Summary

This policy outlines the requirements and principles for governing and managing data at Swinburne University of Technology (Swinburne). It establishes a unified, principles-based framework to ensure data is treated as a strategic asset and managed consistently throughout its lifecycle, supporting compliance, security, and effective use.

Objectives

This policy aims to:

  • Set clear principles for governing data
  • ensure compliance with legal and ethical obligations
  • clarify roles and responsibilities, and support effective, consistent management of data assets across their lifecycle.
     

 It also supports compliance with research ethics approvals, funding and collaboration agreements, the Australian Code for the Responsible Conduct of Research, the NHMRC guidelines for ethical conduct in research with Aboriginal and Torres Strait Islander peoples and communities, and associated guidance on the management of data and information in research.

Scope

This policy applies to all Swinburne staff, students, contractors, consultants and third parties in their handling of data in any format collected, managed or used by Swinburne.    

This policy applies to enterprise and research data.

1. Principles

Swinburne University of Technology recognises data as a strategic asset that underpins its academic, research and operational activities.  Effective governance of data assets is essential to enable appropriate use, ensure integrity and quality, protect privacy and security, and support compliance with legal, ethical and contractual obligations.

Data is governed and managed across its lifecycle in a manner proportionate to its sensitivity, risk and intended purpose, and in accordance with applicable legislation, policies, standards and agreements.

Research data is governed and managed in accordance with research integrity principles and relevant ethics approvals, codes, guidelines, consent conditions, cultural considerations and contractual obligations.

1.1.  Security and Protection

Swinburne has legal and ethical obligations to protect data and personal privacy.  The University implements robust data governance and management practices to safeguard the integrity, security, quality, use and reuse of data and metadata.

Swinburne has institutional responsibility for providing governance, facilities and guidance for the safe, secure and responsible management of enterprise data, research data and research materials. Data is only developed, collected, accessed, used, and shared for appropriate, legitimate and necessary purposes, and personal data is managed in accordance with the Privacy Procedures.

Data is protected throughout the data lifecycle in a manner proportionate to its sensitivity, regardless of where the data resides or what purpose it serves. Protection measures are informed by data classification, which categorises data (physical or digital) based on confidentiality, integrity, and availability requirements, and supports consistent decisions about access, handling and controls.

Swinburne acknowledges the sovereignty of Indigenous peoples over their data. Data collection involving Indigenous peoples must be based on free, prior, and informed consent, and data practices must respect Indigenous traditions, cultures, and protocols. The University will actively and purposefully collaborate with Indigenous communities in the governance and management of their data.

In the event of a data breach, or a data security incident, the major incident management process applies. Where an incident involves personal data, research data, or data subject to Indigenous Cultural and Intellectual Property (ICIP) or Indigenous Data Sovereignty (IDS), additional reporting, escalation and remediation obligations may apply under research ethics approvals, the Australian Code for the Responsible Conduct of Research, NHMRC guidelines, funder or collaboration agreements, and Indigenous data governance arrangements.

1.2. Accessibility and sharing

Data is shared and accessed to support legitimate institutional, academic and research purposes.

Swinburne is committed to a responsible and rigorous approach to data accessibility and sharing that enables appropriate use while protecting privacy, security, intellectual property, cultural interests and contractual obligations, in accordance with applicable governance requirements.

Access to and sharing of data is guided by consistent data sharing principles that consider purpose, people, settings, data and outputs. These principles support proportionate, transparent and accountable decisions about access across the University.

In the research context, Swinburne supports transparency and openness to enhance the validity, reuse and impact of research. Where research data is shared, the University encourages practices consistent with the FAIR (Findable, Accessible, Interoperable, Reusable) and CARE (Collective Benefit, Authority to Control, Responsibility, Ethics) principles. Research data should be made as open as possible and as closed as necessary, while remaining consistent with ethical, legal, cultural and contractual obligations.

Access to and sharing of data and records must align with their classification and with relevant institutional, research and legislative requirements.

1.3. Quality and Accountability

Swinburne is accountable for maintaining and continuously improving the quality and integrity of its data. This responsibility is shared by all staff who create, manage, use or steward data.

Data quality is supported through defined roles and responsibilities, including data stewards, custodians and their delegates, who are responsible for managing data quality throughout the data lifecycle in accordance with applicable governance requirements. The University is committed to transparency in its data practices and is accountable to Indigenous peoples concerning data that relates to them.

Enterprise data definitions, terms and measurements are applied to support consistent understanding and use of data across the University. In the research context, definitions, standards and documentation may be discipline specific and method dependent, and institutional frameworks are applied in ways that support accepted research practices.

Records and information management form part of accountable data practice across all University processes, systems and services, with ownership and responsibilities defined in accordance with applicable requirements.

1.4. Innovation and Reuse  

Swinburne supports the continuous improvement of its data and information systems, practices and capabilities to enable effective, innovative and responsible use of data.

Data reuse is encouraged where it delivers academic, research or operational value and is consistent with applicable governance requirements, supporting efficiency, insight and innovation across the University.

In the research context, reuse and secondary use must align with research governance arrangements, including ethics approvals, consent conditions, cultural considerations and contractual obligations.

1.5. Storage, Preservation and Accountable Destruction or Transfer 

Data is retained, preserved and disposed of in a manner proportionate to its value, risk and purpose, and in accordance with applicable legislation, retention and disposal authorities, and institutional requirements.

As a Victorian public sector organisation and public office, Swinburne manages records to support accountability, transparency and compliance with applicable policy, legislation and recordkeeping standards, and ensures records are securely destroyed or transferred when they are no longer required.

The University is responsible for establishing governance, facilities and guidance to support the secure storage and management of digital and physical research materials.

Research data is retained and managed in accordance with research integrity requirements, ethics approvals, funder, publisher and collaboration obligations, and applicable legal requirements. Ownership of research data remains with the University unless explicitly transferred by contract.

Ownership of research data is exercised through stewardship and does not of itself confer rights of access, reuse or control. Decisions about access, use, retention, transfer and publication of research data are governed through stewardship arrangements and are subject to ethics approvals, consent conditions, cultural considerations, disciplinary norms, contractual obligations and Indigenous data governance arrangements. These principles apply to both digital data and physical research materials.

1.6. Roles and Responsibilities

Role/Decision/Action Responsibility
Conditions and limitations

Overseeing Swinburne-wide data governance and providing oversight and assurance of related strategic initiatives to protect data, information and records across Swinburne.

Establishing mandatory procedures in the domain of information technology. 

Vice President, Service & Operations & Chief Operating Officer  

Establishing mandatory guidelines in the domain of information technology.

Assigning Swinburne-wide management responsibilities for the use of Swinburne information resources, digital communication platforms/technologies and artificial intelligence systems.

Responsible for overseeing the security of Swinburne’s data assets, information systems, and digital infrastructure.

Chief Information Officer  
Accountable for institutional oversight of research data governance, ensuring that appropriate frameworks, guidance, assurance mechanisms and capabilities are in place to support the responsible management of research data in accordance with this policy, the Australian Code for the Responsible Conduct of Research, and applicable ethical, legal and contractual obligations. Deputy Vice-Chancellor (Research)  
Provides institutional leadership and oversight to ensure that data governance practices involving Indigenous peoples, communities, data and knowledge are consistent with Indigenous Data Sovereignty (IDS) and Indigenous Cultural and Intellectual Property (ICIP) protocols.

Pro Vice-Chancellor, Indigenous Engagement

Delegates operational responsibilities to Professor, Indigenous Research

Responsible for leveraging data and technology to optimise operations and advance strategic initiatives.

Chief Data Analytics Officer

 
University’s Privacy Officer, responsible for supporting Swinburne in its compliance with privacy legislation, including notifying relevant regulator(s) in the event of an Eligible Data Breach or as otherwise required. Director, Legal, Compliance and Integrity  
Responsible for the overall management of Swinburne’s data and information governance and for establishing and managing the operational processes to support this policy. This includes coordinating targets and reporting cycles for data quality and metadata monitoring and reporting. Associate Director, Data Governance  

Establishing and implementing a records management program.

Issuing guidance on policy implementation for records.

Overseeing retention and facilitation of disposal of data, information and records and maintaining the physical and digital University archives.

Applying Retention and Disposal Authorities.

Facilitating the lawful disposal of information and records.

Delegated by the Vice-Chancellor to the Manager, Information and Data

In accordance with this policy and s.13 of the Public Records Act 1973 (Vic)

Business role, usually an executive or divisional head of a functional area, accountable for one or more data topics. For their topic, they oversee:

  • data governance principles, guidelines and procedures
  • data governance operations
  • data protection
  • communications and partnerships.
Data Trustee

Accountable for a data topic

Data Trustees, Data Stewards and Data Custodians do not have decision‑making authority over research data.

Business owner of one or more data entities, responsible for ensuring the quality, integrity, and appropriate use of data throughout its lifecycle. For their entity, they:

  • apply data governance principles, guidelines and procedures
  • provide data descriptors
  • assure data quality
  • provide subject matter expertise on business requirements
  • assess business process impact
  • manage data governance issues
  • endorse data disposal.
Data Steward

Accountable for a data entity

Data Trustees, Stewards and Custodians do not have decision‑making authority over research data.

Accountable for the governance, quality, integrity and appropriate management of research data within a research project or activity. The Research Data Steward ensures research data is managed in accordance with research ethics approvals, funder and collaboration agreements, and Swinburne’s research data governance framework. This role is often the Chief Investigator. For HDR students, this is the principal supervisor.

Research Data Steward

Accountable for research data for a research project or activity

Technical role responsible for managing and operating a source system who:

  • applies data governance principles, guidelines and procedures
  • manages and operates data infrastructure
  • provisions data access once endorsed
  • ensures data availability
  • assesses business process impact
  • manages data governance issues.
Data Custodian

Accountable for a source system

Data Trustees, Data Stewards and Data Custodians do not have decision‑making authority over research data.

End user role responsible for entering, using, developing, storing and sharing data across the data life cycle.

Undertakes appropriate preparation, training and compliance. Works with data, following data governance principles, policies and processes.

Raises concerns and issues relating to data.

Data User  

Researchers and supervisors must comply with the Australian Code for the Responsible Conduct of Research principles, and any applicable guides relating to management of data in research.

Researchers have primary responsibility for deciding which research data and primary materials are candidates for long-term retention and wider accessibility.

Researchers and research supervisors

 

Definitions

Term Definition
Australian Aboriginal and Torres Strait Islander Indigenous community

The Australian Aboriginal and Torres Strait Islander Indigenous individuals, groups, organisations, Traditional Owners, Elders, cultural knowledge holders, governance bodies or wider communities who are affected by, connected to, or have rights and interests in the research, data or knowledge being collected, used, shared or published.

Research projects should be staged to allow continuing opportunities for consideration of the research by the community. Indigenous communities are distinct, and one Indigenous community, group or representative cannot be assumed to speak for another. 

CARE

CARE principles emphasise Collective Benefit, Authority to Control, Responsibility and Ethics, ensuring that Indigenous data is governed in ways that respect Indigenous rights, values and self‑determination.

Data  

Data are measurements or observations that are collected as a source of information. There are a variety of different types of data, and different ways to represent data. Data can be in digital and physical forms. Data becomes valuable when it is processed and analysed to extract meaning, leading to insights, decisions or predictions.

Data breach

An unauthorised access to, disclosure of, or loss of data that compromises its confidentiality, integrity, or availability.

Data classification

The process of categorising data based on its sensitivity, value, and risk to determine appropriate handling, access, and protection requirements.

Data user

An end user role responsible for entering, using, developing, storing and sharing data across the data lifecycle in an appropriate way.

Data custodian

A technical role responsible for managing and operating a source system.

Data entity

A defined business concept or object about which data is collected and managed, such as a person, activity, or transaction.

Data governance

Data governance is the exercise of authority, control, and shared decision-making over the management of data assets. Data governance provides the structure, policies, and oversight necessary to ensure that data is accurate, secure, accessible, and used responsibly across the organisation. 

Data lifecycle

The stages through which data passes, from creation or collection through use, sharing, storage, retention, and disposal.

Data quality

Fitness of data for its intended purpose.

Data security incident

An event that threatens the security of data or information systems, whether it results in a data breach.

Data sharing

The controlled provision of data to internal or external parties for approved purposes, in accordance with legal, ethical, and institutional requirements.

Data steward

A business role who usually reports to an executive or divisional head, accountable for one or more data entities. The data steward is responsible for data quality and integrity. 

Data topic

A high‑level subject area or domain of data for which governance accountability is assigned.

Data trustee

A senior business role accountable for governance, protection, and appropriate use of a defined data topic.

Enterprise data

Any data that is created, collected or managed to support the administration, operation, governance, planning or delivery of the University’s activities, including data arising from educational, outreach, commercial and other non‑research projects. Enterprise data is also referred to as institutional or corporate data.

FAIR

Principles for research data management and stewardship that promote data being Findable, Accessible, Interoperable and Reusable through appropriate metadata, standards and governance.

Global Indigenous community

A community of Indigenous peoples who share collective identity, culture, language, knowledge systems, governance practices, or connections to lands, waters or territories, and who identify as Indigenous. This definition refers to Indigenous communities outside the Australian Aboriginal and Torres Strait Islander community. 

Indigenous communities are distinct, and one Indigenous community, group or representative cannot be assumed to speak for another.

Indigenous Cultural and Intellectual Property (ICIP)

The rights of Indigenous peoples to their cultural knowledge, practices and heritage. This comprises all images, objects, sites, artefacts, art, genealogies and knowledge (oral, pictorial and written) materials, the nature or use of which has been transmitted and continues to be transmitted inter-generationally through past, present and future, and which is regarded as pertaining to a particular Indigenous group or groups, and/or their territory, Country and land. The cultural heritage of an Indigenous peoples is a living one and includes (but is not limited to) objects, images, genealogies, knowledge, literary and artistic works which may be created in the future based on that heritage.

Aboriginal and Torres Strait Islander cultural heritage, knowledge and data includes (but is not limited to):

  •  literary, performance and artistic works (comprising songs, music, dance, story, ceremony, symbols, artefacts, language(s) and designs);
  • scientific, agricultural, technical and ecological knowledge (comprising cultigens, medicines and the phenotypes of flora and fauna);
  • all items of movable cultural property;
  • cultural governance and practice;
  • human remains and tissues;
  • immovable cultural property (including sacred and historically significant sites and burial grounds); and
  • documentation of Indigenous peoples’ culture(s) and heritage in archives, genealogies, film, photographs, artwork, literary and scholarly works, videotape or audiotape and all forms of media.

Indigenous data

Includes data, information and knowledge, in any format, that impact Indigenous peoples, nations and communities at an individual and collective level. Data can be quantitative or qualitative or both. It includes, without limitation, data about land and environment, people and cultures. It may be generated by Indigenous peoples or government or other institutions including research organisations. 

Indigenous Data Governance

Refers to the right of Aboriginal and Torres Strait Islander people to manage what, how, where, when and why Indigenous data is collected, accessed, stored and used.

Indigenous Data Sovereignty (IDSov)

The right of Indigenous people to exercise ownership over Indigenous data. Ownership of data can be expressed through the creation, collection, access, analysis, interpretation, management, dissemination and reuse of Indigenous data.  IDSov rights are enshrined in Article 31 of the UNDRIP.

Metadata

Information that describes data, including its meaning, structure, origin, context, and use, to support understanding, management, and reuse.

Personal information

Information or an opinion (including information or an opinion forming part of a database), that is recorded in any form and whether true or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion, but does not include information of a kind to which the Health Records Act 2001 applies.

Record

Information captured as evidence of Swinburne’s business activities, decisions, and transactions. Examples include emails, reports, correspondence, meeting agendas and minutes, file notes, and decisions. Records management is integral to the University’s operations and accountability. Certain records must be retained for a specified period to meet legislative requirements. Records can be in physical or digital form.  

Research data

Records or materials, in any format, that comprise the observations, findings, or outcomes of research, including data created manually by researchers and data generated automatically by instruments, machines, sensors or other research equipment.

Research data steward

Accountable for the governance, quality, integrity and appropriate management of research data within a defined research project or activity.

Research materials

Physical or digital materials generated, collected or used in the conduct of research, including samples, specimens, artefacts, laboratory materials, notebooks, or models.

Sensitive information

Sensitive information includes personal, financial, and health-related data. It requires heightened protection due to legal, ethical, or reputational risk, and must be handled in accordance with applicable privacy laws and institutional policies. Sensitivity is determined through data classification processes. 

Source system

An information system where data is originally created, captured, or maintained and from which it is made available for use or distribution.

Structured data

Structured data is measurable, such as a set of observations organised into a table, spreadsheet or database. It is commonly stored in relational databases or data warehouses, where rows and columns define a clear structure. This makes it easy to search, filter, and combine data for reporting and analysis. 

Third party

An external individual, organisation, or entity that is not part of Swinburne University and with whom data may be shared.

Unstructured data

Unstructured data cannot be easily measured, such as audio and video files and documents. It is typically stored in file systems, content repositories, or cloud object storage. Unlike structured data, it lacks a fixed schema or formal structure, making search and analysis more complex and often requiring metadata or AI-driven indexing. 

Policy Governance

Policy details

Domain / Subdomain

Information Technology

Data Governance

Category

Operational

Approval

Vice-Chancellor

Approved 7/09/2026

Endorsement

Deputy Vice-Chancellor (Research)

Chief Operating Officer and Vice President, Service and Operations Excellence

Endorsed 4 September 2026

Policy Owner

Chief Information Officer

Policy Author

Associate Director Data Governance

Status Current
Version

1.0

Review Date

2031

History

History of approval of the policy and its amendments 

Version Date

Approved by

Change

1.0

7/09/2026

Interim Vice-Chancellor and President

New policy

V1.1

9/09/2026

 

Administrative change

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