Legal Insights

Two new recordkeeping requirements - contact tracing and alcohol / drug testing

By Melanie Olynyk

• 30 July 2020 • 2 min read
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The Public Records Office Victoria (PROV) has issued Variation 6 of PROS 07/01 Retention and Disposal Authority for Records of the Common Administrative Functions (PROS 07/01), to include the following two changes:

  1. The provision of disposal coverage for attendance records to support contact tracing.

    To elaborate, the Department of Health and Human Services (DHHS) requires organisations to create attendance records (i.e. name and phone number of people (staff and visitors) at a premises) to support contact tracing (if required). PROS 07/01 authorises disposal of these records in accordance with the directions issued by the public health authority (DHHS currently). A new activity ‘Public Health Compliance’ and record class has been added under function ‘Occupational Health & Safety’ (see class 11.13.1).

  2. New coverage for records of alcohol and drug testing of employees.

    This has been added under function ‘Personnel Management: Employment Conditions’ (see class 12.5.8). It means that all records documenting drug and alcohol testing of agency employees (including records of consent and the results) may be destroyed 7 years after the action has been completed.

Retention and Disposal Authority (RDA) PROS 07/01 applies to all Victorian public offices. Variation 6 was developed with advice provided by DHHS. PROV has also commenced a project to completely replace PROS 07/01 with a new Common Administrative Functions RDA. This project has been ‘paused’ for now, however, agencies are still invited to submit feedback to PROV on the existing RDA PROS 07/01 (PROV’s project page provides further information).

For further information about Variation 6 of PROS 07/01 please see PROV's blog post.

If you require any advice or assistance to understand your record keeping obligations during this challenging time, please don’t hesitate to get in touch. Maddocks is operating business as usual and we continue to be available by telephone and email and can even hold virtual ‘face-to-face’ meetings via a number of platforms such as Microsoft Teams or Skype.

Please get in touch with the FOI & Privacy Team for more information.

By Melanie Olynyk

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