SDS Retention and Disposal Policy. February 2014

Transcription

1 SDS Retention and Disposal Policy February 2014

2 Title SDS Retention and Disposal Policy Prepared By PRSA Executive Reviewed By Head of Corporate Office Signed off By ELG (March 2014) Version Number 1.0 Review Frequency Annually Next Review Date February 2015 Version Date Status Prepared by Reason for Amendment 2

3 Table of Contents 1. Introduction Objectives of the Policy Statement and Schedule Retention of records Disposal of records Amendments to the Policy statement and Schedule Review of the Policy Statement and Schedule Annex A: Schedule... 7-xx 3

4 1. INTRODUCTION The SDS Retention and Disposal Policy Statement and Schedule (The Schedule) details the recommended retention periods for which the records should be held and the action that must be taken when they have reached the end of their retention period. The Schedule (attached as Annex A) relates to all records created or received by Skills Development Scotland in line with business need, legislative, statutory and regulatory requirements. This Retention and Disposal Policy Statement and Schedule has been created to guide and support staff of SDS in ensuring good business practice and compliance with Data Protection, Freedom of Information and Public Record Acts and other legislation. It is intended that the Schedule will promote the rationalisation of retention policies throughout SDS and assist future data sharing initiatives. The Schedule is intended to cover the continuum of records and information from creation through to destruction or permanent preservation (the records life cycle ). It is intended to be independent of any particular format or media of records and information and cover manual records including paper, microfilm, microfiche, audio and video tapes as well as digital information including databases, SMS, mobile data, spreadsheets, word processed documents and OBJECTIVES OF THE POLICY STATEMENT AND SCHEDULE The aims of the Schedule are to: Identify those records worth retaining; Prevent the premature destruction of records that need to be retained for a specified period to satisfy operational, legal, financial and other requirements of public administration. Identify vital records necessary for business continuity purposes. Prevent the unnecessary retention of records Assist SDS staff in identifying records that may be worth preserving permanently as part of the organisation s contribution to national archives. Provide consistency of approach to the destruction of those records not required permanently after specified periods. Promote improved records management practices across the organisation. Promote public confidence in our records management actions on the part of SDS partners, customers and stakeholders. 3. RETENTION OF RECORDS SDS has produced a business classification scheme (BCS) which set out the categories of records we currently keep. In order to assess if the current scheme is up to date, SDS will review the BCS - at least annually - against: - the statutory and regulatory environment - business and accountability requirements - the risks associated with keeping or disposing of a record at any particular point in time The retention schedules that are presently published on the SDS intranet do not reflect all corporate records and systems retention periods. A comprehensive up to date Schedule will be prepared following consultations with designated contacts across the planning units so as to match the information provided in the updated BCS. The schedules are intended to be as 4

5 wide-ranging as possible, but it is recognised that some particular functions or information may not be included. The retention schedules contain information of specific record types and either minimum recommended periods that those should be retained for, or their appropriate retention period based on legal and regulatory requirements. When we hold information within SDS there should be a rational or justification for doing so, this provides the basis of a retention schedule which lays how long information should be kept and the rational for that period which then provides a defensible position. The retention period specified in the attached Schedule does not mean that the document or information should, without exception, be destroyed after the set date. The retention period specifies the latest date to re-evaluate the information. At the end of the Retention period should be a decision point around either retaining the specific records longer because there is a justification for doing so or to dispose of them either by destruction or moving them to a permanent archive outside the organisation, at which time the organisations responsibilities cease in relationship to those records. As a result, at the end of a retention period SDS staff should: a) evaluate the business value of the records / information; b) if applicable, set a further retention period which might include the decision to store the records off site at for example Iron Mountain; c) move to their disposal/final action. Owners of the records should ensure that these records remain accessible for as long as required and are managed appropriately throughout their lifecycle. 4. DISPOSAL OF RECORDS This section deals with the records disposal regime. It is particularly important under FOI that there are clearly defined policies and procedures for identifying how long records should be kept, for disposing of those no longer required for business purposes, (either by destruction or transfer to an archive) and for documenting the decisions and their implementation. Section 9 of the Records Management Code lists the key elements and activities needed to establish the required processes, and mechanisms for effective disposal arrangements. It states that: It is particularly important under FOI that the disposal of records - which is here defined as the point in their lifecycle when they are either transferred to an archive or destroyed - is undertaken in accordance with clearly established policies which have been formally adopted by organisations and which are enforced by properly authorised staff. The process of disposal will be governed by SDS Retention and Disposal Policy Statement and Schedule. There are generally two procedures to follow with regards to the disposal of your records once they have reached the end of their recommended retention period: 5

6 i) Destruction of records If the records are no longer required for business purposes and have been retained for the recommended retention period, in line with any legislative or statutory obligations, the record should be destroyed/ deleted. When records identified for disposal via destruction, a Document Destruction Log Sheet should be completed and a register of such records needs to be kept. Enough details should be retained to identify which records have been destroyed. The retention period in the Schedule stipulates the length of time the records should be retained. Unless they are subject to a review or an exemption, records should be destroyed within the prescribed timescale. This includes backup copies stored on alternative media. Failure to destroy such records will bring organisations into conflict with Data Protection, Freedom of Information and Public Records legislation. Of course, the recommendations in this document do not prevent the retention of individual records in the event of ongoing activity. If you only have a convenience copy of a document, and did not create or have responsibility for it, then you may destroy it as soon as you no longer require it for administrative purposes. ii) Transfer to Archive/ Review for Archival value All records that are of potential historical value should be transferred to the appropriate archive repository for permanent preservation, once their local administrative use is concluded. For SDS this would mean transfer of records to the National Records of Scotland (NRS). Records for permanent preservation should be passed to Corporate Office for review. Then, SDS should contact the NRS Archivist for further information on transfer procedures. The collection policies of individual archives vary and depend on the records information classification. Records no longer required for administrative use may still retain sensitive information. NRS should be informed of sensitivity at the time of transfer of the material to the archives, and an appropriate closure period agreed. The closure period should comply with Freedom of Information legislation and the authority s policy. 5. AMENDMENTS TO THE SCHEDULE Any amendments to the Schedule should be forwarded to the appropriate RM Champions and/or where appropriate Information Asset Owners for review, approval and implementation. Once the amendments are considered and agreed by the relative planning unit, the responsibility for updating the Schedule lies with Corporate Office. This is necessary to ensure that any amendments do not conflict with professional or statutory regulations or guidance. 6

7 6. REVIEW OF THE SCHEDULE Corporate Office and IGLG will review this Schedule frequently. It is expected that new categories of records will emerge and will be incorporated in the Schedule. Staff who identify anomalies or omissions should contact their local RM champion or Information Asset Owner in the first instance outlining the issue or their suggestions. Corporate Office in cooperation with the respective Information Asset Owner will consider any proposal, in terms of relevant legislation and service practice, and will recommend amendments to the policy where appropriate. This Retention and Disposal Policy will be reviewed annually and the Schedule at least sixmonthly and when legislation is introduced that changes record retention periods. Responsibility for the regular review, maintenance and development of this document lies with Corporate Office. 7. ANNEX A APPLYING THE SCHEDULE The Schedule is separated into broad functional areas according to SDS planning units. Activities may be structured differently in each planning unit/ directorate, but this does not affect the application of the schedules. For the purpose of the schedules: - Unless otherwise stated Current year means current business year (e.g ). - Records should be disposed of as soon as practically possible once the retention period has ended. - Where records are recommended for review after a set period, it is the responsibility of each planning unit to develop and maintain guidelines for this procedure. Explanation of the abbreviations: CY = Current Year (business year) CY+ (X)Y = Current year plus the number of years stated D = Destroy A = Archive P = Preserve permanently *Periods are in full years unless otherwise stated. 7