8 - Records Management Policy
Renfrewshire Council · 13 June 2024
Back to Finance, Resources and Customer Services Policy Board — 13 June 2024 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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1 ___________________________________________________________________ To: Finance & Resources and Customer Services Policy Board On: 13th June ___________________________________________________________________ Report by: Director of Finance & Resources ___________________________________________________________________ Heading: Records Management Policy ___________________________________________________________________ 1. Summary 1.1 The Records Management Policy for Renfrewshire Council was first approved by the General Management and Finance Policy Board on 28 April 2010 and is subject to regular review. 1.2 The Policy is due for review. The proposed revisals are minor and reflect the current structure of the Information Governance Team and incorporate reference to the Council’s Business Classification Scheme. A Business Classification Scheme provides the primary framework for the organisation and life-cycle management of Council information and records. ___________________________________________________________________ 2. Recommendations 2.1 That the Board approves the revised Records Management Policy which forms the appendix to this report and agrees that this be reviewed on a two-yearly basis. _________________________________________________________
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2 3. Background 3.1 Renfrewshire Council’s records are essential for the Council to function and for staff to carry out their jobs. Records are a vital source of information providing evidence of the Council’s actions, policies and decisions. 3.2 The Public Records (Scotland) Act 2011 places an obligation on the Council to prepare and implement a records management plan which sets out efficient arrangements for the management of the Council’s records. The records management policy corresponds with Element 3 of the Council’s records management plan and the Keeper states that the Council’s policy should be available to all staff. 3.3 This policy is the top-level management document for records management in Renfrewshire Council. It applies to all recorded information - regardless of format – relating to the Council’s actions and transactions during its business activities. 3.4 This policy applies to all staff and elected members, as all staff have a responsibility to manage our records from creation to disposal. ___________________________________________________________________ Implications of the Report 1. Financial - none 2. HR & Organisational Development - none 3. Community/Council Planning - none 4. Legal - the updates to the Policy will ensure the Council’s continued compliance with its obligations under the Public Records (Scotland) Act 2011 5. Property/Assets - none 6. Information Technology - none 7. Equality & Human Rights – The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations will be reviewed and monitored, and the results of that assessment will be published on the Council’s website. 8. Health & Safety - none 9. Procurement - none 10. Risk - none
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3 11. Privacy Impact – Effective records management can only have a positive impact on people’s privacy whereby records are only retained for as long as necessary and are kept securely. 12. Cosla Policy Position – none 13 Climate Risk - none _________________________________________________________ List of Background Papers none ___________________________________________________________________ Author: Stacey Anderson, Records Management Officer Stacey.Anderson@renfrewshire.gov.uk 0141 487 1085
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4 Appendix 1 Renfrewshire Council Corporate Records Management Policy 4.3 2024
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5 Document Details Title Corporate Records Management Policy Author Records Management Officer Issue Date Subject Records Management Description Version 4.3 Source Updating Frequency 2 yearly review unless required earlier Document History Version Date Author Reason for Issue / Change 1.0 April 2010 Archivist/ Records Manager To support Corporate EDRMS System 2.0 January 2014 Review of Policy 3.0 October 2015 Joseph Bartoletti, Records Manager Review of policy for Council’s Records Management Plan 4.0 September 2019 Andy Connor, Records Manager Removal of RM Guidance into separate document. 4.2 May 2022 Andy Connor, Records Manager Review of Policy 4.3 May 2024 Stacey Anderson, Records Management Officer Review of Policy and Update to Staff Details Related Documents Ref Document Name/ Version Document Location 1 Freedom of Information Policy Intranet 2 Data Protection Policy Intranet 3 Information Security Policy Intranet 4 Records Disposal Policy Intranet 5 Business Classification Scheme Intranet Document Review and Approval Name Action Date Communication
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6 1. Allison Black, Managing Solicitor (DPO) Approved May 2022 Email 2. Records Management Working Group Approved June 2022 Email and minute at meeting 3. Finance & Resources and Customer Service Policy Board Approved November 2019 Board Paper Submission 4. Finance & Resources and Customer Service Policy Board Board Paper Submission
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7 Table of Contents Introduction .................................................................................................................... 5 Why manage records? ................................................................................................. 5 Roles and Responsibilities ........................................................................................... 6 The Council .................................................................................................................. 6 Directors ....................................................................................................................... 6 Managers ..................................................................................................................... 6 Records Management Officer ...................................................................................... 7 Records Management Working Group ......................................................................... 7 Further Information ....................................................................................................... 8 Relationship with existing policies ................................................................................ 8 Review of Policy ............................................................................................................ 8
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8 Introduction Renfrewshire Council’s records are essential for the Council to function and for staff to carry out their jobs. Records provide information for decision making and evidence of the Council’s activities and provide evidence of the rights and responsibilities of the Council and of our citizens The Public Records (Scotland) Act 2011 places an obligation on the Council to prepare and implement a records management plan which sets out efficient arrangements for the management of the Council’s records. This policy is the top-level management document for records management in Renfrewshire Council. It applies to all recorded information – regardless of format – relating to the Council’s actions and transactions during its business activities. This policy applies to all staff and elected members, as all staff have a responsibility to manage our records from creation to disposal. Why manage records? Statutory Requirements The Council has a statutory requirement to “make proper provision for the preservation and management” of its records; to be publicly accountable for and able to justify its decisions and actions; and to enable compliance with the requirements of the Public Records (Scotland) Act, 2011, the Data Protection Act 2018, the Freedom of Information (Scotland) Act 2002 and the Environmental Information (Scotland) Regulations 2004. Principles of Records Management • Information is a vital corporate resource; • Records belong to the Council – not to individual officers or departments; • Every member of staff has responsibilities to manage the records that they deal with; • Records should be held in a properly managed system; • Records should be reliable, accurate, up-to-date and fit for purpose; • Records should remain accessible for the lifetime of their retention; • Personal, sensitive or confidential information should be appropriately managed; • Records will be disposed of in accordance with the Council’s Records Retention Schedule; • Good records practice should be applied to information in ALL media – print AND electronic. Benefits of Records Management Good quality records and information management will benefit the Council by: • Delivering best value by encouraging efficiently in the accuracy, storage and retrieval of information; • Ensuring adherence to statutory obligations, including those established by the Public Records (Scotland) Act, the Data Protection Act 2018 and the Freedom of Information (Scotland) Act 2002; • Demonstrating evidence of accountability and information about the Council’s decisions and activities;
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9 • Supporting the delivery of efficient and effective frontline services by providing appropriate access to full and accurate records; • Saving of physical and virtual space through the reduction of duplication and timely destruction of obsolete information; • Ensuring the identification and survival of records for permanent preservation as part of the Council’s corporate memory. Roles and Responsibilities The Council The Council has a corporate responsibility for records management and compliance with the PRSA 2011. Employees Every employee (irrespective of grade or position) shall ensure that all key documents or records they are responsible for are filed in an appropriate manner. They shall ensure that they know: • Where the records relating to the business of their team are stored; • How they are handled / disposed of; • How long they should be retained for; • How their records management awareness and skills can be improved; • What electronic folder set up is used within their team for the sharing of information; and how the information relevant to the official corporate record is identified; • Ensuring that all actions and decisions of the Council are properly recorded and that records relating to their actions and decisions are authentic and reliable; • Managing records to support the Council’s business aims and objectives; • Complying with this policy for records management; • Complying with relevant legislation, policy and corporate guidance on records management. Elected Members Elected Members are required to ensure secure retention, disposal or return of Council information, as appropriate, at the end of their term. Directors Directors are accountable for: • Ensuring the records used by employees under their line management are managed in accordance with this policy and associated guidance and ensuring that all employees are aware of, receive guidance on and can adhere to this policy; • Support for records management in terms of resources and commitment; • Having in place control systems and measures to ensure the proper care and custody of records used under their line management;
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10 • Ensuring that records management is reflected in job descriptions and roles where appropriate; • Ensuring the general security of records. Managers All Managers are responsible for: • Ensuring the records used or created by employees under their line management are managed in accordance with this policy and associated guidance; • Ensuring that employees are adequately trained in records management according to their role, and are aware of and can adhere to this policy and associated guidance; • Ensuring that records are kept in a record keeping system with adequate controls and measures and designating employees to administrate the records keeping system; • Determining the sensitivity of records and defining restrictions on access and extraordinary access; • Ensuring that, where relevant, records are prepared and archived in line with Council procedures and in the approved place of deposit. • The secure and confidential destruction of records, when required by the Council Records Retention Schedule; • Ensuring that all partners delivering services to the service area for which they are responsible, have an effective records management policy which meets the requirements of this policy as a minimum, and that responsible employees of the partner are adequately trained to ensure the partner complies with that policy; • Ensuring that employees are aware of the Council’s arrangements regarding access to information and comply with them, and ensure that procedures are in place to document decisions concerning access. Records Management Officer The Records Management Officer is responsible for: • Overseeing the compliance of records management practice with this policy, the legislation and professional obligations; • Overseeing the operation of the Council’s Corporate Record Store; • To maintain, review and lead on the implementation completion of the Council’s Records Management Plan, in accordance with the Council’s responsibilities under the Public Records (Scotland) Act 2011; • Creating and maintaining guidance, and the provision of advice and support for all records management; • To advise Council Services and provide guidance on all aspects of records management, including the introduction of effective and appropriate management of electronic records; • To promote good records management and raise awareness of records management issues; • To develop and deliver training in records management; • To advise Services on retention and disposal periods and have oversight of Services’ retention and disposal schedules; • To manage the Council’s corporate records store;
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11 • To advise on electronic document and record management projects and initiatives, ensuring that records are managed to agreed standards and that current records management policies and procedures are adhered to; • Access to information arrangements and ensuring that the Council’s policies and procedures comply with the requirements of relevant legislation, guidance and codes of practice relating to access to information, such as the Freedom of Information (Scotland) Act 2002, the Environmental Information (Scotland) Regulations 2004, and the Data Protection Act 2018; • Providing guidance on the development of corporate records management tools, and the procedures for their use, including the: o Business Classification Scheme and File Plan; o Retention and Disposal Schedules, in conjunction with Services; and o Corporate File / Record Audit. • Providing guidance on the development and approval of record keeping systems and records management controls and measures; • The Council’s policy and procedures on archiving historic records; • The ownership and periodic review of this records management policy. Records Management Working Group Each Service and its senior management will retain a service responsibility for ensuring that its records are disposed of at the appropriate time, in accordance with the Council’s records retention schedules. All Services are required to nominate at least one departmental officer, of appropriate seniority, and a delegate to supervise this process. These officers will: • Attend quarterly meetings of the Records Management Working Group; • Act as service first point of contact for the Records Management Officer; • Be responsible for driving forward the RMWG agenda within their service in order to create positive change in relation to the management of records; • Report to the Records Management Officer any areas of concern within their service. The Records Management Officer will maintain an up-to-date list of members of the Group. Further Information Contact: The Records Management Officer First Floor, Renfrewshire House (0141) 487 1085 Relationship with existing policies This policy has been formulated within the context of Council documents including: • Data Protection Policy; • Freedom of Information Policy; • Information Security Policy; • Information Management Strategy; • Information Handling Policy; • Information Governance Strategy
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12 • Information Governance Framework; • ICT Acceptable Use Policy. Review of Policy This policy will be reviewed on at least a two-yearly basis by Records Management Officer, in consultation with the Records Management Working Group and approved by the Finance & Resources and Customer Services Policy Board. An earlier review will be carried out should any legislative or business change require this.