Policy development and review cycle

The policy development and review cycle is based on the universally accepted quality cycle that involves the plan-do-check-act approach. It is structured to capture all policy actions in a continuous cycle of improvement to ensure that policies remain current and relevant, and that they continue to address the issues that they were initially implemented to address.

1. Initiate; 2. Develop; 3. Consult; 4. Approve; 5. Implement and monitor; 6. Evaluate and review; 7. Rescind
Image: Policy development and review cycle

The policy development and review cycle divides the policy process into the following stages.

A policy goes through stages 1 and 7 once and through stages 2 to 6 at least every three years.

During a review cycle, stages 2 and 3 may be repeated on a number of occasions until the policy owner is satisfied that all relevant policy issues have been resolved.

Main activities in this stage

  • Consider if policy is the best way to mitigate a risk or address an issue
  • If so, identify whether a new policy is required or a related policy may be amended
  • Seek approval from your Executive Director using the policy initiation approval form
  • Prepare a plan for the policy development project.

The department is committed to reducing red tape, including reducing the number of policy documents and eliminating cumulative and overlapping compliance burdens for schools.

Instead of starting with the idea that a policy is needed, the department requires a policy owner to explore the many other solutions available to address the issue or mitigate a risk.

If policy is deemed to be the best option, the policy owner should do the following.

Examine existing policies

Before a new policy is developed, the department requires the policy owner to determine if the issue or risk can be addressed by amending an existing policy rather than creating a new one. This will reduce overcrowding of policies, provide clarity for users and reduce red tape in the department.

It also may be possible to address an issue or risk effectively by making small changes to an existing workflow or system.

Amending or reviewing a current policy to address an issue or risk requires collaboration with and the approval of the policy owners. The Policy Coordination and Review team can help.

Get approval to initiate a new policy

The relevant Executive Director must approve the development of a new policy, using the policy initiation approval form.

Once approved by the Executive Director, the proposed policy solution should also be tabled at the Schools Policy Governance Group for discussion. This creates a mechanism to inform all areas of the department about current plans for policy development and consider whether emerging policy issues are already addressed in existing policy documents.

The completed policy initiation approval form must be kept in the relevant HP Records Manager (previously known as TRIM) policy file for this project.

Prepare a plan for the policy development project

It may be useful to have a policy development group to determine roles and responsibilities and manage the simultaneous activities undertaken for policy development or major review.

You may use the policy project plan template to record details that can be used to manage the delivery of the project, or can be referred to when briefing senior staff on the progress of the project.

Main activities in this stage

  • Create a HP Records Management record for the policy development activity
  • Consider issues, risks and other requirements
  • Construct an evidence base from current research and reliable data sources
  • Develop or amend policy documents using the prescribed format and standards.

Create a HP Records Management (HPRM) record for the policy development activity

Records relating to policy development and review must be made and kept in accordance with the State Records Act 1998 and the department’s Records Management Program. Policy owners should be mindful that the department may be required to provide records relating to policy development by a statutory agency at any time.

To assist policy owners meet this obligation, a file on HPRM (previously TRIM) will need to be created at the beginning of the policy development and review process. Contact the Policy Coordination and Review team if you do not know the HPRM file number for your policy or if HPRM access needs to be arranged for policy officers in your business area.

At this stage, the team may also create a collaboration space (e.g. SharePoint site) which will facilitate the joint production of content, collection and collation of stakeholder comments, and communication with the project team.

Clarify the issues and risks

In developing a policy, a clear understanding of the issues or risks to be managed is needed.

A cross section of stakeholders may be gathered together to identify key issues relating to the policy. Policy owners should record all issues identified in an issues register, along with the actions that need to be taken to address the issue.

Research

The department requires all policies to be informed by evidence. Evidence is gathered from research and the analysis of relevant material. Evidence is used to support proposed options for solutions to the policy problem and issues. This facilitates impartial decision making and evidence-informed policy content and processes.

Research helps to place the issue or risk in context. Consider current practice in other jurisdictions, any available data or relevant research findings, existing policies developed by other agencies, any current or proposed legislation or agreements in place, or any financial or budgetary constraints.

Within School Policy and Information Management, the Research team can provide advice and support and the Data and Analysis team can assist with data analysis. Contact the Policy Coordination and Review team if assistance with research or data analysis is required.

Develop or amend policy documents

Drafting policy documents should be done collaboratively. If a policy document is drafted by an individual, peer review should be completed regularly to ensure that policy decisions are not made in isolation.

In drafting documents, consider the purpose your policy and your audience. Use plain English and appropriate visual aids to help user understanding. Referring to these online resources will help.

Policies must be written according to the department's mandated policy structure. Wherever necessary, the policy statement should refer to any supporting documents that should be read to better understand the issues and requirements.

Implementation documents do not have a set structure but it must adhere to the department's guidelines and standards. The document should be designed to optimise the way information is presented to meet the objectives of the policy and audience needs. The information should be organised into categories of related material, then ordered by importance.

Owners of policies that affect the work of schools are also required to advise to schools on sample evidence that could be provided for the A-Z policy implementation tool.

Use the templates for the policy statement, the implementation document and the evidence of policy implementation guidelines for the A-Z tool. These templates have been designed to meet the department's accessibility requirements.

There are generally three stages in drafting policy documents: initial drafting; redrafting and final drafting. These stages are flexible and may be omitted or repeated, depending on the policy under development.

  • Initial drafting commences following review of an existing policy or proposal of a new policy. Initial drafting may follow or occur concurrently with information gathering, research and analysis. The initial draft is reviewed by relevant managers prior to the initiation of consultation with internal stakeholders.
  • Redrafting occurs following consultation. This stage involves the consolidation, consideration and incorporation of stakeholder feedback. In addition, further research of issues identified by stakeholders is usually required. The redraft is reviewed by relevant managers, and if needed by Legal Services, prior to further consultation with internal and external stakeholders. A number of redrafts may be needed.
  • Final drafting involves the consolidation, consideration and incorporation of all stakeholder feedback. The final draft is reviewed by relevant managers prior to being submitted for approval.

Consider the department's obligations under information classification and labelling, copyright and content accessibility.

If further assistance is required, contact the Policy Coordination and Review team.

Main activities in this stage

  • Identify the stakeholders to be consulted
  • Consider consultation method to be used
  • Negotiate policy issues
  • Keep accurate and comprehensive consultation records

Development of new policy and major policy reviews require consultation to make informed policy decisions and promote transparency in policy development. Minor review and 'quick-fixes' may not require consultation.

Stakeholders should understand the purpose of the consultation and the expectations of their capacity and influence in the process. Material communicated to stakeholders should be comprehensive, accurate and distributed in a timely manner. Realistic deadlines for feedback should be set, considering the timeline for the policy review and stakeholder commitments. If possible, stakeholders should be approached about the most useful consultation method to effectively engage them.

Consultation should be structured to encourage high quality debates on policy issues in order to develop transparent and acceptable policies. Discussions should include policy issues and various proposed solutions, arguments for and against, and any comments the stakeholders would like to make.

An Executive Director should also review and endorse a draft of the policy, before consulting with external stakeholders. In some cases, it may be necessary to obtain the endorsement of Legal Services before consulting externally.

Identify the stakeholders to be consulted

The types of stakeholders groups consulted depend on the subject matter of the policy.  For example, if the policy relates to homework, then the priority groups for consultation will include teachers, principals and parents. However if the policy relates to business continuity planning, a greater and more diverse range of staff across the department should be consulted which may include representatives from corporate areas and representatives from schools.

Policy owners should consult a range of stakeholders including:

  • key users of the policy (eg primary teachers, secondary teachers, head teachers, principals, support staff and the community)
  • groups affected by the policy position taken
  • subject matter experts in various issues referred to in the policy
  • owners of any procedures, guidelines or related documents
  • owners of related policies.

External stakeholders who may need to be consulted include other government agencies, relevant associations and unions, parents, education or community groups.

Legal Services should be consulted when developing a new policy or undertaking a major review. .

You may want to use the consultation plan template to record the stakeholders to be consulted and the type of engagement you require from each.

Consider consultation method to be used

Consultation and development are part of an iterative process in which one step informs the other. Consultation on a number of occasions and with a variety of people through a range of different forums resulting in making numerous changes to the draft document in the process may be needed.

Meetings are the most common consultation method. Stakeholders can be provided with draft policy documents to review before a consultation meeting. A large consultation meeting may be held with many stakeholders to allow for discussion of policy issues among a diverse audience. Alternatively, several smaller consultation meetings may be held with various groups of stakeholders to provide an environment for opinions to be expressed more easily or to address subject matter particular to the groups. Detailed notes should be taken to capture feedback.

The following are some alternative consultation methods.

  • Surveys can sample a broad audience such as teachers, parents, or community groups. Surveys may be conducted electronically, via email or online survey applications.
  • Digital consultation tools, such as SharePoint, allow for engagement in a collaborative and creative space for policy solutions.
  • The policy website or intranet can be used to notify the entire department, an area of the department (eg schools), or the general public, that a policy is under review.
  • Informal consultation can be undertaken via telephone or email, and notes should be kept of these conversations and filed on HP Records Manager in the relevant policy file.
  • Reference groups can bring stakeholders together to more closely define policy problems and develop solutions, as well as eliciting consensus and support for proposed actions. These groups can be used to gather more comprehensive details and information from content specialists on policy issues.
Negotiate policy issues

Policy review and development often involves stakeholders with diverse needs and views about policy issues. Some stakeholders may own supporting policy documents that are directly impacted by the policy under review.

Preparation is essential when negotiating policy issues:

  • identify the policy issues that require negotiation
  • identify relevant stakeholders and their policy positions on the issue
  • identify the right level of departmental officer required to negotiate an issue (for example some issues may need to be resolved by a Deputy Secretary or Executive Director, especially if the issues involves an external agency)
  • analyse stakeholder policy positions
  • formulate a variety of options for resolution, identifying positive and negative aspects of all options and ranking them.

Negotiations involve proposing and exploring various options, and evaluating and selecting options to determine an agreed course of action.

Keep accurate and comprehensive consultation records

You may want to use the templates for gathering and collating stakeholder feedback and for recording actions following consultation.

Records of consultation are included in submissions to approve policy documents. These must also be kept on the HP Records Management (TRIM) for the prescribed retention period.

Main activities in this stage

  • Approval of the policy documents by a senior officer at the required level
  • Maintaining records of policy documents and records related to policy development on HP Records Manager (TRIM).

Schools policy documents must have approval to be uploaded to or removed from the Policy Library.

The level of approval required for new and existing policy is detailed below.

Activity Example Approver (minimum level)
1. ‘Quick-fixes’ Alignment updates e.g. update roles titles, contact information, hyperlinks Policy owner or delegate
2. Minor policy review

Amalgamation of existing documents

Policy owner
3. Major policy review

Change of purpose or intent

Deputy Secretary
4. Initiate a new policy An emergent need to provide staff with instructions which cannot be done using an existing policy instrument Executive Director (using this form)
5. Finalise a new policy The policy has been developed following consultation and is ready for approval and publication Deputy Secretary
6. Rescind a policy Rescission of existing policy that has become redundant or irrelevant. Deputy Secretary

Approval to finalise a new policy or rescind a policy (points 5 and 6 above) must be sought using a standard briefing template that provides appropriate key information making clear the position that is being recommended.

Approvals must be stored in the allocated program folder for the policy on the HP Records Manager (BOX031625).

Main activities in this stage

  • Prepare and implement a policy implementation plan
  • Publish the policy documents on the Policy Library
  • Support policy users to comply with the policy
  • Ensure policy development records are stored on HPRM

Prepare a policy implementation plan

Policy development or review projects should include an implementation plan that specifies actions to ensure the new or revised policy is communicated to staff and embedded as current practice.

The implementation plan should consider who needs to be informed of the policy, how will they be informed, and if there are implications for specific schools or areas in the department. It would also consider the profile of the policy and how it might link to significant departmental reform agendas, government priorities or commitments. These considerations will impact on how the policy changes are communicated to staff.

SchoolBiz is one means of communicating new or updated policies to schools. Proposed SchoolBiz articles must be approved by a Director or above and an online submission form must be completed. This form, the how to guide and further information is available on the SchoolBiz intranet page.

A Deputy Secretary may also circulate information about a new or updated policy directly to employees through other mechanisms.

Publish the policy documents on the Policy Library

As a NSW government agency, the department must make its policies publicly available unless there is an overriding public interest against disclosure of the information. Section 14 of the Government Information (Public Access) Act 2009 has more details about public interest considerations against disclosure.

Unless there are overriding circumstances, all policies and related implementation documents must be made publicly available through the Policy Library in the department's website in appropriate format.

Policy owners must pay particular attention to the policy's metadata, especially in selecting search keywords to enable staff to easily find the policy document on the Policy Library.

Remember that all documents published on the department's website must meet accessibility standards.

An interim publication process is in place until work on the integration of the Policy Library and HP Records Management is completed. Contact the Policy Coordination and Review team when your policy has been approved for publication.

Support policy users to comply with the policy

In addition to an information campaign, consider other ways to maximise compliance with the policy, such as:

  • training resources for staff and/or external stakeholders
  • amendments to workflows or changes to IT systems
  • formal change management processes for policies that result in significant changes to the department and the work of schools
  • seminars with representatives of policy users or presentations at principals networks conferences
  • online tools and resources.
Store policy development records on HPRM

HP Records Manager (HPRM) is the department's approved records management system. Many policy managers use HRPM (previously known as TRIM) throughout the policy development or review process.

If policy documents were drafted outside HPRM, all relevant records must be stored on HPRM at the conclusion of this stage of the policy development or review cycle. Keep the records in the allocated program folder for the policy on the HP Records Manager (BOX032344).

Contact the Policy Coordination and Review team if you require assistance with managing records related to policy development and review.

Main activities in this stage

  • Monitor the effectiveness of the policy in achieving its intended outcomes
  • Review policy documents so that they remain relevant and valid
  • Considering if policy remains the best way to mitigate risk or address the issue
  • A review may result in a policy update or rescission.

Policy owners must monitor and review their policies periodically to ensure that they remain relevant and valid. Polices must be reviewed at least every three years or more frequently if required.

Policy owners gather evidence to indicate whether and how policies are meeting objectives. Data may be collected from users and stakeholders. The data collected is brought together and analysed to determine achievements or issues associated with the policy and implementation.

Findings will be used to inform the policy review and the decisions that flow from the review, including the degree of revision required or decision to rescind the policy.

Monitoring the effectiveness of the policy in achieving its intended outcomes

Implementation of policies requires monitoring by the relevant business area. The policy owners will need to track progress in achieving the intended outcomes of the policy.

Monitoring involves the use of regular and systematic data gathering to inform the evaluation and subsequent reviews of the policy. This may be done:

  • At targeted points to show progress (for example, after 3 months, 6 months and 12 months)
  • At longer intervals for comparison (for example, with baseline data).

Keeping a log of enquiries and feedback from policy users will also help identify aspects of the policy that could be improved.

Data that reflects the implementation of policies by schools, for example, can be sourced through the A-Z Policy Implementation Tool. This system has report generating functions to obtain information data about implementation at either an individual school level or within a network of schools. This function can be used by policy owners in monitoring the implementation of policy and when conducting reviews.

Review policy documents

Periodic reviews ensure that policy documents remain relevant and valid. A policy review may result in updates to the policy, an amalgamation of policies or rescinding a policy.

The scope and activities for a policy review depends on the trigger of the review (i.e. periodic or priority review) and the changes required (i.e. ‘quick fix’, minor review or major review).

  • Trigger of the review
    Periodic review

    Policy documents must be reviewed at least every three years to ensure consistency with related legislative or regulatory requirements, government policy, departmental goals and other policies.  The review should be informed by evidence and information gathered on the implementation of the policy.

    Priority review

    A priority review may need to be carried out outside the periodic review cycle. This may be in response to:

    • legislative and case law changes
    • changes in the environment within or outside of the department
    • public events generating media interest and drawing attention to policy issues
    • other initiatives from external stakeholders
    • government policy imperatives such as government reforms, for example, Local Schools, Local Decisions
    • departmental directives and strategic plans
    • results of research and evaluation studies.
  • Changes required
    The ‘quick-fix’

    From time to time, changes of an insubstantial, administrative or minor editorial nature will need to be undertaken. ‘Quick-fixes’ may include typographical improvements, updating the titles of roles and organisational units, and changes to the policy owner contact details. These changes would not normally need consultation with stakeholders or approval by an Executive Director.

    Minor review

    A minor review may need to be undertaken to change certain aspects of the policy. These changes do not alter the purpose or outcomes of the policy nor impact on related policy documents or stakeholders to whom the policy document applies. For example, minor updates may need to be undertaken to align the policy with strategic directions, amalgamate existing documents or reorganise the manner in which information is presented within a policy document.

    Minor reviews would usually involve minimal drafting and consultation with a limited group of stakeholders.

    Major review

    A major review of a policy may be undertaken in order to:

    • make changes of a substantial nature
    • alter the purpose, intent, outcomes or scope of the policy
    • respond to significant impacts on related policy documents or stakeholders to whom the policy applies.

    When conducting a major review, policy owners perform activities similar to that of initiating a new policy, for example:

    • determining if policy remains to be the best way to address the risk or issue
    • if policy remains to be the best solution, determining if there are existing policies that already address the risk or issue
    • prepare a project plan for the policy review.

    Approval from the relevant Executive Director is required to start a major review. A Deputy Secretary approves policy documents following a major review.

Main activities in this stage

  • Business impact analysis to determine the effect of the policy rescission
  • Approval by the Deputy Secretary to rescind the policy
  • Communication to policy users
  • Removal of the documents from the Policy Library

A policy review may result in a decision to rescind the policy. A policy that becomes irrelevant (i.e. it no longer serves its purpose) or redundant (i.e. another policy or risk mitigating solution exists or will exist) will need to be rescinded.

Business impact analysis

The analysis involves the preparation of a risk assessment and an impact statement. It should detail why the policy has been deemed irrelevant or redundant, and include details of the alternative solution that has replaced the policy.

The impact statement should identify the issues for and against the rescission of the policy, the potential impact on the department or stakeholders and a recommendation for action.

Stakeholder consultation is recommended to determine the benefits and risks in rescinding a policy. Meetings with stakeholders should be held and feedback recorded.

Approval

Only a Deputy Secretary can approve the rescission of a policy.

Approval to rescind a policy must be sought using a standard briefing template that:

  • states the reasons that the policy (or a supporting document) is no longer required
  • makes the recommendation to rescind the policy.

The approval must be stored in the allocated program folder for the policy on the HP Records Manager (BOX031625). The rescinded policy documents must be moved into the 'Versions' folder. The 'rescinded date' must be entered on policy metadata (accessible by right-clicking on the record and then selecting Details - Additional Fields).

Communication with policy users

A communication plan to inform policy users of the policy rescission will need to be prepared and implemented.

Approval to rescind a policy should be tabled at the Schools Policy Governance Group to ensure that there is oversight of policy changes across the department.

The rescinded policy documents must be removed from the Policy Library. Consider the timing of the policy rescission to avoid a policy vacuum (i.e. not having a policy in place) or overlapping policies (i.e. having multiple, potentially contradictory, policies) that cover specific issues. If the policy rescission is contingent on alternative solutions then these solutions must be in place prior to the removal of the policy documents from the Policy Library.

The Policy Coordination and Review team can assist with the removal of the policy from the Policy Library and in ensuring that records management obligations are met.

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