Administrative Change and Information Continuity: Making Section 23 Work in Practice

Administrative change is a constant in the public sector.

Functions move, agencies are restructured, and new delivery models emerge.

While these shifts are often driven by policy or operational priorities, they carry a critical risk: the disruption of information continuity.

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The Hidden Risk in Administrative Change

Section 23 of the Public Records Act 2005 (PRA) provides a clear statutory obligation to manage this risk. When functions and associated records transfer between public offices, responsibility must be reassigned, information must remain properly managed, and the Chief Archivist must be notified within three months. Te Rua Mahara o te Kāwanatanga provides an overview and advice here - Managing information during administrative change – Archives New Zealand

The real challenge for leaders and information management (IM) specialists is ensuring that information remains accessible, usable, and accountable throughout, and beyond, organisational change.

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Key Insights

1. Section 23 Requires a structured and auditable approach

A structured process that is systematic and auditable can ensure that during administrative change, information remains:

• Clearly identified

• Appropriately managed

• Accessible to those who need them

• Under the responsibility of a defined public office

Establishing a defensible approach to information transfer means designing processes that can demonstrate that information has been transferred completely, accurately, and with clear accountability.

2. Responsibility Transfers, But Obligations Do Not Reduce

The transfer of responsibility from one public office to another is not simply a handover. The receiving agency inherits ongoing obligations under the PRA, including:

• Ensuring records continue to be managed appropriately

• Preventing unauthorised disposal

• Maintaining records in accordance with approved disposal authorities

Transfer does not reduce compliance risk, it relocates it. Agencies accepting transferred functions must be prepared to integrate and manage information as part of their ongoing business operations.

3. Effective Transfer Depends On More Than Moving Records

Transferring information is not limited to moving documents or datasets. It involves preserving the broader information environment that gives those records meaning.

• Some information may be exported into formats that cannot be readily accessed without specific tools or systems

• Metadata may be extracted into separate files, requiring deliberate management to maintain usability

• Without appropriate handling, records may lose context, limiting their long-term value

A technically complete transfer can still fail in practice if information not accessible or interpretable. Effective transfer must therefore consider systems, formats, and metadata alongside the information.

4. Notification Is A Milestone, Not The End Point

The requirement to notify the Chief Archivist within three months is a clear statutory milestone, but it should not be treated as the conclusion of the transfer process. 

Instead, it marks the point at which responsibility formally changes hands. Beyond this:

• Information must continue to be managed in line with statutory requirements

• Receiving agencies must ensure ongoing access and control

• Information must be integrated into existing IM frameworks and practices

This reinforces the need for continuity. Transfer is not an isolated event but part of an ongoing management of information.

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Practical Application: What This Means in Practice

For public sector leaders and IM specialists, the implications are practical and immediate.

1. Treat information as a core component of administrative change

• Include IM considerations in planning from the outset

• Recognise that information transfer is integral to successful function transfer

• Ensure alignment between organisational change timelines and information transfer activities

2. Define and document accountability clearly

• Establish who is responsible for information before, during, and after transfer

• Maintain documentation that captures what has been transferred and to whom

• Ensure there is no ambiguity about ongoing custodianship

3. Plan for system and format dependencies

• Identify systems information is held in and how they will be accessed post-transfer

• Ensure exported data remains usable and accessible

• Retain and manage metadata to support interpretation and retrieval

4. Build in assurance and traceability

• Develop processes that can demonstrate completeness and accuracy of transfer

• Retain records of transfer decisions and actions

• Ensure the organisation can evidence compliance if required

5. Prepare receiving agencies for ongoing stewardship

• Integrate transferred records into existing IM frameworks

• Apply appropriate retention and disposal rules

• Ensure controls for access, security, and use are in place from day one

These actions enable compliance it in a way that is robust, defensible, and sustainable.

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Closing: Ensuring Continuity in a Changing System

As functions move and responsibilities evolve, the continuity of information becomes a critical enabler of both operational effectiveness and public accountability.

A structured, auditable, and transparent well planned and documented approach to information transfer enables ongoing stewardship.

When done well, it ensures that information remains where it needs to be, accessible when required, and managed by those clearly responsible for it. 

Insights in this blog have been informed by the work we have done with government agencies that have undergone administrative change.  If your agency is going through administrative change get in touch to discuss your specific challenges and opportunities and how X4 can support you. 

Full transparency: We used AI to help structure this blog post and refine some wording

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