Social Media Recordkeeping Requirements in Australia

By Michael Schloman

Many government agencies overlook social media, not giving any thought to, or realising, that social media communications are State and Commonwealth Records that are required to be maintained. Other agencies we’ve spoken with assume that they are being recorded as part of their records management program, when in fact they aren’t. Considering social media has been around since 1997, it’s an area that is only just beginning to get the attention it deserves.

With 52% of Australian organisations now use social media for business communications (and these figures are only increasing), it’s essential organisations and key stakeholders understand their responsibilities for implementing and maintaining a compliant social media records management program. This can seem like an unrealistic task when you consider how dynamic digital content is, especially when it goes viral.

In this post we explore the definition of social media records within Australia, what is legally required to be kept, whose responsibility it is, the challenges of social media recordkeeping, and a brilliant social media archiving tool called Brolly.

To understand what social media records are, let’s first define social media. Social media is any technology-based environment that allows users to create, publish, collaborate on and share content. Whilst traditional media, such as radio and television, deliver content to an end-user in a one-way communication dialogue, social media allows for two-way communication, in that end users can create, modify, discuss and share content.

Each state has their own definition of a record, however the Archives Act 1983 defines a record as a document or object, in any form (including any electronic form) that is, or has been, kept by reason of:

  1. any information or matter that it contains or that can be obtained from it; or
  2. its connection with any event, person, circumstance or thing.


The National Archives of Australia states in simple terms that “all information created, sent and received as part of your work for the Australian Government is a record” and “when you use social media in the course of your business, you are generating a Commonwealth record”.

An important aspect to note, is that records can be in any format, therefore opening up recordkeeping requirements to a whole suite of non-traditional digital formats including;

  • Media sharing and streaming sites such as YouTube, Vimeo, Pinterest
  • Social networking sites including Facebook, Twitter, LinkedIn and Yammer
  • Blogs
  • Wikis and online collaboration sites
  • Forums discussion boards and groups
  • Instant messaging and messaging
  • Social bookmarking
  • Crowdsourcing
  • Geospatial tagging including Google maps
  • Videocasts and podcasts
  • Online surveys


When using third party social platforms, it is important to ensure that Australian government standards for the management of information are met. Social media records held in their native applications are generally not legally regarded as a Commonwealth record, thus posing the challenge of how to maintain compliant social media records.

Who Is Required to Maintain Social Media Records in Australia?

All government agencies in Australia as well as organisations in regulated industries with recordkeeping obligations.

Within an organisation, the act of capturing and storing the information itself depends on the organisational structure, however most government agencies have a dedicated Policy and/or Records & Information Management team, whose responsibility it is.

Do You Have to Keep Every Social Media Interaction?

This is a question many government organisations are seeking clarification on. The answer is, it’s complicated. The National Archives of Australia states that, “different information has different value and purpose. More valuable social media information, such as feedback about policy, announcements or complaints, needs to be retained appropriately. The decision is not always obvious, so a judgement must be made about the material’s relevance to your agency’s business.” Therefore, it becomes difficult and risky to decide what needs to be retained and what doesn’t.

Questions to ask yourself when assessing whether the social media post should be retained include;

  • Are you using a personal social media account for business purposes? (i.e. a member of parliament)
  • Did the social media post communicate decisions, dispense advice or commit the organisation to an action?
  • Did the post relate to sensitive or contentious activities?
  • Is it a unique record or does it exist elsewhere in a different record or format?
  • Did the post generate a lot of interest from the media and public?
  • Does it fit into my state government’s definition of a social media record?


It can be an administrative nightmare to manually and accurately capture all social media records, and leaving it to personal “judgement” as to whether or not the record is “important” can be time consuming and extremely risky for an organisation.

There are numerous challenges associated with compliant social media recordkeeping, such as;

Records Held in Their Native App Are Likely Non-Compliant

The National Archives of Australia states that “social media records held in their native applications at third party sites may not be legally regarded as a State/Commonwealth record”, so using the platform itself as a records management system is not recommended for several reasons. Data on third-party apps is typically stored outside of Australia which poses data sovereignty issues. Government agencies are also vulnerable to the destruction or loss of data/records, for which they may not be responsible, but will be accountable for. A provider could go out of business, close the site or delete information, thereby damaging the integrity of the agency and its records.

Not Capturing Everything Is Risky

Having staff make a “judgement” call on whether a social media post is “important” enough to be kept as a record is risky business and not to mention time consuming. There are so many factors to consider, that even if a detailed matrix were to be developed and followed, the accuracy of those records would be still be open to human error. To mitigate this risk, it is in the best interest of agencies to retain all of their social records, which, in the case of many larger organisations, can be in the thousands and therefore an impossible task without the aid of technology.

An Unrealistic Manual Task & Ever Evolving Records

Real-time, accurate social media archiving would be virtually impossible to do manually as post interactions can spiral in every direction, especially when content goes viral and is shared, liked, retweeted, replied to, or discussed via private or public comments. Posts are generally comprised of multiple media types including text, an image, video or hyperlink which can be edited at any time, thereby instantly changing the context of the post and the integrity of the record. When something becomes popular the content is forever changing. Without technology, it would be impossible to ensure the record is up to date and accurate. Even if you were to tackle it manually, how would you go about capturing the records in real-time – a spreadsheet with various screenshots of all media and threads attached, taken at semi-regular intervals? Ineffective when you consider how quickly viral content can spread. How easy would search/discoverability be when required?

Maintaining Records in a Way That Makes Them Easily Discoverable for FOI Requests

Under the Freedom of Information Act 1982, individuals have the right to request access to government records, which could end up being a social media record. Depending on how you are keeping record of your social media records, have you considered (or tested) how easy it is to retrieve the right records when you need them?

Social Media Platforms Are Not Designed for Records Management

Social media platforms such as Facebook, Twitter and LinkedIn are not designed for record capture and unfortunately don’t serve up the required information in a nice little screenshot that’s easy to record. The message itself, interaction, hyperlinks, edits and version history, multimedia snapshots and metadata information, such as the time and date created and by who, are spread out and typically take some manual sifting to get all of the required information. Some platforms may not even have the information required for a complete and compliant record.

Records Retention Schedules You Have No Control Over

In most third party apps, your data is subject to the terms and conditions set out by the platform. Some sites assert copyright over content posted to their platform, rather than it remaining the property of the entity that posted it. Many sites also dictate how long they retain that information for, which can be in direct opposition to state and national retention and disposal schedules and essentially impossible to place a legal hold on.

Making Sense of Varying Legislative Policies

Each state has their own respective social media policy, however obligations and standards for records management practices are also set out in the Archives Act 1983, AS ISO 15489, AS/NZS ISO 16175, AS/NZS 5478, the Australian Government Recordkeeping Metadata Standard 2.2, and in other policies such as the Victorian Electronic Records Strategy (VERS) Version 2. Making sense of the various relevant standards, principles and legal obligations can be a challenging task, which can often be alleviated by qualified advice from a records management specialist.

When organisations realise the challenges of social media recordkeeping, it often leaves government agencies hesitant to even use social media as a communications tool because it seems unmanageable and too risky. However, there are specialised records management tools for social media that can assist with compliance. With a well thought out social media records management plan, organisations can reap the benefits of social media in a compliant, risk-free manner.

At Miktysh, our team of consultants specialise in records and information management strategy. If you’d like expert advice in developing your organisation’s social media records management policy, please get in touch with our team.

Michael Schloman is a co-founder and Executive Director at Miktysh