Records management policy
In compliance with data protection legislation, personal data will be retained for 'no longer than is necessary for the purposes for which the personal data are processed'. To determine what has been deemed as necessary please refer to the Retention Guidelines that are an appendices to this policy. The Retention Guidelines provide details of all the Council's records, both personal and non-personal data.
Retention periods have been set in accordance with primary or secondary legislation or, where there is not a legal requirement, they have been set in accordance with business need or good practice.
As a local authority we may also identify a need to retain documents of historical value.
Where records are authorised for destruction they should be destroyed in accordance with paragraph nine.
Standard operating procedure
Standard operating records do not ordinarily need to be kept and can be destroyed in line with the disposal guidelines below.
Standard operating procedure records can include:
- working papers leading to a final report
- out of date distribution lists
- telephone message slips
- trivial emails
- compliment slips
- telephone message slips
This is a non-exhaustive list.
Council documents, which are not standard operating procedure records, will be retained in accordance with the Council's retention schedules.
Where you have scanned original copies of documents and we do not need to keep an original copy you must ensure that the scanned copy is clear and legible prior to disposal. In some circumstances, an original copy will need to be safely and securely stored. The Inland Revenue and Customs and Revenues prescribe the retention of original paperwork in some circumstances. Law Society guidance also provides information on the retention of some original documentation, such as deeds or guarantees.
Service managers are responsible for:
- ensuring that scanned documents are legible and provide a true copy of the original
- ensuring that scanned documents are retained in accordance with the document retention schedules
- ensuring that scanned documents can be located and retrieved promptly when required for:
- operational purposes
- a subject access request or other exercise of a data subject's rights under data protection legislation
- a request under the Freedom of Information Act 2000
- legal proceedings
Document retention and disposal protocol
Each Head of Service is the assigned Information Asset Owner. They must ensure that they have in place an adequate system for documenting the retention of records within their service. This system should take into account the legislative and regulatory environment in which they work.
Records of each activity should be complete and accurate enough to allow employees and their successors to undertake appropriate actions in the context of their responsibilities to:
- facilitate an audit or examination to those authorised to do so
- protect the rights of the Council, its residents, contractors and clients and any other persons affected by its actions
- provide authenticity of the records so that the evidence derived from them is shown to be credible and authoritative
To facilitate the above, the following principles should be adopted:
- Records created and maintained should be arranged in a record keeping system ensuring ownership of these records that will enable the Council to obtain the benefit from the quick and easy retrieval of information.
- Record systems utilised within services, whether paper or electronic, should include a set of rules for referencing, titling, indexing, and if appropriate, security marking documents and records. These should be easily understood and enable the efficient retrieval of information.
- The movement and location of records should be controlled to ensure that a record can easily be retrieved at any time and that any outstanding issues can be dealt with, and that there is an auditable trail of record transactions.
- Storage accommodation for current records should be clean and systematic, to prevent damage to the records and to ensure accessibility. Equipment used for current records should provide storage, which is safe from unauthorised access, meets fire regulations, but allowing maximum accessibility to authorised officers when required.
- Documents that are no longer required for operational purposes but still require retention should preferably be placed in a designated records centre.
- Services should ensure that a contingency or recovery plan is in place to provide protection for records, which are vital to the continued functioning of the Council.
- A system should be in place to ensure that where a member of staff leaves, changes role, or is absent, that records remain accessible to those who will require access. Information Asset Owners should ensure that a suitable system is in place.