(APROSS). This Guideline - Public Record Office Victoria

Public Record Office Victoria 

PROS 11/01 

Storage 

Guideline 

1 

Approved Public Record Office Storage 

Suppliers (APROSS) 

Version Number: 1.1 

Issue Date: 27/07/2011 

Expiry Date: 27/07/2016 

© State of Victoria 2011 Version 1.1

PROS 11/01: Guideline 1: Approved Public Record Office Storage Suppliers 

Table of Contents 

1. Introduction ..................................................................................................................... 4 

1.1. Public Record Office Victoria Standards.................................................................. 4 

1.2. Purpose.................................................................................................................... 4 

1.3. Scope....................................................................................................................... 4 

1.4. Definitions ................................................................................................................ 5 

1.5. Related Documents.................................................................................................. 5 

2. What is APROSS? ........................................................................................................... 6 

3. Choosing an APROSS .................................................................................................... 7 

4. Transferring Records to an APROSS ............................................................................ 8 

5. Retrieving Records from an APROSS ........................................................................... 9 

6. Becoming an APROSS Certified Facility..................................................................... 10 

7. Maintaining APROSS Certification .............................................................................. 11 

8. References ..................................................................................................................... 12 

Appendix One: Legislation Concerning APROSS............................................................. 13 

Appendix Two: Transfer to APROSS Process Diagrams ................................................. 15 

Appendix Three: APROSS Facility Process Diagrams ..................................................... 16 

© State of Victoria 2011 Version 1.1 Page 2 of 17


Copyright Statement 

© State of Victoria 2011 

This work is copyright. Apart from any use as permitted under the Copyright Act 1968, no 

part may be reproduced through any process without prior written permission from the 

publisher. Enquiries should be directed to Public Record Office Victoria, PO Box 2100, North 

Melbourne, Victoria 3051 or email: agency.queries@prov.vic.gov.au. 

Disclaimer 

The State of Victoria gives no warranty that the information in this version is correct or 

complete, error free or contains no omissions. The State of Victoria shall not be liable for any 

loss howsoever caused whether due to negligence or otherwise arising from the use of this 

Guideline. This Guideline does not constitute, and should not be read as, a competent legal 

opinion. Agencies are advised to seek independent legal advice if appropriate. 

Acknowledgements 

The Public Record Office Victoria would like to acknowledge the valuable contribution of 

members of the Storage Advisory Group during the development of this Guideline. 

Version Version Date Details 

1.0 27/07/2011 Released 

1.1 21/09/2011 APROSS Forms added to text. 



1. Introduction 

1.1. Public Record Office Victoria Standards 

Under section 12 of the Public Records Act 1973, the Keeper of Public Records (‘the 

Keeper’) is responsible for the establishment of Standards for the efficient management of 

public records and for assisting Victorian government agencies to apply those Standards to 

records under their control. 

Recordkeeping Standards issued by the Public Record Office Victoria (PROV) reflect best 

practice methodology. This includes international standards issued by the International 

Organisation for Standardisation (ISO) and Australian Standards (AS) issued by Standards 

Australia, in addition to PROV research into current and future trends. 

Heads of government agencies are responsible under section 13b of the Public Records Act 

1973, for carrying out with the advice and assistance of the Keeper, a program of efficient 

management of public records that is in accordance with all Standards issued by the Keeper. 

In Victoria, a programme of records management is identified as consisting of the following 

components: 

• A recordkeeping framework; 

• Recordkeeping procedures, processes and practices; 

• Records management systems and structures; 

• People and organisational structures; and 

• Resources, including sufficient budget and facilities. 

A programme of records management needs to cover all agency records in all formats, 

media and systems, including business systems. 

1.2. Purpose 

The purpose of this Guideline is to provide useful and practical guidance on the storage of 

public records with a commercial storage provider, while adhering to best practice 

recordkeeping principles identified in the Storage Standard. This Guideline will assist 

government agencies to implement the requirements in the Agency Custody Storage 

Specification in situations where they have outsourced the storage of public records in their 

custody to an Approved Public Record Office Storage Supplier (APROSS). This Guideline 

will also be a useful reference for APROSS companies to understand the compliance 

requirements of their Victorian government clients. 

1.3. Scope 

This Guideline applies to government agencies that either store or intend to store records in 

an APROSS facility. It applies to the storage of both digital and hard copy records with 

commercial storage suppliers. For guidance regarding Places of Deposit (POD) please refer 

to Storage Guideline 4: Places of Deposit. 



1.4. Definitions 

This Guideline uses terms located in the Storage Standard. For a full list of records 

management and PROV terminology, see the Master Glossary. 

1.5. Related Documents 

This Guideline must be read and implemented in conjunction with PROV’s Standards and 

associated documentation, including appropriate Retention and Disposal Authorities (RDA). 

The Standard, Specifications and other Guidelines associated with this Guideline are 

detailed below: 

Figure 1: Relationship Diagram 



2. What is APROSS? 

An APROSS is a commercial storage facility which has been appointed by the Keeper of 

Public Records under s. 12 of the Public Records Act 1973, following an inspection regarding 

its suitability for the storage of public records. Records held in an APROSS are deemed to be 

under the custody of the controlling agency. Mandatory conditions govern the control of 

records to be transferred to, or stored at, the site of the approved commercial facility. 

The APROSS programme was established by PROV in the 1990s in response to the issue of 

government agencies having insufficient space within their own offices to store public 

records. A system of certifying external storage providers was developed, which includes 

inspections to ensure that records were being stored in satisfactory locations and conditions. 

Approved Public Record Office Storage Supplier companies provide record storage services 

to agencies that do not wish to run their own extensive in-house records storage and retrieval 

programme. PROV has inspected each of the existing commercial storage facilities approved 

under the APROSS programme and found them to comply with the requirements outlined in 

the Agency Custody Storage Specification. The APROSS programme gives agencies the 

opportunity to negotiate retrieval and storage costs in a competitive environment with 

approved commercial facilities. 

Approved Public Record Office Storage Supplier companies and government agencies are 

bound under various acts including the Public Records Act 1973, the Information Privacy Act 

2000, Health Privacy Act 2001 and the Freedom of Information Act 1982. Government 

agencies are obliged to follow these acts regardless of whether their records are stored in an 

APROSS or not. For further details regarding this legislation refer to Appendix One. 



3. Choosing an APROSS 

Current certified APROSS facilities are listed on the PROV website. When selecting an 

APROSS the agency should assess and compare service levels and fee structures. 

Permanent retrieval fees in particular should be identified as they may impact the cost of 

implementing the agency’s disposal programme. 

When choosing an APROSS, consider asking the following questions: 

• Where is the storage facility located? 

• How much notice do you require to retrieve records? 

• Are you certified to store the type of records we need to store (not all APROSS facilities 

are certified to store all formats of public records)? 

• Do you provide couriers or will the agency need to arrange them? 

• What are your fees? 

• Are records able to be processed onsite (such as when the agency needs to run 

disposal programmes), and is there a cost involved? 

• Do you provide a secure record destruction service? 

• Are we able to retrieve records via an online ordering service? 

The agency should ensure that all required purchasing processes are followed. The agency 

should obtain legal advice before signing the contract. The contract should specify at a 

minimum: 

• Any special requirements for the records; 

• Access arrangements; 

• Security arrangements; 

• Exit fees (including permanent retrieval); and 

• Ongoing management and setup costs. 

The agency should also confirm with their insurance provider that all records are still covered 

whilst stored in APROSS facilities. 



4. Transferring Records to an APROSS 

Once an agency has chosen the appropriate APROSS and has a contract in place, records 

can start to be transferred 1 . There may be a number of triggers for transferring records to an 

APROSS. These may include: 

• Inadequate space in onsite storage areas; 

• Onsite storage areas do not meet PROV Standards; 

• Long record retention periods; 

• Infrequent use of records; 

• Restricting physical access to agency staff; or 

• Lower cost of storage. 

Identification and control 

Before transferring any records to an APROSS they should be appropriately identified and 

controlled. Requirements 31 to 33 in the Agency Custody Storage Specification must be 

implemented by the agency prior to transfer. This includes having systems in place to track 

the physical location of records and the intellectual control to enable records to be easily 

retrieved from storage containers. This means that the agency needs to document which 

records are being stored in each box and record where each box is currently located. Each 

transfer should be documented by the agency (in conjunction with the APROSS) through a 

form which can be signed off upon receipt of the records. The agency is still responsible for 

the records once they have been transferred and will need to know what records were 

transferred to which location at what date. Further guidance is located in the Implementing a 

Storage Programme Guideline. 

Unsentenced records 

Unsentenced records may only be sent to an APROSS if a plan to sentence the records has 

been approved by the Keeper of Public Records. PROV form PRO 41 Request for Approval 

of Sentencing Plan should be completed by the agency and submitted to PROV for approval. 

The records must only be transferred to the APROSS once approval has been granted. 

State Archives 

State Archives (i.e. records identified in a current disposal authority as being permanent) 

may only be sent to an APROSS if a plan to transfer the records to PROV has been 

approved by the Keeper of Public Records. PROV form PRO 42 Request for Approval of 

Transfer Plan should be completed by the agency and submitted to PROV for approval. The 

records must only be transferred to the APROSS once approval has been granted. 

Security 

Digital and hardcopy records need to be appropriately secured when in transit to the 

APROSS facility. Extra care should be taken when dealing with records containing sensitive 

or personal information. The agency should also ensure that any special security 

requirements for security classified material are met. 

1 Process diagrams covering transfer to an APROSS facility are located at Appendix Two. 



5. Retrieving Records from an APROSS 

After records have been transferred to an APROSS they will need to be retrieved to meet 

client, staff and legal access requirements. In the case of permanent records, they will need 

to be retrieved once administrative use has concluded so they can be transferred to PROV. 

Control 

Clear procedures should be developed as part of the agency’s storage programme, which 

details how records are to be retrieved from an APROSS and promptly returned to storage 

once access requirements have been met. These procedures should cover: 

• Identifying the current location of records; 

• Submitting retrieval requests to the APROSS; 

• Handling urgent retrieval requests; 

• Deadlines and retrieval turn around times; 

• Checking and documenting receipt of retrieved records; 

• Updating the current location of records; 

• Maintaining the security of records; and 

• Following up on the return of records to storage. 

State Archives records 

Records identified as being permanent in a current disposal authority will need to be 

retrieved once administrative use has concluded so they can be transferred to PROV as 

State Archives. The transfer of these records to PROV is a requirement of the Disposal 

Standard. When retrieving these records it is important that the APROSS is advised that the 

retrieval is permanent and the records will not be returning to the APROSS for storage. This 

will ensure that the agency doesn’t continue to be charged for the storage of these records. 



6. Becoming an APROSS Certified Facility 

Facilities are certified as an APROSS following the receipt of paperwork and inspection by an 

authorised PROV representative 2 . Once certified as an APROSS, the facility retains that 

certification for fifteen years, unless it is revoked by PROV. 

To begin the certification process, commercial storage companies must first complete PROV 

form PRO 37 APROSS Registration of Interest and submit it to PROV. It is recommended 

that the company examine the Agency Custody Storage Specification, to understand the 

requirements that will be assessed by PROV. 

Once the form has been received, PROV staff will contact the company to organise a time to 

inspect and assess the facility. Inspections take a couple of hours and involve the PROV 

representative using the Agency Custody Storage Specification to assess the facility and any 

documentation as required. Form PRO 39 APROSS Certification Checklist identifies the 

documentation to be provided at the time of inspection. If any compliance requirements are 

not met, the PROV representative will write a report detailing what requirements were not 

met, and what action can be taken by the facility to ensure compliance with these 

requirements. 

The company then has the opportunity to rectify any issues identified in the report written by 

the PROV representative. Once these actions have been completed, the company should 

contact PROV to organise another inspection. 

When the facility passes the inspection, PROV staff will write a recommendation to the 

Keeper of Public Records that facility be appointed as an APROSS. When this is approved, 

the facility is recognised as an APROSS and the facilities are deemed to be appropriate for 

the storage of public records. The contact details and location of the new APROSS will then 

be published on the PROV website. 

2 See Appendix Three for a process diagram covering APROSS Certification. 



7. Maintaining APROSS Certification 

As a condition of continued certification, PROV will arrange to have a representative visit 

each APROSS regularly to ensure that it still complies with the requirements set out in the 

Agency Custody Storage Specification. If facilities are found to be of unsatisfactory condition, 

PROV will issue a notice to the APROSS detailing what needs to be rectified in order to 

continue as a certified APROSS. It should be noted that APROSS certification is site-specific 

and if a company is to change premises, it must reapply to PROV for certification. When 

there is a change of ownership of an APROSS facility, the new owner should notify PROV 

who will then determine if a further inspection is necessary in order to transfer the 

certification. 

Reporting to government agencies 

Public records stored in an APROSS are considered to be under the custody of the 

government agency that they belong to. While there is no obligation to report to PROV any 

transfers of records between the agency and APROSS, the agency should ensure that they 

maintain full and up-to-date lists of record transfers between themselves and the APROSS 

for PROV to inspect if required. 

Approved Public Record Office Storage Suppliers reporting requirements may be built into 

the contract between the APROSS and the government agency. At a minimum, the APROSS 

is required to inform the agency when there are any incidents affecting the integrity of their 

records. This includes: 

• Disasters leading to the damage or destruction of public records; 

• Inability to locate public records when requested; and 

• Any incident affecting security and access to the public records. 

Approved Public Record Office Storage Suppliers must also make available to the agency 

copies of their disaster management plan, emergency response plan, procedures for the 

retrieval and returning of records, and procedures for reporting missing records. 

Reporting to PROV 

The head of the APROSS is required to attest that their certified facilities are compliant with 

the Agency Custody Storage Specification on an annual basis. The Keeper of Public 

Records will write to the head of each APROSS with a request to complete PRO 44 

APROSS Annual Attestation form by the end of the financial year. Failure to complete and 

return the documentation may result in the APROSS certification being revoked. 

PROV must also be informed immediately if there are any incidents, such as a disaster, 

which may affect the status of the facility as an APROSS. This includes: 

• Major structural damage to the facility; 

• A major issue with the facility’s ability to locate and retrieve records; and 

• The ability of the facility to ensure appropriate security and access to public records. 

PROV also requires that a report of public records stored in the APROSS be provided if 

requested by the Keeper of Public Records. This report should provide details of which 

government agencies store records in the facility, and how many shelf meters of records 

each government agency has in the APROSS. 



8. References 

Legislation 

Freedom of Information Act 1982 (Vic) 

Health Records Privacy Act 2001 (Vic) 

Information Privacy Act 2000 (Vic) 

Public Records Act 1973 (Vic). 

All Victorian legislation is available at http://www.legislation.vic.gov.au. 

Other Resources 

For more information about APROSS, please contact: 

Public Record Office Victoria 

Ph: (03) 9348 5600 

Fax: (03) 9348 5656 

Email: agency.queries@prov.vic.gov.au 

Web: www.prov.vic.gov.au 



Appendix One: Legislation Concerning APROSS 

The storage of public records is an area with several legal requirements, as outlined below. 

The agency is ultimately responsible for ensuring compliance with legal requirements, 

regardless of where records are stored. 

Public Records Act 1973 

The Public Records Act 1973 gives PROV the right to nominate approved offsite storage 

providers for the storage of public records. This role is in the context of PROV’s general 

regulatory role in setting and maintaining Standards for public recordkeeping in Victoria. 

APROSS are appointed by the Keeper of Public Records under section 12 of the Act. 

12. Standards for Management of Public Records 

The Keeper of Public Records shall establish standards for the efficient management of 

public records and in particular with respect to – 

(a) the creation, maintenance and security of public records; 

(b) the selection of public records worthy of preservation; 

(c) the transfer of public records to the Public Record Office; and 

(d) the segregation and disposal of public records not worthy of preservation – 

and shall assist public officers in applying these standards to records under their control. 

13. Duties of officer in charge of a public office 

(b) shall be responsible, with the advice and assistance of the Keeper of Public 

Records, for the carrying out within the office of a programme of records 

management in accordance with the standards established under section 12 by the 

Keeper of Public Records; 

13A. Inspection of public office or other place 

The Keeper of Public Records may enter, at any time, a public office or any place in 

which the public records of that office are stored to inspect the storage and conservation 

arrangements of the records in the office or place and the carrying out in that office or 

storage place of the programme of records management referred to in section 13(b) 

19. Offence to remove etc. public records without authority 

A person who unlawfully removes sells damages or destroys a public record shall be 

guilty of an offence. 

Penalty: 5 penalty units. 

Destruction or disposal of public records by a public officer in accordance with standards 

established under section 12 is lawful. 



Information Privacy Act 2000 and Health Records Act 2001 

Both the Information Privacy Act 2000 and the Health Records Act 2001 impose significant 

requirements on the agency to respect and actively protect the privacy of information about 

individuals held by them. It is the agency’s responsibility to ensure compliance with these 

Acts, and to assign appropriate security and access levels to records stored in an APROSS. 

An APROSS should be aware of the following information privacy principle (IPP) and inform 

the agency if it has been breached: 

IPP 4 Data security: Take reasonable steps to protect personal information from misuse, 

loss, unauthorised access, modification or disclosure. 

A similar provision exists in the Health Records Act, with the added requirement that if 

records are transferred to a third party a record must be kept of this transfer (HPP 4.4). While 

this primarily relates to organisations transferring medical information to different or 

successor health providers, it can also apply to the offsite storage of records. 

The agency remains responsible for protecting the privacy of personal information collected 

by them, even when it is stored offsite. This responsibility extends to protecting privacy and 

security during the physical or electronic transfer of records. When choosing an APROSS 

and a mechanism for delivering records to and from the facility the agency should consider 

the: 

• Physical security of the premises (as a safeguard against third parties gaining unlawful 

access to information); 

• Procedures in place for access to information by the agency itself; 

• Procedures used by APROSS staff in managing the facility and the records contained 

therein; and 

• Security involved in any transfer of records to or from the APROSS. 

The agency may choose to make matters of privacy protection a part of their contractual 

relationship with an APROSS; this can help to distribute the legal burden. Records in the 

custody of an agency, including those stored offsite at an APROSS facility, still carry privacy 

obligations for government. These need to be carefully considered in any APROSS 

arrangement. 

Freedom of Information Act 1982 

The Freedom of Information Act 1982 contains key provisions governing aspects of 

government recordkeeping, disclosure and public accountability. It creates a general right of 

access to public records created and maintained by the agency. The right of access can only 

be removed or varied for specific reasons (such as "essential public interests" and "private 

and business affairs of persons"). The rights created under this Act impose a requirement on 

the agency to be able to satisfy requests for information, records and documents that are 

sought by members of the public, unless they are being withheld on one of the grounds in the 

Act. APROSS facilities should be aware that the public records they store may still be the 

subject of a Freedom of Information (FOI) request. The APROSS must be able to locate and 

retrieve records when requested by the agency. 



Appendix Two: Transfer to APROSS Process Diagrams 

Transfer of unsentenced records to an APROSS facility 

Unsentenced records 

transfer to APROSS 

request 

PRO 41 

Request and 

sentencing plan 

reviewed 

Records 

received at 

APROSS 

Records transferred to 

APROSS 

Y 

Request 

approved 

Figure 4: Transfer of unsentenced records to an APROSS facility process diagram 

This process is triggered by an agency request to transfer unsentenced records in its custody 

to an APROSS facility. A Sentencing Plan (form PRO 41) must be approved by PROV before 

such a transfer can be conducted. 

Transfer of State Archives to an APROSS facility 

Figure 5: Transfer of State Archives to an APROSS facility process diagram 

This process is triggered by an agency request to transfer records identified in a current 

disposal authority as being permanent (i.e. State Archives) in its custody to an APROSS 

facility. A Transfer Plan (form PRO 42) must be approved by PROV before such a transfer 

can be conducted. 



Appendix Three: APROSS Facility Process Diagrams 

Certification of an APROSS 

Figure 2: APROSS Certification Process Diagram 

This process is triggered by a commercial storage facility completing Registration of Interest 

form PRO 37 and sending it to PROV. Copies of the documents required for PROV to 

conduct a document review using the APROSS Certification Checklist form PRO 39 will also 

need to be forwarded to PROV. 



On successful completion a numbered certificate is sent to the new APROSS, the PROV 

website will be updated, and details of the assessment and inspection will be recorded at 

PROV. 

APROSS annual attestation process 

Figure 3: APROSS annual attestation process diagram 

This process is triggered by the approaching end of a financial year and finalised with an 

update to PROV’s website with the status of an APROSS facility’s Attestation. Failure to 

provide a properly completed Attestation (PRO 44) form may trigger a review of an APROSS 

facility’s certification.

(APROSS). This Guideline - Public Record Office Victoria

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