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Policy Governance Instruction - Developing and Reviewing Policies

Section 1 - Purpose

(1) This Instruction provides details on how to develop or review RMIT Group level policies, standards and procedures. 

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Section 2 - Authority

(2) Authority for this document is established by the Policy Governance Policy.

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Section 3 - Scope

(3) This Instruction applies to all staff who are developing or reviewing RMIT Group policies, standards and procedures.

(4) For the purposes of this Instruction, the term policy document refers to policies, standards and procedures.

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Section 4 - Instruction

(5) The steps for developing a new policy document or reviewing an existing policy document are almost identical. Where variations exist, they are described below.

(6) Where procedures or standards are developed separately from a new policy or a policy review process, the development or review process should follow all the steps outlined below, except for those concerning creating a policy advisory group and consulting with the approval authority midway through the process.

(7) Where instructions or guidelines are developed separately from a new policy or a policy review process, the policy author can determine a development process which ensures the documents support the principles of the overarching policy.

(8) Where RMIT legislation (regulations or statute) exists in relation to a policy suite, it must be included in the scope of the cyclical review of a policy suite.

Commencing

(9) For new policy documents, refer to clauses 21 – 23 of the Policy Governance Procedure on the steps for proposing a new policy, procedure or standard. After a proposal for a new policy document has been endorsed by the University Policy Manager, the project lead nominated in the proposal form can commence the development.

(10) For existing policies, Central Policy reminds policy owners of their requirement to conduct a major policy review approximately 12 months prior to the ‘review by’ date published on the Policy Register. The project lead nominated by the policy owner should commence the review at least nine months prior to the ‘review by’ date published on the Policy Register. This allows time for extensive engagement and consultation, and for processing the revised documents through the relevant committees and approval authority.

(11) Project leads must notify Central Policy when they have commenced policy development or review so Academic Board or the Audit and Risk Management Committee can be notified in the University Policy Manager’s Biannual Report.

(12) Central Policy may initiate a meeting with the project lead to provide advice on the development or review process, the resources and assistance available and the expectations of approval authorities.

(13) Where a cyclical review is being undertaken for an existing policy, all documents in the policy suite are reviewed together, regardless of the effective date of the subordinate documents in the suite.

(14) It is recommended that project leads establish a small working party of subject matter experts from across the RMIT Group to act as an advisory group throughout the development or review process, particularly project leads who are not in a dedicated policy role or who are not experienced policy writers. If the policy must meet legislative or regulatory requirements, the working party should include membership from Legal Services and Education Regulation, Compliance and Assurance, respectively.

(15) The policy advisory group meets as often as is necessary to support the policy lead, and this will vary depending on the size or complexity of the policy suite. For a small policy suite, this may only be three or four times over the development or review period, for reasons including:

  1. gathering feedback when the project commences on current issues and challenges (either with an existing policy or from the absence of a policy)
  2. exploring options for the policy suite after consideration of the desktop research and early engagement with stakeholders, and
  3. commenting on drafts of the policy suite.

Early engagement with stakeholders

(16) Policy owners and authors must provide direction to the project lead at the commencement of the development or review process and outline the issues they wish the policy to address.

(17) Project leads must consider engaging with the Sustainability team and utilising the Sustainability and Equity Evaluation Tool. The tool provides insights into how the policy subject matter intersects with the Inclusion, Diversity, Equity and Access Framework, RMIT’s commitment to supporting the United Nations Sustainable Development Goals, and its impact on Aboriginal and Torres Strait Islander peoples.

(18) After completing the Sustainability and Equity Evaluation, project leads must reach out to the Indigenous Education, Research and Engagementteam to determine whether the policy suite requires input from Aboriginal and Torres Strait Islander staff, students or community. This must be done early in the process as policies that may impact on place and community will require time for Aboriginal and Torres Strait Islander staff to consult with Elders and community members.

(19) Heads of each of the controlled entities must be contacted early in the process to determine if the new or revised policy suite or policy document will have significant implications for local operations. If so, a local subject matter expert should be sought for the policy advisory group or for the project lead to consult with.

(20) Early guidance and ongoing engagement and advice on new or revised academic and governance policies should be sought from the Education Regulation, Compliance Assurance team for insight into regulatory compliance requirements to be addressed in the policy.

Desktop research

(21) Desktop research must be conducted for new policy suites and policy suite reviews. Findings are reported to the approval authority at the midway check (refer to clause 24) and in the final submission. Desktop research includes:

  1. benchmarking against professional or industry standards, and legislative and regulatory requirements
  2. benchmarking with other universities or similar-sized organisations to identify best practices and any gaps in RMIT’s policies
  3. determining whether delegations of authority embedded in the policy are comparable with other institutions
  4. considering feedback received or issues raised over the life of the existing policy or from the policy advisory group
  5. reviewing any breaches of the existing policy and the remedial action taken
  6. assessing the relationship between the policy subject and the management of RMIT’s risk domains.

(22) After completing desktop research and developing ideas for the new or revised policy suite, project leads should engage with key stakeholders about the proposed changes to an existing policy suite or proposed content for a new policy suite. Refer to the resource on Effectively Engaging with Policy Stakeholders on the staff Policy Hub for ideas and guidance on engagement and consultation.

(23) All aspects of the desktop research and stakeholder engagement should be documented in case the approval authority requests evidence of this work.

Engaging midway with the approval authority

(24) Prior to drafting the policy suite, the policy owner must submit a brief report (the ‘midway check’) to either the Vice-Chancellor's Executive Meeting (for governance and operational policies) or Academic Board to:

  1. summarise insights gathered from engagement with stakeholders, the policy advisory group, desktop research and any other relevant sources
  2. outline the proposed direction of a new policy suite, or the proposed changes to an existing policy suite, and the rationale, and
  3. seek endorsement to proceed with drafting the policy documents as proposed in the report.

(25) This step does not apply to procedures or lower level documents developed as single documents separately from the development or review of a policy suite.

Quality and compliance checks

(26) Drafting the policy documents is an iterative process that involves seeking feedback from the policy advisory group, policy author, policy owner, and others as required. Refer to the guidance notes for writing policy documents on the staff Policy Hub.

(27) When the policy author endorses the documents for official consultation, the policy documents are sent to Central Policy. Central Policy checks the documents for clarity, compliance with the Policy Governance Policy and Procedure, and any overlap with other policies, before entering the draft documents into the database underpinning the Policy Register. The documents may be returned to the project lead with questions or for amendment.

Formal consultation

(28) It is compulsory to conduct two rounds of consultation on the Policy Register Bulletin Board.

  1. The first round is with targeted stakeholders nominated by the project lead and Central Policy, and must run for a minimum of two weeks.
  2. The second consultation period, after feedback from the first round has been considered and changes possibly incorporated, is open for all RMIT Group staff to provide feedback. It also must run for a minimum of two weeks.
  3. A project lead may choose to run additional consultation rounds via the Bulletin Board.

(29) Changes to policy documents between the rounds of consultation must be sent to Central Policy to add to the versions in the policy database, including after the RMIT Group-wide round on the Bulletin Board. This is to enable Central Policy to provide the policy author with PDFs of the final versions of the policy documents to submit to the approval authority.

Preparing documents for the approval authority

(30) Refer to the Policy Governance Procedure for preparing a submission for policy suite approval, and to the relevant Secretariat for meeting schedule advice.