éçmadou System of Record and have an identified records and information management Business owner (responsible for the business process) and System owner (responsible for the business system). These responsibilities may be delegated where appropriate and documented.

    2.3ÌýÌýÌýÌýÌý The assessment process to determine if a business system is a Âé¶¹Éçmadou System of Record is to be completed by the Business owner using this and is maintained by the Records & Archives Office.

    2.4ÌýÌýÌýÌýÌý Records and information management is assessed in all outsourced, cloud and similar service arrangements in consultation with the Records & Archives Office.

    2.5ÌýÌýÌýÌýÌý The Business owner and System owner must ensure that records and information are maintained throughout system and service migrations.

    2.6ÌýÌýÌýÌýÌý System decommissioning takes into account retention and disposal requirements for records and information held in the system before final approval by the Manager, Records & Archives.

    Long-term records

    2.7ÌýÌýÌýÌýÌý State archives and University archives are routinely identified and transferred by the Records & Archives Office to safeguard, manage and preserve records with long-term value.

    2.8ÌýÌýÌýÌýÌý Records that are more than 20 years old are by default under the deemed to be open to public access unless a CPA (Closed to Public Access) direction has been made by Âé¶¹Éçmadou. CPAs are created and maintained by the Records & Archives Office.

    High risk and high value records

    2.9ÌýÌýÌýÌýÌý Âé¶¹Éçmadou is required to identify the systems, records and information needed to support its high value and high-risk processes.

    2.10Ìý High risk and high value records are one (or more) of the following:

    • records Âé¶¹Éçmadou is required to retain for more than 20 years
    • records of Âé¶¹Éçmadou’s core activities (research, teaching)
    • records of Âé¶¹Éçmadou’s key corporate functions (personnel, finance, student administration)
    • records containing personal or health information
    • records of agreements and contracts for expenditure of $150,000 or more (including GST)
    • records of significant organisational change.

    2.11Ìý Records of high-risk high value business and the systems that manage them are identified and documented by the Records & Archives Office to enable them to be prioritised and any risks evaluated and managed appropriately.

    2.12Ìý A Âé¶¹Éçmadou System of Record assessment is used by the Records & Archives Office to identify where records of high-risk high value business are captured. The completion of these evaluations is the responsibility of the Business owner.

    2.13Ìý Business owners retain overall responsibility for ensuring records of high risk and high value business are safely managed and protected by business continuity plans.

    2.14Ìý A business and the systems that manage them is maintained by the Records & Archives Office.

    2.15Ìý The Records & Archives Office routinely monitors and reviews compliance with the requirements for the identification and management of high-risk records.

  • Metadata records

    3.1ÌýÌýÌýÌýÌý The following metadata must be recorded for records and information:Ìý

    a.ÌýÌýÌýÌý a description of their content

    b.ÌýÌýÌýÌý their structure (form and format) and the relationships between their components which comprise them

    c.ÌýÌýÌýÌý the business context in which they were created or received and used; who created them, why they were created, how they have been used and managed

    d.ÌýÌýÌýÌý relationships with other records, information and metadata

    e.ÌýÌýÌýÌý business actions and events involving the records and information throughout their existence

    f.ÌýÌýÌýÌýÌý information that may be needed to retrieve and present them.

    3.2ÌýÌýÌýÌýÌý Metadata must be configured in systems and carried forward to accompany the records through system changes.

    Storage and scanning

    3.3Ìý Records and information in digital format must be stored in an appropriate, secure location in accordance with the . Hard copy records should always be stored securely with appropriate access restrictions.

    3.4Ìý Portable storage devices storing medium or high Confidentiality Risk rated digital information must comply with the

    3.5Ìý Portable storage devices of an unknown source or origin must not be used.

    3.6Ìý Records stored offsite should use Âé¶¹Éçmadou’s of storage. Records stored offsite must always be appraised and a disposal authority applied prior to their transfer.

    3.7Ìý Scanning records from hardcopy to digital only impacts their format; it has no bearing on the minimum legal period for which they must be retained. However, it may be possible to destroy the source paper records as part of this process if the conditions for their destruction have been met.

    3.8Ìý The Records & Archives Office routinely monitors and reviews compliance with record storage requirements.

  • 4.1Ìý Records must be linked to a current authorised retention and disposal authority.

    4.2Ìý For the types of data in the box below, the additional procedures stated must be followed, where relevant:

    Ìý

    Research Data

    Researchers have primary responsibility for determining and applying the appropriate retention period for their research data and materials, including long-term retention. Such decisions should be made in collaboration with Data Custodians.

    Researchers leaving Âé¶¹Éçmadou must ensure that research data is retained by Âé¶¹Éçmadou to support research integrity and fulfil retention obligations.

    Researchers must publish metadata about their research that is published or made publicly available in association with a project, publication, or HDR thesis in , the Âé¶¹Éçmadou institutional repository, or a suitable third-party repository.

    N.B. Scholarly Information Resources are recorded in the library system, Alma.

    Ìý

    Aboriginal and Torres Strait Islander people’s data

    Data that may have cultural significance or value to Aboriginal and Torres Strait Islander peoples’ decision-making should be retained for future use in accordance with Indigenous data governance principles.

    Âé¶¹Éçmadou must retain Aboriginal and Torres Strait Islander peoples’ data in compliance with the and in consultation with the Aboriginal and Torres Strait Islander owners of the data.

    Ìý

    Personal and/or health information

    Personal and/or health information must be retained in compliance with Âé¶¹Éçmadou’s Privacy Management Plan and relevant Privacy Statements.

    Ìý

  • 5.1Ìý Records must never be destroyed without undergoing a formal process of appraisal, and consultation where appropriate with the researcher and the approval of the Records & Archives.

    5.2Ìý Once the destruction of record is approved, the System owner must ensure that the records are securely and irretrievably destroyed.

    5.3Ìý Records that are ephemeral or facilitative and do not have any continuing value are destroyed in accordance with Normal Administrative Practice (NAP). What constitutes NAP is described here:ÌýNormal Administrative Practice (NAP)

    5.4Ìý The Records & Archives Office monitors and reviews compliance with record disposal and destruction requirements.

  • 6.1Ìý Manager, Records & Archives

    See the responsibilities section of the Information Governance policy above for the responsibilities and authorities of the Manager, Records & Archives.

    Ìý

    6.2Ìý Records & Archives Office

    The Records & Archives Office supports the Manager, Records & Archives, to maintain and implement the principles and procedures in relation to records and information management. The Office is responsible for:

    • support for the management of all records, in any format, including access to and use of the enterprise recordkeeping system RAMS
    • providing records and information management training and initiatives to the Âé¶¹Éçmadou community as required, to improve records and information management practice across Âé¶¹Éçmadou
    • the collection, maintenance and provision of access to, Âé¶¹Éçmadou’s archival collections
    • consultancy services on records and information management including business process analysis, redesign and support for the identification of digital recordkeeping solutions
    • oversight of the Âé¶¹Éçmadou System of record framework
    • providing advice on, and authorisation for, the disposal of records
    • responding to records and information management legislative and regulatory requirements.

    6.3Ìý ÌýSupervisors and Business owners

    Supervisors and Business owners are responsible for:

    • ensuring appropriate systems and processes are in place for the capture, retention and disposal of records within their areas of responsibility
    • ensuring employees in their business unit are aware of their recordkeeping responsibilities and how to meet them, including the requirement to never destroy records without the necessary approval
    • confirming that any new business system is assessed as a Âé¶¹Éçmadou system of record prior to implementation
    • ensuring that high risk and high value business records and the systems which manage them are identified and protected by business continuity strategies and plans.Ìý

    Ìý

Effective:Ìý20 May 2025Ìý Ìý Ìý Ìý Ìý Ìý ÌýResponsible:ÌýManager, Records & ArchivesÌý ÌýÌýÌýÌýÌý Ìý Ìý Ìý Ìý Ìý Ìý Ìý ÌýÌýLead:ÌýManager, Records & Archives


Section 3: Privacy Procedure

Scope

This procedure applies to students, researchers, research trainees, employees and affiliates. Controlled entities of Âé¶¹Éçmadou manage personal and health information in accordance with laws applicable to that entity.

  • 1.1Ìý Âé¶¹Éçmadou manages personal and health information in accordance with this policy and the Privacy Management Plan.

  • 2.1Ìý Before any new project (other than a research project or activity) that is designed to hold or process personal information and/or health information on behalf of Âé¶¹Éçmadou is implemented, it may be subject to a Privacy Impact Assessment (PIA). A PIA ensures that personal information and/or health information is protected from unauthorised access, use, modification or disclosure.

    2.2Ìý The sponsor of the new project is responsible for notifying Âé¶¹Éçmadou Legal & Compliance and, where appropriate the Âé¶¹Éçmadou IT Cyber Security Strategy & Governance team, that a new project has been proposed.

    2.3Ìý The procedure for conducting a PIA is set out in Appendix 2: Information Governance Instruction Manual.

    2.4Ìý Âé¶¹Éçmadou Legal & Compliance will advise the new project sponsor of the outcome of the PIA assessment.Ìý

  • 3.1Ìý Âé¶¹Éçmadou publishes open access information that can be accessed via the Accessing University Information webpage or by conducting a search of Âé¶¹Éçmadou’s website at /.

    3.2Ìý Âé¶¹Éçmadou may disclose information that is not published on its website informally or through a formal application process in accordance with the .

    3.3Ìý Informal requests for information should be emailed to:Ìýgipaa@unsw.edu.au

    3.4Ìý The procedure for requesting information is set out in Appendix 2: Information Governance Instruction Manual.

  • 4.1Ìý Privacy complaints about Âé¶¹Éçmadou may be resolved through the Complaints Management and Investigations Policy and Procedure, or through an application for internal review under the (PIPP Act). Further information about internal or external complaints is set out in the Privacy Management Plan.

    4.2Ìý The procedure for making a privacy complaint is set out in Appendix 2: Information Governance Instruction Manual.

  • 5.1. University Leadership Team

    See the responsibilities section of the Information Governance policy above for the responsibilities and authorities of the University Leadership Team.


    5.2. Âé¶¹Éçmadou Legal & Compliance

    Âé¶¹Éçmadou Legal & Compliance is responsible for:

    • providing advice on the privacy obligations imposed by this policy and applicable privacy laws.
    • supporting the University Compliance Officers to develop local protocols and privacy statements for use in their area of responsibility
    • developing guidelines, training and other supporting material to support awareness of obligations imposed by applicable privacy laws
    • conducting internal reviews of privacy complaints received in accordance with applicable legislation.

    5.3. University Compliance Owners (UCOs)

    UCOs are responsible for:

    • ensuring that University-wide procedures implemented to support this policy are applied in the management of personal and health information within their respective portfolios
    • implementing effective local procedures to ensure that personal and health information held within their portfolio is managed in accordance with this policy
    • ensuring that any person who has access to the personal information held within their portfolio understands their responsibilities regarding such information
    • ensuring that privacy statements that comply with all applicable laws are provided to individuals when their personal information is collected.

    Ìý

Effective:Ìý20 May 2025Ìý Ìý Ìý Ìý Ìý Ìý ÌýResponsible:ÌýChief Assurance and Legal OfficerÌýÌýÌýÌýÌý Ìý Ìý Ìý Ìý Ìý ÌýÌýLead:ÌýHead of Compliance & Privacy Law


Section 4: Data Breach Procedure

Scope

This procedure applies to students, researchers, research trainees, employees and affiliates

  • 1.1Ìý A data breach occurs when any data (whether in digital or hard copy) held by Âé¶¹Éçmadou is lost or subjected to unauthorised access (both internal and external to Âé¶¹Éçmadou), modification, disclosure, or other misuse or interference. Examples include:

    • unauthorised access to, or the unauthorised collection, use, or disclosure of, data
    • accidental loss, unauthorised access, or theft of classified material, data or equipment on which such data is stored (such as loss of paper records, laptop, iPad or USB stick)
    • unauthorised use, access to, or modification of data or information systems (such as, sharing of user login details (deliberately or accidentally) to gain unauthorised access or make unauthorised changes to data or information systems)
    • unauthorised disclosure of confidential information (such as an email sent to an incorrect recipient or document posted to an incorrect address or addressee) or personal information posted on the website without consent
    • a compromised user account (such as accidental disclosure of user login details through phishing)
    • failed or successful attempts to gain unauthorised access to Âé¶¹Éçmadou information or information systems
    • equipment failure, malware infection or disruption to or denial of IT services resulting in a data breach
    • the loss or theft of a device containing personal information or health information
    • a Âé¶¹Éçmadou database or information repository containing personal or health information being subject to a cyber-attack
    • a device, database or information repository containing personal or health information being accessed without authorisation
    • Âé¶¹Éçmadou inadvertently providing personal or health information to an unauthorised person or entity.
  • 2.1Ìý A data breach involving personal information and/or health information (whether in digital or hard copy) occurs when there is:

    • unauthorised access to or unauthorised disclosure (whether internal or external to Âé¶¹Éçmadou) of personal information or health information held by Âé¶¹Éçmadou; or
    • a loss of personal information or health information held by Âé¶¹Éçmadou in circumstances that are likely to result in unauthorised access to, or unauthorised disclosure of, the information.

    2.2Ìý Where a data breach involves personal information or health information, and a reasonable person would conclude that the access or disclosure of the information is likely to result in serious harm to an individual to whom the information relates, such a data breach will constitute an “eligible data breach†and be subject to mandatory data breach notification obligations prescribed by the (‘PIPP Act’) (and in certain circumstances by other privacy laws).

  • 3.1Ìý Anyone who has identified a suspected or confirmed a data breach must immediately raise a ticket via the IT Service Centre: (itservicecentre@unsw.edu.au).

    3.2Ìý ÌýOn receiving the notification, the IT Service Centre will:

    a.ÌýÌýÌýÌý forward the notification to the Cyber Security Incident Response Team who will assess the breach to determine whether the breach constitutes a cyber security incident; and

    b.ÌýÌýÌýÌý the Data Breach Management Committee (DBM Committee).Ìý

    3.3Ìý The Cyber Security Incident Response Team will immediately notify the DBM Committee of the outcome of their assessment of the data breach.Ìý

  • 4.1Ìý Where a ticket is raised to report a suspected or confirmed data breach the IT Service Centre will immediately notify all members of the Data Breach Management Committee (DBM committee).

    4.2Ìý Upon such notification, the DBM committee will:

    a.ÌýÌýÌýÌý immediately update the IT ticket to note that the breach has been referred to them

    b.ÌýÌýÌýÌý in consultation with the Committee as a whole, assign a member of the Committee (the lead investigator) to assess and manage the data breach in accordance with the Data Breach Management Plan, set out in Appendix 2: Information Governance Instruction Manual

    c.ÌýÌýÌýÌý notify the Critical Incident Team if the data breach is determined by the Committee to amount to a major data breach; and

    d.ÌýÌýÌýÌý provide support and guidance to the staff member(s) who identified the data breach.

  • 5.1Ìý Where the suspected or confirmed data breach involves personal information or health information, Âé¶¹Éçmadou Legal & Compliance will assess the breach. If there are reasonable grounds to suspect that the breach is an eligible data breach, Âé¶¹Éçmadou Legal & Compliance will:

    a.ÌýÌýÌýÌý immediately update the IT ticket to note that the breach has been referred to them

    b.ÌýÌýÌýÌý notify the General Counsel of the potential eligible data breach

    c.ÌýÌýÌýÌý assign a lead investigator on behalf of the DBM committee and assess and manage the data breach in accordance with the Data Breach Management Plan, the mandatory data breach notification obligations prescribed by the PPIP Act, and any contractual obligations relating to the data impacted by the breach.

    d.ÌýÌýÌýÌý in accordance with s 59ZJ of the PPIP Act, the functions of the Vice-Chancellor, acting as the head of Âé¶¹Éçmadou for the purpose of Part 6A of the PPIP Act, are delegated to the General Counsel.

  • 6.1Ìý Upon referral of a suspected or confirmed data breach or eligible data breach, the lead investigator will enact the Data Breach Management Plan, as set out in the Information Governance Instruction Manual, as follows:

    • immediately contain the breach and conduct a preliminary assessment
    • evaluate the risks associated with the breach
    • notify affected individuals or entities
    • notify employee who reported the breach
    • investigate the cause of the breach to prevent future breaches.
  • 7.1. IT Service Centre

    IT Service Centre receives the first notification of the suspected or confirmed data breach and creates a ticket.

    7.2. Cyber Security Incident Response Team

    The Cyber Security Incident Response Team assesses the suspected or confirmed data breach to determine whether it constitutes a cyber security incident.

    7.3. Data Breach Management Committee

    The Data Breach Management Committee implements the Data Breach Management Plan for a suspected or confirmed data breach or eligible data breach, appoints lead investigator, notifies Chief Legal Officer of suspected or confirmed eligible data breach.

    The Data Breach Management Committee has authority to change the:

    7.4. Lead Investigator

    The Lead Investigator investigates the suspected or confirmed data breach or eligible data breach in accordance with the Data Breach Management Plan.

    7.5. Chief Legal Officer

    The Chief Legal Officer, in the case of an eligible data breach notifies the Privacy Commissioner and individuals that are affected by the breach.

Effective:Ìý20 May 2025Ìý Ìý Ìý Ìý Ìý Ìý ÌýResponsible:ÌýChief Assurance and Legal OfficerÌýÌýÌýÌýÌý Ìý Ìý Ìý Ìý Ìý ÌýÌýLead:ÌýHead of Compliance & Privacy Law


Section 5: Use of Âé¶¹Éçmadou Information Resources and Digital Communications Platforms/Technologies Procedure

Scope

This procedure applies to students, researchers, research trainees, employees and affiliates.

  • 1.1Ìý Âé¶¹Éçmadou information resources and provisioned digital communication platforms/technologies must be used for in an ethical, lawful and responsible manner.

    1.2Ìý Users are accountable for all activities originating from their own and other Âé¶¹Éçmadou accounts they access.

    1.3Ìý Users must take all reasonable steps to protect Âé¶¹Éçmadou information resources from physical or digital theft, damage or unauthorised use.

    1.4Ìý Users must only store, process or transmit digital information in accordance with this policy.

    1.5Ìý Senders, recipients and managers of digital communication platforms/technologies are required to exercise due diligence to ensure the protection of confidential communications.

    1.6Ìý Digital communication platforms/technologies should not be used to send sensitive and confidential information unless the appropriate security measures including encryption have been taken.

    1.7Ìý Employees are responsible for capturing and retaining digital communications relating to Âé¶¹Éçmadou’s business activities so that they are accessible as records to meet business and evidential needs.

    1.8Ìý Employees are responsible for:

    a.ÌýÌýÌýÌý reporting any spam, phishing, malware and other malicious digital communications

    b.ÌýÌýÌýÌý reporting any digital communications sent intentionally or unintentionally that violates the or may result in a data breach.

    1.9Ìý ÌýEmployees must complete Âé¶¹Éçmadou assigned cyber security awareness training.Ìý

  • 2.1ÌýÌýÌý Âé¶¹Éçmadou recognises that the nature of work, study and research at Âé¶¹Éçmadou means that a user may use Âé¶¹Éçmadou information resources and digital communication platforms/technologies for a broad range of legitimate purposes (consistent with the principles of academic freedom). However, users must not use Âé¶¹Éçmadou information resources or digital communications platforms/technologies to:

    a.ÌýÌýÌýÌý harass, stalk, menace, defame, vilify, or unlawfully discriminate against another person

    b.ÌýÌýÌýÌý collect, use or disclose personal information except in accordance with this policy

    c.ÌýÌýÌýÌý knowingly copy, download, store or transmit material which infringes the intellectual property of any other party

    d.ÌýÌýÌýÌý knowingly distribute spam, phishing, chain letters, or any other type of unauthorised widespread distribution of unsolicited digital communications in contravention of the Spam Act 2003 (Cth)

    e.ÌýÌýÌýÌý represent or create the impression of representing Âé¶¹Éçmadou unless authorised to do so

    f.ÌýÌýÌýÌýÌý represent another person or claim to represent another person unless explicitly authorised, or

    g.ÌýÌýÌýÌý otherwise cause loss or harm to the reputation of Âé¶¹Éçmadou.

    2.2ÌýÌýÌý Users must not:

    a.ÌýÌýÌýÌý use another person’s account including those assigned to other individuals and system accounts, without a delegation and approval to do so

    b.ÌýÌýÌýÌý share their password or other authentication factor with any other person

    c.ÌýÌýÌýÌý assist or permit the use of Âé¶¹Éçmadou information resources or digital communications platforms/technologies by an unauthorised person

    d.ÌýÌýÌýÌý attempt to gain unauthorised access to or access for an unauthorised purpose Âé¶¹Éçmadou information resources or digital communications platforms/technologies

    e.ÌýÌýÌýÌý use Âé¶¹Éçmadou information resources, or personal devices, or digital communications platforms/technologies to intentionally or knowingly compromise the confidentiality, integrity, availability or privacy of Âé¶¹Éçmadou information resources or digital information

    f.ÌýÌýÌýÌýÌý travel with Âé¶¹Éçmadou Information Resources (for any purpose) to a destination deemed by Âé¶¹Éçmadou to be high risk, without the approval of the Âé¶¹Éçmadou Risk Management team.

    g.ÌýÌýÌýÌý use Âé¶¹Éçmadou information resources or digital communications platforms/technologies to access, display, store, copy, process, transmit or provide prohibited or restricted material, other than in accordance with section 3 of this procedure below

    h.ÌýÌýÌýÌý intentionally distribute spam, phishing, chain letters, or any other type of unauthorised widespread distribution of unsolicited digital communications

    i.ÌýÌýÌýÌýÌýÌý intentionally distribute viruses, worms, Trojan horses, malware, corrupted files, hoaxes, or other items of a destructive or deceptive nature, including using a platform/technology to distribute software that covertly gathers or transmits information about an individual

    j.ÌýÌýÌýÌýÌýÌý use language that is excessively violent, incites violence, threatens violence, or contains harassing content

    k.ÌýÌýÌýÌýÌý create a risk to a person’s safety or health, create a risk to public safety or health, compromise national security, or interfere with an investigation by law enforcementÌý

    l.ÌýÌýÌýÌýÌýÌý attempt to manipulate, circumvent or interfere with the security and functionality of the platform/technology in any mannerÌýÌýÌýÌýÌý

    m.ÌýÌýÌý intentionally circumvent identity controls or other cyber security controls other than for authorised testing

    n.ÌýÌýÌýÌý test, bypass, deactivate or modify the function of any cyber security control (including an operating system), knowingly install or use malicious software or connect an end-of-life, end-of-support, or intentionally compromised device to Âé¶¹Éçmadou information resources or digital communications platforms/technologies except for research or teaching purposes; and (ii) with written approval of the Head of School as part of an approved course or equivalent and in an isolated testing environment or isolated network

    o.ÌýÌýÌýÌý collect or use email addresses, screen names information or other identifiers without the consent of the person identified (including without limitation, phishing, spidering, and harvesting).

  • 3.1ÌýÌýÌý Users can access, display, store, copy, or transmit prohibited or restricted material on or using Âé¶¹Éçmadou information resources for research or teaching purposes only (i) in accordance with all applicable laws, Ìýincluding those jurisdictions where the data is collected, stored or published, policies, procedures, and standards, including the ; and (ii) with human or animal ethics approval where appropriate; and (iii) with the express written approval of a relevant Deputy Vice-Chancellor (for prohibited material) or a Head of School or equivalent (for restricted material).

    3.2ÌýÌýÌý Users can access, display, store, copy, or transmit prohibited or restricted material on or using Âé¶¹Éçmadou information resources for the purpose or intention of investigation of a potential breach of a code of conduct, policy, procedure by the Conduct and Integrity Office or Human Resources.

  • 4.1ÌýÌýÌý Âé¶¹Éçmadou provides access to Âé¶¹Éçmadou information resources and digital communications platforms/technologies for users to perform work, research or studies at Âé¶¹Éçmadou and all usage must be consistent with that purpose, other than the exceptions in the next clause.

    4.2ÌýÌýÌý Users are permitted limited and incidental personal use of Âé¶¹Éçmadou information resources and digital communications platforms/technologies. However, this use must not:

    a.ÌýÌýÌýÌý directly or indirectly impose an unreasonable burden on any Âé¶¹Éçmadou information resource or burden Âé¶¹Éçmadou with incremental costs

    b.ÌýÌýÌýÌý unreasonably deny any other user access to any Âé¶¹Éçmadou information resource

    c.ÌýÌýÌýÌý contravene any law, Âé¶¹Éçmadou’s Code of Conduct and Values and Âé¶¹Éçmadou policies or interfere with or conflict with Âé¶¹Éçmadou’s functions.

    d.ÌýÌýÌýÌý in the case of employees, interfere with the execution of their responsibilities.

    4.3ÌýÌýÌý Users who store, process or transmit their own personal information as part of their personal use of a Âé¶¹Éçmadou information resource are responsible for deciding how that information is secured (such as, encrypted) and backed up.

    4.4ÌýÌýÌý Âé¶¹Éçmadou is not responsible for ensuring that personal data is retained or providing such data to a user.

    4.5ÌýÌýÌý Personal emails remain subject to the provisions of this policy and as such may be accessed in accordance with the monitoring and surveillance section of this procedure below.

    4.6ÌýÌýÌý Excessive use of Âé¶¹Éçmadou information resources (such as to generate or mine crypto currency) is not permitted, except for research or teaching purposes, and with the express written approval of the Head of School or equivalent.

    4.7ÌýÌýÌý Employees and students must not use Âé¶¹Éçmadou information resources or digital communications platforms/technologies for:

    a.ÌýÌýÌýÌý financial or commercial gain for themselves or any third party; or

    b.ÌýÌýÌýÌý private professional practice.

  • 5.1ÌýÌýÌý Employees performing duties at Âé¶¹Éçmadou using personal devices must ensure that these devices:

    a.ÌýÌýÌýÌý are password protected, or have an equivalent access restriction mechanism enabled

    b.ÌýÌýÌýÌý have malware protection enabled, where available

    c.ÌýÌýÌýÌý are patched or updated promptly and

    d.ÌýÌýÌýÌý are encrypted.

    5.2ÌýÌýÌý Employees must report the loss or theft of, or damage of a personal device containing Âé¶¹Éçmadou data to Âé¶¹Éçmadou Campus Security and to the IT Service Centre at the earliest opportunity in accordance with the reporting data breach requirement set out in the Data Breach Procedure.

    5.3ÌýÌýÌý Âé¶¹Éçmadou does not guarantee that a personal device will be able to access, or be compatible with, all Âé¶¹Éçmadou information resources.

    5.4ÌýÌýÌý Using personal accounts or storing information locally on personal devices for University business is prohibited.

    5.5ÌýÌýÌý If personal accounts are used, Âé¶¹Éçmadou systems that are accessible via a personal device (e.g. Outlook, Teams, OneDrive) must be used. Any information generated must be automatically saved in a Âé¶¹Éçmadou system.

    5.6ÌýÌýÌý If there are no other options but to use a personal account, the information generated must be captured to a Âé¶¹Éçmadou system as soon as practicable.

  • 6.1ÌýÌýÌý Âé¶¹Éçmadou takes reasonable precautions to protect the security of Âé¶¹Éçmadou information resources and digital communications platforms/technologies but does not guarantee that Âé¶¹Éçmadou information resources and digital communications platforms/technologies will always be available, secure, confidential, or free from defects, including malicious software.

    6.2ÌýÌýÌý Âé¶¹Éçmadou accepts no responsibility for loss or damage (including consequential loss or damage or loss of data) arising from the use of Âé¶¹Éçmadou information resources and digital communications platforms/technologies, or from the maintenance and protection of Âé¶¹Éçmadou information resources and digital communications platforms/technologies.

    6.3ÌýÌýÌý Subject to complying with all applicable laws, Âé¶¹Éçmadou may take any necessary action in accordance with the Cyber Security Policy, to mitigate any threat to Âé¶¹Éçmadou information resources and digital communications platforms/technologies, with or without notice.

    6.4ÌýÌýÌý Âé¶¹Éçmadou reserves the right to:

    a.ÌýÌýÌýÌý limit or terminate the use of Âé¶¹Éçmadou information resources and digital communications platforms/technologies, with or without notice, subject to clause 11.4 of this Procedure

    b.ÌýÌýÌýÌý view, copy, disclose or delete digital information stored, processed, or transmitted using Âé¶¹Éçmadou information resources and digital communications platforms/technologies subject to complying with all applicable laws

    c.ÌýÌýÌýÌý monitor or examine the security of any device connecting to Âé¶¹Éçmadou information resources and digital communications platforms/technologies, to identify or address a cyber security threat

    d.ÌýÌýÌýÌý monitor, access, examine, take custody of, and retain any Âé¶¹Éçmadou information resource and digital communications platforms/technologies.

    6.5ÌýÌýÌý Access to a Âé¶¹Éçmadou information resource, or storage, processing and transmitting of data (including email) may be delayed or prevented in the event of misuse or suspected misuse, or in the event of a security event or suspected security event.

    6.6ÌýÌýÌý Âé¶¹Éçmadou may at any time require a user to:

    a. acknowledge in writing that they will abide by this policy

    b. complete relevant training in Âé¶¹Éçmadou policies and procedures.

  • 7.1ÌýÌýÌý Transmission of digital communications to multiple users must only be undertaken using a Âé¶¹Éçmadou approved service provider.

    7.2ÌýÌýÌý The transmission must be controlled so that users do not receive a large quantity of unwanted and unsolicited digital communications as this can reduce the effectiveness of the digital communications platforms/technologies.

    7.3ÌýÌýÌý Users may solicit communications on a particular topic by subscribing to a Âé¶¹Éçmadou mailing list or third-party mailing list from which they can also unsubscribe at will.

    7.4ÌýÌýÌý Unsolicited communications may only be sent to multiple users where the communication is related to their Âé¶¹Éçmadou duties and the sender has a relevant work relationship with the recipients.

    7.5ÌýÌýÌý Any broadcast email to students should be conducted via Student Communications or Faculty/School specific communications channels.

    7.6ÌýÌýÌý Special interest groups must issue invitations to join before including any group or individual in a mailing list, and members have the right to unsubscribe at will.

    7.7ÌýÌýÌý Users who wish to send a broadcast digital communication to the Âé¶¹Éçmadou community, or a substantial subset of the community (such as all academics) must follow the procedure set out in Appendix 2: Information Governance Instruction Manual.

  • 8.1ÌýÌýÌý The use of scanned signatures is discouraged as they are vulnerable to forgery. The digital signature technology approved by Âé¶¹Éçmadou will be published by Âé¶¹Éçmadou IT. Alternate solutions such as electronic and digital signatures should be used instead for all official documents.

  • 9.1ÌýÌýÌý Âé¶¹Éçmadou may terminate the access of any user whom it believes is not operating in compliance with this procedure or the law.

  • 10.1ÌýÌýÌý All data stored, processed, or transmitted using any Âé¶¹Éçmadou information resource and digital communications platforms/technologies:

    a.ÌýÌýÌýÌý may be recorded and monitored on an ongoing and continuous basis, in accordance with the Âé¶¹Éçmadou Cyber Security Standards

    b.ÌýÌýÌýÌý may be subject to the Government Information (Public Access) Act 2009 (NSW)

    c.ÌýÌýÌýÌý may be subject to the Privacy and Personal Information Protection Act 1998 (NSW)

    d.ÌýÌýÌýÌý may be subject to the Health Records and Information Privacy Act 2002 (NSW)

    e.ÌýÌýÌýÌý may be subject to the State Records Act 1998 (NSW), and

    f.ÌýÌýÌýÌýÌý will remain in the custody and control of Âé¶¹Éçmadou other than where the conditions for external sharing of Âé¶¹Éçmadou data stated in the data management procedure section above are met.

    10.2ÌýÌýÌý Users should be aware that personal use of Âé¶¹Éçmadou information resources and digital communications platforms/technologies may result in Âé¶¹Éçmadou holding personal information about the user or others which may be accessed and used by Âé¶¹Éçmadou to ensure compliance with this and other policies.Ìý

    10.3ÌýÌýÌý Scanning and monitoring of personal drives and devices connected to a Âé¶¹Éçmadou Information Asset must not unreasonably intrude into the personal affairs of individual employees or students.Ìý

    10.4ÌýÌýÌý The following approvals are required for access by a person other than the owner or custodian to Âé¶¹Éçmadou storage services and storage devices such as mailboxes, Microsoft 365 services, hard drives, and file shares that may also contain personal information.ÌýÌýÌý

    Circumstance

    Approver

    When required for legal proceedings or as required by law (such as to comply with a notice to produce or subpoena).

    Chief Legal Officer and any one of:Ìý

    Chief People Officer

    Director, Conduct & Integrity

    Chief Information Officer.

    For cyber security purposes

    Chief Information Officer; or Director, Cyber Security and any one of:

    Chief Legal OfficerÌý

    Chief People Officer

    Director, Conduct & Integrity

    When Âé¶¹Éçmadou reasonably suspects that an individual(s) is not complying with legislation or a Âé¶¹Éçmadou code, policy or procedure

    Chief Legal Officer, and any one of:

    Chief People Officer

    Director, Conduct & Integrity

    Chief Information Officer

    When an employee is absent from work and access is required for legitimate business purposes (for example, work continuity) or occupational health and safety reasons (for example, where there are reasonable concerns about the individual’s health and safety)

    Chief People Officer and the relevant:

    Provost

    Dean

    Deputy Vice-Chancellor or

    Vice-President

    When a student or researcher is absent from study or research and access is required for legitimate business purposes (for example, work continuity) or occupational health and safety reasons (for example, where there are reasonable concerns about the individual’s health and safety)

    Deputy Vice-Chancellor Education and Student Experience, or where relevant the Deputy Vice-Chancellor of Research and the relevant Dean

    When an identified approver has a conflict of interest

    Any two of the following:

    Vice-Chancellor and President

    Chief Legal OfficerÌý

    a member of Council who does not have a conflict of interest


    10.5ÌýÌýÌý No access is to be provided without two signatures. An authorisation from only one person (regardless of the seniority of the person or the role that they perform) is insufficient to provide access.

    10.6ÌýÌýÌý Âé¶¹Éçmadou IT will:Ìý

    a.ÌýÌýÌýÌý provide a University-wide directory, which will include email addressesÌý

    b.ÌýÌýÌýÌý make available a mailing list system for creating email lists and to establish lists for valid purposes

    c.ÌýÌýÌýÌý monitor the performance of the existing central email system and its usage to ensure the service meets the needs of its users within the available resources

    d.ÌýÌýÌýÌý administer usage of the central service and apply temporary or permanent usage constraints or limits to the service for any user (including discontinuance or deactivation) who is in breach of this policy or any other Âé¶¹Éçmadou rules or policies, or applicable Federal or State law. Any such decision may be appealed to the Chief Information Officer

    e.ÌýÌýÌýÌý retroactively detect and remove malicious emails that have already been delivered to users.

    10.7ÌýÌýÌý Âé¶¹Éçmadou may exercise its legal right to read any digital communication sent via Âé¶¹Éçmadou information resources. The information viewed by any third party authorised to read the digital communication (i.e. other than the sender or recipient), will only be used for the sanctioned purpose.

  • 11.1ÌýÌýÌý The use and disclosure of an individual’s digital identity must comply with this policy, Âé¶¹Éçmadou’s Privacy Management Plan and Privacy Statements.

    11.2ÌýÌýÌý Forms of identity used to access Âé¶¹Éçmadou information resources should not be published together with the identity of the user. However, identities may be published within Âé¶¹Éçmadou’s internal directory.

    11.3ÌýÌýÌý The identity of students can be displayed in a teaching context, to an individual student or between an individual student and their teacher or class support. However, employees and students must not:

    a.ÌýÌýÌýÌý display a list of students’ identities to a class or other group, and/or

    b.ÌýÌýÌýÌý share a list of students’ identities to a class or other group without an approved data sharing approval.

    11.4ÌýÌýÌý Âé¶¹Éçmadou Estate Management and other Âé¶¹Éçmadou business units may provide user’s identities with access to physical buildings and to spaces within buildings. An identity for this purpose should be classified as private under the Âé¶¹Éçmadou Data Classification Standard.

    11.5ÌýÌýÌý A list of persons who have access to spaces which includes first name, last name and identity can be shared with employees who have legitimate business reasons to have access to this information. This information must not be shared via email.

  • 12.1.ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý In the event of misuse or suspected misuse of Âé¶¹Éçmadou information resources Âé¶¹Éçmadou may:

    a.ÌýÌýÌýÌý withdraw or restrict a user’s access to Âé¶¹Éçmadou information resources

    b.ÌýÌýÌýÌý commence disciplinary action

    c.ÌýÌýÌýÌý notify the Police or other relevant government authority.

  • 13.1ÌýÌýÌý The loss, theft or damage to Âé¶¹Éçmadou information resources must be reported at the earliest opportunity to Âé¶¹Éçmadou Campus Security and to the IT Service Centre in accordance with the reporting data breach requirement set out in the Data Breach Procedure.

    13.2ÌýÌýÌý Any person who notices a potential or actual cyber security incident must report it as soon as possible to the Âé¶¹Éçmadou IT Service Centre or Âé¶¹Éçmadou IT Cyber Security Team.Ìý

  • 14.1ÌýÌýÌý Any non-compliance with the use of Information Resources and digital communications platforms/technologies procedure must be approved in accordance with the Cyber Security Standard - Framework Exemption, including a mandatory risk assessment and agreed compensating controls.Ìý

  • 15.1. The Chief Information Officer

    See the responsibilities section of the Information Governance policy above for the responsibilities and authorities of the Chief Information Officer.

    15.2. Âé¶¹Éçmadou ITÌý

    Âé¶¹Éçmadou IT facilities, services and manages Âé¶¹Éçmadou information resources.Ìý

    15.3. Users of Âé¶¹Éçmadou information resources and digital communication platforms/technologies

    Users of Âé¶¹Éçmadou information resources are responsible for using Âé¶¹Éçmadou information resources in accordance with this policy.Ìý

    Ìý

    Ìý

Effective:Ìý20 May 2025Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý ÌýResponsible:ÌýVice-President, OperationsÌý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý ÌýLead:ÌýChief Information Officer


Section 6: Use of Artificial Intelligence Systems or Tools Procedure

  • 1.1ÌýÌýÌý Users are accountable for all activities originating from their use of artificial intelligence (AI) systems or tools.

    1.2ÌýÌýÌý AI systems or tools must be used ethically, lawfully and responsibly.

    1.3ÌýÌýÌý Users of AI systems or tools must ensure that confidentiality of highly sensitive, sensitive, commercial and/or personal information is maintained throughout the data management life cycle.Ìý

  • 2.1ÌýÌýÌý Before any AI system or tool (other than for using an approved, deployed enterprise grade system i.e. CoPilot) is used an AI self-assurance assessment must be conducted.

    2.2ÌýÌýÌý The AI self-assurance assessment (based on the ) comprises the following elements that must be considered before using an AI system or tool:

    a.ÌýÌýÌýÌý sensitive data - The AI system or tool does not involve the use or creation of highly sensitive, sensitive, commercial and/or personal data without consent/approval

    b.ÌýÌýÌýÌý harm - The AI system or tool is respectful of fundamental human rights, the rights of the child and/or the environment

    c.ÌýÌýÌýÌý compliance - The AI system or tool complies with Âé¶¹Éçmadou policies, relevant legislation, and the Ethical and Responsible Use of Artificial Intelligence at Âé¶¹Éçmadou principles Ìý

    d.ÌýÌýÌýÌý fairness - The outputs of the AI system or tool are equitable, inclusive, accessible and free from bias and there is a mechanism for challenging outcomes

    e.ÌýÌýÌýÌýÌýÌý business value - The AI system or tool aligns with Âé¶¹Éçmadou's core values, Strategic Plan, improves services or efficiencies and there is an approved budget for the initial and ongoing costs

    f.ÌýÌýÌýÌýÌýÌýÌý transparency and accountability - The AI system or tool provides identifiable, explainable, reliable, and interpretable outputs to the user and there is clear accountability and monitoring to ensure that the system or tool continues to function as designed.

    2.3ÌýÌýÌý Data used to train the AI system or tool must be diverse and representative of the population it serves.

    2.4ÌýÌýÌý Data must only be used and stored in an AI system or tool in accordance with its classification.

    2.5ÌýÌýÌý AI systems and tools deployed at Âé¶¹Éçmadou must be continuously monitored by users after deployment to identify any emerging biases or unfair outcomes.

  • 3.1 The Chief Information Officer

    See the responsibilities section of the Information Governance policy above for the responsibilities and authorities of the Chief Information Officer.

    Ìý3.2ÌýUsers of AI systems or tools

    Users are responsible for using AI systems or tools in accordance with this policy.

    Effective:Ìý1 February 2025Ìý Ìý Ìý Ìý Ìý Ìý Ìý ÌýÌýResponsible:ÌýVice-President, OperationsÌý Ìý Ìý Ìý Ìý Ìý Ìý ÌýLead:ÌýChief Information Officer

    Ìý

Effective:Ìý20 May 2025Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý ÌýÌýResponsible:ÌýVice-President, OperationsÌý Ìý Ìý Ìý Ìý Ìý Ìý Ìý Ìý ÌýLead:ÌýChief Information Officer


Appendix and revision history

  • Legislative compliance

    This policy is intended to ensure that Âé¶¹Éçmadou complies with the:

    1.ÌýÌýÌýÌýÌýÌý (NSW)

    2.ÌýÌýÌýÌýÌýÌý (NSW)

    3.ÌýÌýÌýÌýÌýÌý (Cth)

    4.ÌýÌýÌýÌýÌýÌý (NSW)

    5.ÌýÌýÌýÌýÌýÌý (NSW)

    6.ÌýÌýÌýÌý (NSW)Ìý

    7.ÌýÌýÌýÌý (NSW)

    8.ÌýÌýÌýÌýÌýÌý Ìý (NSW)

    9.ÌýÌýÌýÌý (NSW)Ìý

    10.Ìý (Cth)

    11.Ìý (Cth)Ìý

    12.ÌýÌý (Cth)

    13.ÌýÌý

    14.ÌýÌý (Cth).ÌýÌýÌý

    15.ÌýÌý (NSW)

    Ìý

    Supporting documents

    ÌýInformation Governance Instruction ManualÌý

      • Policy document

        Approval

        Change

        Information Governance Policy (1.0) 1 February 2025

        VC

        New policy

      • Policy document in effect

        Approval

        Change

        Information Governance Policy (1.1) 20 May 2025 See below See below

        - Principles (20 May 2025)

        N/A Administrative change

        - Section 1: Data Governance and Management Procedure (15 May 2025)

        Manager, Data and Information GovernanceÌý Minor update

        - Section 2:ÌýRecords and Information Management Procedure (19 May 2025)

        Manager, Records & Archives Minor update

        - Section 3: Privacy Procedure (16 May 2025)

        Head of Compliance & Privacy Law Minor update

        - Section 4: Data Breach Procedure (20 May 2025)

        N/A No change

        - Section 5: Use of Âé¶¹Éçmadou Information Resources and Digital Communications Platforms/Technologies Procedure (20 May 2025)

        N/A No change

        - Section 6:ÌýUse of Artificial Intelligence Systems or Tools Procedure (20 May 2025)

        N/A Administrative change
      • Policy document in effect

        Approval

        Change

        Information Governance Instruction Manual (1.0) 1 February 2025

        Policy Leads

        New instruction

Access the PDF versions:

In this policy

Responsible Officers

Scientia Professor, Vlado Perkovic, Provost

Andrew Walters, Vice-President, Operations

Clair Hodge, Chief Assurance and Legal Officer