Retention & Records Management Policy

Document Control for Bassetlaw District Council
Organisation		Bassetlaw District Council
Title		Retention and Record Management Policy
Author		Lesley K Bianco
Filename
Owner		Bassetlaw District Council
Subject
Protective Marking		Open
Review Date
Revision History
Revision Date	Reviser	Previous Version	Description of Revision
April 2018
August 2018	J Glass		Land Charges
January 2019	J Glass		Democratic Services
Feb/Mar 2019	J Glass		Various amendments to existing entries
Document Approvals
This document requires the following approvals
Sponsor of Approval	Name	Date

Document Distribution
This document will be distributed to:-
Name	Job Title	Email Address

Acknowledgements
Introduction
Establishment of the Guidelines
Scope of Guidelines
Retention Guidelines Objectives
Litigation
Active Management of Information (Databases)
Emails
Disposal of Records
Roles and Responsibilities
Reviewing of Schedule
Format of Records
Data Protection Act
Enactment of Standard for Local Authority
Index of Retention Schedule

Acknowledgements

Special thanks are due to the following for their help in developing the schedule:

Record Management Society of Great Britain, Local Government Group
Batchelor Associates Keith Batchelor
East Sussex County Council Colin Hinton
Devon County Council Angela Doughty
Hertfordshire County Council Tony May
Kent County Council Elizabeth Barber
NPS Property Consultants Ltd Louise Chittock
Surrey County Council Eileen Perren
Westminster City Council Simon McKeon
And, Huntingdonshire District Council

Introduction

Bassetlaw District Council recognises that its records are an important public asset and are a key resource to effective operation and to accountability. Like any asset they require careful management and this policy sets out the Council’s responsibilities and activities in regard to the management and retention of its records.

As a local authority we must be consistent in the way we handle, share and dispose of our information, to undertake effective management of all types of records and information, particularly keeping them organised, accessible and secure for the purpose they were obtained, and only for as long as they are needed.

These guidelines will assist Bassetlaw District Council in meeting local needs whilst providing a consistent approach to record keeping across Government.

The Council has made a commitment to be an open and transparent organisation, and having robust retention policies and procedures ensures that members of the public understand what information the Council holds and for how long it is kept for.

This Retention Policy applies to all information the Council processes regardless of how it was created or received or the way in which the information is stored. This policy applies to information and data in electronic and physical formats.

Establishment of the Guidelines

These guidelines have evolved through two stages:

a) The Records Management Society of Great Britain for Local Authorities draft retention guidance

b) Additional input from Bassetlaw District Council Officers

Statutory requirements. Information will be retained for only as is required by statute
Ongoing business need. Information will be retained for only as long as it is required to run the organisation effectively. Storing information cost money, therefore storing information for longer than is necessary incurs unnecessary cost.

Scope of the Guidelines

These Retention Guidelines have been adapted from those issued by the Record Management Society of Great Britain. The original guidelines were issued to support local authorities in the areas of Data Protection, Freedom of Information, Record Retention and the Local Government Act.

Specific retention periods have been reviewed and amended in accordance with industry specific guidelines, and verified by the Council’s Heads of those Professions, e.g. Finance, Building Control, Environmental Health, etc.

The Guidelines are intended to be independent of any particular format of record that might be historically created (e.g. card, register) or media (e.g. paper electronic) and prolong the Guidelines period of application.

The Guidelines are intended to cover the continuum of records and information through to destruction or for retention for historical or research purposes.

Records sentenced for destruction under the Guidelines may be destroyed in accordance with the provisions of the Guidelines.

The retention policy and retention schedule help the Council to meet its statutory obligations to ensure that information is retained for the correct period of time and then disposed of appropriately. It is unlawful to retain information for longer than necessary.

Backup copies stored on alternative media (e.g. serves/microfilm/paper) should also be destroyed. This is vital to ensure compliance with the requirements of Data Protection and Freedom of Information legislation.

Records for permanent preservation should be stored as agreed within the attached schedule.

Retention Guidelines Objectives

These guidelines are intended to:

Assist in identifying records that may be worth preserving permanently as part of a local authority’s archives.
Prevent the premature destruction of records that need to be retained for a specified period to satisfy legal, financial and other requirements of public administration.
Provide consistency for the destruction of those records not required permanently after specified periods.
Promote improved Records Management practices within local authorities.

Litigation

Where litigation is possible, the records and information that might be required should not be amended or disposed of until the possibility of litigation has been removed.

Legislation relating to mandatory retention periods and the rights of citizens to the information held is spread across a range of sources including;

Local Government Act 1972
Limitation Act 1980
Audit Commission Act 1998
GDPR - Data Protection Act 2018
Freedom of Information Act 2000
Environmental Information Regulations 2004
Legislation relating to taxation and financial records e.g. HMRC

Active Management of Information. (Databases)

Information held in databases is constantly evolving, however this does not mean that it is exempt from the retention policy. Managers must ensure that information held in databases meet the statutory obligations in regard to any retention and disposal. Defunct or closed databases must be managed in accordance with the Council’s retention schedule.

The Council will take active steps to ensure that the information held in databases it manages, owns or use is accurate and up to date and not retained beyond the time limit set in the retention schedule. Where there seems to be no justified reason to hold personal or sensitive information it must be destroyed immediately, unless the information owner can present a sound business reason or statutory requirement to Senior Management.

In managing information held in databases the Council will correct errors on discovery and dispose of any out of date records in line with the Council’s retention schedule.

Where information needs to be retained for statistical or research purposes the information owner must ensure that all such information is anonymised or meets our statutory obligations for the management of personal or sensitive information.

Emails

Emails and attachments relating to authority's business are corporate records and must be managed in accordance with the authority's retention schedule.

Emails users need to manage their accounts effectively and proactively and retained emails should be filed appropriately. Each individual will be responsible for removing any documents/e-mails from their email account to their personal location on the network if they are required to keep this longer than the 7 years retention.

Any officer requiring editing rights beyond the 7 years needs to gain permission from the Head of Service and ICT.

Disposal of Records

A Record and Document Disposal Register of destroyed records will be maintained. Enough detail will be recorded to identify which records have been destroyed. It is not sufficient to indicate that a quantity of records have been destroyed on a certain date. Enough details should be retained to identify which records have been destroyed. A designated manager will have overall responsibility for the register of destroyed records.

For records not covered by the Policy, contact the Council’s Audit department, legal department or suitable experienced sources for further advice.

Records should be destroyed at the end of their life cycle using the appropriate methods, paper records shredded via the Council’s approved contractor or for electronic records, deletion from the IT system (please contact ICT support desk for advice).

Electronic information must be treated in the same way as physical information; therefore electronic information must be disposed of once it has reached its set disposal date.

Checks should also be carried out for deletion of any “Backups” stored on the Electronic Document Management System and main back office systems.

For records not covered by the guidelines contact the Information Services Manager for further advice.

Roles & Responsibilities

Managers will be responsible for ensuring that their Retention Policy remains up-to-date and the register of destroyed records is completed for their area of responsibility. If the Manager wishes to delegate responsibility for these guidelines to another member of the department they should inform the Information Services Manager. Each department will identify this officer (or these officers) and publicise their identify to their staff. Staff will contact this officer if they have any concerns or queries about the Policy.

Managers have the responsibility to ensure information is held and used appropriately, retained for the correct period of time and then correctly disposed of or transferred to the archives service.

Managers are responsible for ensuring that staff comply with the retention policy and follow associated guidance relating to specific responsibilities. Managers are also responsible for ensuring that their staff comply with the retention schedule and ensuring it is reviewed and updated on a regular basis.

It is the responsibility of information owners to investigate wrongful disposal of information.

Reviewing the Schedule

These guidelines prescribe minimum and permanent retention periods. The Policy and Schedule will be reviewed at regular intervals. If any additional records are identified for inclusion within these guidelines, you will need to inform the Information Services Manager.

Format of Records (electronic, paper, microfiche)

Record Retention Policies were primarily created to define retention periods for paper records. However as more of the Council business is performed electronically there is a need to define the retention periods of electronic records. These record retention guidelines are relevant to records which are electronic, paper or records which have been transferred to another format such as microfiche.

Data Protection Act

Under the GDPR - Data Protection Act (2018) it is illegal to retain information for longer than is necessary

Enactment of Standard for a Local Authority

As there is no legal basis for the enforcement and support of this Policy, Bassetlaw District Council needs to ensure that the actions shown in the Policy and Schedule are ratified internally within the local authority or its agency.

This Retention and Disposal Schedule has been authorised by:

Signature of the Chief Executive

Date of Issue

Signature of 151 Officer