Data stewardship

1. The one rule that governs all of it

2. Is an authority already in place?

An authority attaches to a department and a kind of record, not to a single project, so one may already be in place. Either way, the Information Management (IM) office confirms it.

• Usually, it is already covered. Common admin records (human resources, finance) sit under government-wide authorities every department already holds. The program's own records may be covered too, if the department obtained an authority for that kind of record before, or if they fall under a shared authority for operational case files. Then there is nothing to request, only to confirm.
• Sometimes, it is not. If the records are genuinely uncovered, the department requests a new authority for them, through the IM office. This is where to act early: there is no set timeline, and it can take months, sometimes years.

3. How to sort it out: when, who, and what to ask

Three things settle it.

• When. Early, in Beta, before the service launches. An authority is never refused, so this is not a pass-or-fail checkpoint; the only risk is how long a new one takes, which is why it starts early.
• Who. The Information Management (IM) office. They hold the authorities, know what covers the records, and request new ones from Library and Archives Canada through its Liaison Centre.
• What to ask them. Two questions:
  1. Is an authority already in place for these records, and if not, how is one requested and how long will it take?
  2. What can be cleaned up on an ongoing basis once the service is live, and under which authority?

4. While the service runs: keep it cleaned up

A running service should not simply pile up data until it closes. Clearing records on schedule is allowed, and it uses the same authority each time: a disposition authority is standing permission, not a one-time ticket. As each record reaches the end of its retention period (how long it must be kept), it can be destroyed under the authority that already covers it.

• Transitory records. Drafts, duplicates, and working notes with no lasting value can be destroyed at any time, under a standing government-wide authority made for them.
• Records past their retention period. Once the period ends, the existing authority is the consent to destroy them.
• Personal information. The Privacy Act requires it to be disposed of once it is no longer needed, and at the latest two years after it was last used to decide about a person.

Deciding a record is no longer needed is not the same as being allowed to delete it.

Three parties share the work, in order:

1. 1

   The records' owner approves that a set of records is no longer needed.

2. 2

   The IM office confirms an authority covers it, checks for legal holds or open access-to-information requests, destroys it securely, and records what was done.

3. 3

   The supplier carries out the technical deletion, where the contract requires it.

For a small team running a bought product, the disposal does not happen on its own; it happens only where the contract requires it. So these duties belong in the contract from the start: dispose on schedule, return the data, destroy copies securely, and show it was done. They form the data schedule of a good contract, set when the service is bought.

Why clear records as you go? Three reasons.

• A smaller, safer Sunset.

  Less data at the end means less to migrate, less to dispose of, and less to work out whether an authority exists.

• Privacy compliance.

  Holding personal information past its retention period is a Privacy Act problem in its own right.

• A smaller target.

  Data kept is data to protect. (Storage cost can matter too, but only where the contract charges by usage; under a fixed fee the saving is mostly risk.)

5. When the service is replaced or retired

Retiring or replacing a service runs through its own steps: assess, decide, plan, then move. The data work splits across them.

• The decision comes at the planning step, near the start. For each set of records, choose whether it is migrated to the new system, transferred to Library and Archives Canada, or destroyed under an existing authority. The migration plan depends on this, because the plan cannot be made without knowing what may be destroyed and what must be kept.
• The move comes later, as the old service winds down, finishing only once the new service is live.

• Run the data migration as its own project, ahead of decommission. Departmental decommissioning guides start the migration separately and hold the shutdown until it has finished.
• Decide early. Data kept past need costs storage and effort, so the sooner what leaves is decided, the less is carried into the move.

Records that are kept are cleaned first, because fixing quality before a migration costs less than after, and moved with their meaning intact. Records that are destroyed are destroyed securely. Nothing is destroyed without the authority that covers it.

6. Who you talk to

• Information Management (IM) office — holds the authorities, knows what covers the records, requests new ones, tracks the schedule, and does and documents the disposal. First call.
• ATIP / privacy office — for the Privacy Act duty to dispose of personal information on time.
• Library and Archives Canada, through its Liaison Centre — where the department requests a new authority, reached through the IM office.