RECORD KEEPING POLICY

Purpose 

The purpose of this policy is to establish the guidelines for the creation, maintenance, retention, access, and disposal of records within Horizon Solar Power Pty. Ltd. in compliance with the Victorian Energy Upgrade (VEU) and CEC accreditation standards. This policy aims to ensure efficient and organised management of all company records for legal, regulatory, operational and historical purposes. 

Scope

This policy applies to all employees, contractors and stakeholders who create, handle and/or access records within Horizon Solar Power Pty. Ltd. It covers all types of records, including but not limited to financial records, contracts, invoices, end to end project documentation, employee records, customer information and any other records specific to the CEC and VEU program.

Record Keeping Methadology

All records required to be generated and maintained under CEC and the VEU program guidelines will be collected and stored digitally using Dataforce, a software specifically designed for the purpose of CEC and the VEU program. All records must be accurate, legible and readily accessible as and when required. Records may be kept in hard copy where digital records are not possible as long as they meet the requirements for authenticity, integrity, accuracy and security.

Contractors & Installers

Contractors (if used) and installers must maintain detailed records of all installations completed as per the requirements under CEC and the VEU program. Installers will be provided access to record capture and storage software (Runabout) to enable them to generate relevant records.

Assessors and Auditors 

Assessors and auditors must maintain detailed records of assessments, audits, findings, and recommendations in accordance with CEC and VEU accreditation standards.

Management

Management is responsible for overseeing the implementation of this policy, providing necessary resources for record-keeping activities, and ensuring compliance with regulatory requirements.

Compliance Officer

A designated compliance officer will monitor adherence to this policy, conduct regular audits of record-keeping practices, and address any non-compliance issues.

Mandatory Record Requirements 

This policy dictates that the records to be maintained must include, but not be limited to:

Project and Installation Records

Detailed records of all energy efficiency upgrades conducted under the VEU scheme and CEC, including the date and location of installation, the type of product installed, and the Victorian Energy Efficiency Certificates (VEECs) generated per project must be maintained. This includes quotations/invoices, customer consent forms, STC documentation, assignment forms, contracts, all relevant geo-tagged photos and installer certificates (VBA and CoES). 

Financial Records

Detailed records must be maintained for all financial transactions included but not limited to invoices, receipts of VEEC sales, receipts of STC sales, receipts of sales direct from consumers. All financial records are to be maintained digitally but may be in hard copy if necessary.

Inventory Management Records

Detailed records must be maintained for all inventory purchase invoices and inventory reconciliation. Unique job numbers created through the Dataforce software must be used to link inventory to individual jobs to facilitate inventory management and reconciliation.

Decommissioning and Disposal Records

Detailed records must be maintained for the disposal of all decommissioned products. These can include but are not limited to lists of EPA approved waste disposal facilities to be used, lists of any third-party disposal agents, waste receipt of invoices from EPA approved facilities or any alternative records to demonstrate that the decommissioned product has been disposed in compliance with EPA legislation as set out by the CEC and VEU guidelines.

Employee and Sub-Contractor Records

Detailed records must be maintained for all employees and any sub-contractors including but not limited to employment contracts, any sub-contractor agreements, identification, any relevant licence and accreditation/certification information, training and on-going professional development activities.

Compliance and Quality Assurance Records

Detailed records must be maintained which demonstrate compliance with CEC and VEU regulations, standards and accreditation requirements. Records of any deviations from regulatory requirements and corrective action must also be maintained. Records of all quality assurance measures including phone and field audits conducted documenting customer feedback and complaints must be maintained. 

Regulatory Audit Records

Detailed records must be maintained of any correspondence and documentation in relation to audits conducted by the Essential Services Commission. 

Record Retention and Disposal

All records must be maintained and retained for a period of 6 years as per regulatory requirements. At the end of the stipulated period, records shall be disposed of securely in accordance with applicable privacy and data protection laws. Records that are subject to legal holds or pending investigations must not be destroyed until such holds or investigations are resolved.

Records Access and Security

Access to records will be restricted to authorized personnel with a legitimate need for such access. Adequate security measures will be implemented to protect records from unauthorized access, tampering, loss, or damage. Electronic records will be stored on secure servers with appropriate access controls and encryption mechanisms.

Training

All personnel involved in record-keeping activities will receive adequate training on the requirements of this policy and related procedures. Regular training sessions and updates will be provided to ensure ongoing compliance and awareness of this policy.

Policy Review

This policy will be reviewed every 12 months, and earlier when there are regulatory changes, changes in the workplace or the systems of work.

Non-Compliance and Policy Breaches

Employees who are not fully compliant with this policy will be provided with additional information, instruction, training, or supervisory support to assist them to meet the standards required. Employees who are in blatant breach of this policy and who have subsequently placed themselves, others or the company at risk will be subject to disciplinary action that may lead to termination of employment.

Conclusion

Adherence to this Record Keeping Policy is essential for maintaining the integrity, credibility, and compliance of CEC and VEU accreditation activities. All personnel are expected to familiarize themselves with this policy and adhere to its provisions in their daily activities.