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Records Management Policy Page 1 of 48
Records Management Policy
Author(s)
Andrew Thomas
Version
1.0
Version Date
21 August 2013
Implementation/approval Date
14 August 2013
Review Date
August 2014
Review Body Information Governance Steering Group
Policy Reference Number
023
Version Author Date Reason for review
0.0 Andrew Thomas July 2013
0.1 Neil Taylor August 2013
Formatting Adjustments to match CCG Policy on Polices
0.2 Neil Taylor August 2013
Minor adjustments from IG Steering Group
0.3 Neil Taylor September 2013
Minor adjustments from Policy Review Group
1.0 Neil Taylor October 2013
Final
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Contents Page
1.0 Introduction ...................................................................................................... 3
1.01 Records Management Policy statement and aim ......................................... 3 1.02 Definition of a Record .................................................................................. 4 1.03 Objectives .................................................................................................... 4
2.0 Scope of the Policy .......................................................................................... 4
3.0 Governance ..................................................................................................... 4
3.01 Roles and Responsibilities ........................................................................... 5
4.0 Key Records Management Requirements ....................................................... 5
4.01 Requirement 1 – Record Creation ............................................................... 5 4.02 Requirement 2 – Record Use....................................................................... 5 4.03 Requirement 3 – Records Management Practice ........................................ 5 4.04 Requirement 4 – Records Management Risk Assessment .......................... 5
5.0 Records Inventory ........................................................................................... 6
6.0 Record Disposal .............................................................................................. 6
6.01 Appraisal ...................................................................................................... 6
6.02 Retention and Destruction............................................................................ 6 7.0 Statement of evidence/references ................................................................... 7
7.01 Legislative and Regulatory Environment ...................................................... 7 7.02 Best Practice Standards .............................................................................. 7
8.0 Policy Review .................................................................................................. 8
8.01 Next formal review ....................................................................................... 8
9.0 Monitoring Compliance with this Policy ........................................................... 9
9.01 Monitoring of compliance ............................................................................. 9 9.02 Non Compliance .......................................................................................... 9
10.0 Implementation and dissemination of document............................................ 10
11.0 Training Requirements .................................................................................. 10
12.0 Latest Version ................................................................................................ 10
13.0 Associated Documents .................................................................................. 10
14.0 Appendices .................................................................................................... 11
Appendix 1 Equality & Equity Impact Assessment Checklist ............................. 12 Appendix 2 Consultation History ........................................................................ 13 Appendix 3 Category A Protected Personal Data .............................................. 14 Appendix 4 Business and Corporate (Non Health) Retention Schedule ............ 15
ADMINISTRATIVE (CORPORATE AND ORGANISATION) ............................. 15
ESTATES/ENGINEERING ................................................................................ 25 FINANCIAL ....................................................................................................... 30
IM & T ............................................................................................................... 40 PERSONNEL/HUMAN RESOURCES .............................................................. 41 PURCHASING/SUPPLIES ................................................................................ 47
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1.0 Introduction
It is the policy of NHS Greenwich Clinical Commissioning Group (CCG) to ensure compliance with statutory requirements, Department of Health policy and professional standards in relation to the creation, retention, use and disposal of records of all kinds. GP and Dental practices within the CCG catchment area are encouraged to implement their own policy and they are free to model their policy on this if they wish. In this case NHS Greenwich CCG will waive their copyright on this policy.
1.01 Records Management Policy statement and aim The Records Management: NHS Code of Practice (CoP) published by the Department of Health is a guide to the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England. It is based on current legal requirements and professional best practice. The CoP states that records are the corporate memory, providing evidence of actions and decisions and representing a vital asset to support daily functions and operations. Consequently it requires all NHS bodies to adopt a systematic and planned approach to the management of records, from the moment the need for a record to be created is identified, through its creation, use and maintenance to its ultimate disposal (Full Record Life Cycle). NHS Greenwich Clinical Commissioning Group recognises that effective records management is fundamental to good administration and operational effectiveness, and is an enabler to the achievement of our strategic aims and objectives:
Improving health, quality and maintaining safety of local NHS services.
Sustaining an effective grip on finance, performance and Quality, Innovation, Productivity and Prevention (QIPP).
NHS Greenwich Clinical Commissioning Group is committed to on-going improvement of its records management systems as it believes that it will gain a number of organisational benefits from so doing. These include:
better use of physical and server space;
better use of staff time;
improved control of valuable information resources;
compliance with legislation and standards; and
reduced costs.
NHS Greenwich Clinical Commissioning Group also believes that its internal management processes will be improved by the greater availability of information
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that will accrue by the recognition of records management as a designated corporate function.
1.02 Definition of a Record
Documentary evidence, regardless of form or medium, created, received, maintained and used by the NHS Greenwich Clinical Commissioning Group in pursuance of its legal obligations or in the transaction of business. This definition draws a distinction between a record and a document – a record is a final version that may be retained, while a document can be changed and will not normally be retained except for audit trail purposes where necessary. The purpose of a record is to preserve information in a form that is trustworthy and, once declared, should not be changed Two groups of Category (A) Protected Personal Data can be found at Appendix 3.
1.03 Objectives
The key objectives of this policy and supporting guidance are to:
Demonstrate compliance with relevant legislation
Facilitate and effectively record all organisational operations, business and policy decisions
Achieve and maintain standard of record management practice to level 2 as specified in the Information Governance Toolkit
Ensure that records are protected, complete, accessed and managed in line with information classification and handling arrangements;
Records of historical and evidential significance are identified and held securely;
Define clear responsibilities for managers and staff see below
2.0 Scope of the Policy
This policy applies to all employees of NHS Greenwich Clinical Commissioning Group, volunteers, staff of other NHS and health organisations, and other contracted staff; plus anyone granted access to the organisation’s network whilst engaged in work for NHS Greenwich Clinical Commissioning Group at any occupied location, and/or on any owned or approved computer asset.
This policy applies to all clinical and non-clinical corporate records (paper, electronic or in other formats) that are received, created, or held in the course of Organisation business.
3.0 Governance
The Chief Officer is accountable for information management and compliance with the Data Protection Act within NHS Greenwich Clinical Commissioning Group and delegates responsibility for the management of information risk to the Senior Information Risk Owner and Information Asset Owners who have specific responsibilities. The Information Governance Manager is responsible for ensuring that a framework for proper governance and assurance is in place
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3.01 Roles and Responsibilities All Staff are required to act in accordance with the principles of this policy as it relates to the management of information throughout its lifecycle.
At all times staff should discharge their duties in accordance with the law, ensuring that the confidentiality and security of information is maintained and that any disclosure is appropriate and provided to an authorised recipient. In this they are supported by the Information Governance Framework, procedures and best practice guidance.
4.0 Key Records Management Requirements
Records are a corporate asset and as such are an important source of its administrative, financial, legal, evidential and historical information; they are vital to the organisation’s future operations, for the purposes of accountability and for an awareness and understanding of its history; they are the corporate memory of NHS Greenwich Clinical Commissioning Group.
4.01 Requirement 1 – Record Creation
NHS Greenwich Clinical Commissioning Group will create, capture, use, manage, store and destroy or preserve its records in accordance with all statutory requirements and the NHS records code of practice and will ensure that the appropriate technical, organisational and human resources are in place to make this possible.
4.02 Requirement 2 – Record Use
A record will be created once, only stored for use only as many times as necessary and can be easily retrieved at any time to those who need to use them across NHS Greenwich Clinical Commissioning Group taking into account the need for effective security and appropriate confidentiality and that there is an auditable trail of record transactions
4.03 Requirement 3 – Records Management Practice Records management will be embedded within operational procedures and activities. As such all staff that create, use, manage or dispose of records have a duty to protect them and to ensure that any information that they add to a record is accurate, complete and necessary.
4.04 Requirement 4 – Records Management Risk Assessment The risk to effective records management will be assessed corporately and managed appropriately at strategic and operational levels. Compliance with this policy and associated procedures will be subject to a programme of audit and assurance.
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5.0 Records Inventory
NHS Greenwich Clinical Commissioning Group will establish an inventory of records which will facilitate:
the classification of records into series; and
the identification of record owners
6.0 Record Disposal
Disposal is defined as: ‘The decision on the management intent for a record once it is no longer required for the conduct of current business. ‘
6.01 Appraisal
The decision on the management intent is also known as appraisal. Appraisal is the examination of records to determine whether they should be retained for a further period, transferred to an archival establishment or destroyed.
Appraisal is a two-part decision making process.
The first part is deciding how long the record needs to be kept for business purposes. The second part is deciding whether the record can be destroyed when it is no longer needed by NHS Greenwich Clinical Commissioning Group or whether it is archival (that is: it is of on-going historical or cultural value).
6.02 Retention and Destruction
Linked to the records management policy NHS Greenwich Clinical Commissioning Group will create and maintain retention and destruction schedule which will state, in broad terms, the functions from which records are likely to be selected for permanent preservation and the periods for which other records should be retained once they have become inactive.
It is a fundamental requirement that all of NHS Greenwich Clinical Commissioning Group’s records are retained for a minimum period of time for legal, operational, research and safety reasons. The length of time for retaining records will depend on the type of record and its importance to NHS Greenwich Clinical Commissioning Group’s business functions. Business and Corporate (Non- Health) Records Retention Schedule. This retention schedule details a Minimum Retention Period for each type of non- health record. Records (whatever the media) may be retained for longer than the minimum period, however, records should not ordinarily be retained for more than 30 years. The National Archives should be consulted where a longer period than 30 years is required, or for any pre-1948 records. Organisations should also remember that records containing personal information are subject to the Data Protection Act 1998.
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The following types of record are covered by this retention schedule (regardless of the media on which they are held, including paper, electronic, images and sound):
administrative records (including personnel, estates, financial and accounting
records, and notes associated with complaint handling);
photographs, slides and other images (non-clinical);
microform (ie microfiche/microfilm);
audio and video tapes, cassettes, CD-ROMs, etc;
e-mails;
computerised records; and
scanned documents The schedule is split into the following types of records:
Administrative (corporate and organisation)
Biomedical Engineering Estates/engineering Financial
IM & T
Other
Personnel/human resources
Purchasing/supplies
If viewed in electronic format, the search facility in Word or PDF can be used to search for particular record types. (A Full list of the Retention Schedule is contained in Appendix 4)
7.0 Statement of evidence/references
A full list of guidelines, evidence and references will be provided and maintained in the Information Governance Management Framework.
All NHS records are Public Records under the Public Records Acts. NHS Greenwich Clinical Commissioning Group will take actions as necessary to comply with all legal and professional obligations in particular those contained in:
7.01 Legislative and Regulatory Environment
The Public Records Act 1958
Freedom of Information Act 2000
Data Protection Act 1998
Environmental Information Regulations 2004
Human Rights Act 1998
The common law duty of confidentiality
7.02 Best Practice Standards
ISO 15489 - Records Management Standard.
ISO 27001 – Information Security Standard
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DoH Records Management NHS Code of Practice.
DoH Records Management Roadmap
Confidentiality NHS Code of Practice.
Information Security NHS Code of Practice
Lord Chancellor's Code of Practice on the Management of Records Issued under (s.46) of the Freedom of Information Act.
The National Archive: Essential Records Management
Connecting for Health – Information Governance Toolkit Standards
8.0 Policy Review
8.01 Next formal review Review will take place of the 1st anniversary of adoption and subsequently every three years until rescinded or superseded.
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9.0 Monitoring Compliance with this Policy
9.01 Monitoring of compliance
Measurable Policy Objective
Monitoring/Audit
Frequency of monitoring
Responsibility for performing the monitoring
Monitoring reported to which groups/committees, including responsibility for reviewing action plans
All staff are aware of the Records Management policy and are aware of their responsibilities in records management
We will ensure that staff are aware of the Policy and will monitor the use of Safe Haven procedures and Safe Havens through spot checks and confidentiality audits.
Quarterly Information Governance Lead
Information Governance Steering Group
Performance in the Information Governance Toolkit to Level 2
Completed Information Governance Toolkit to Level 2
Yearly Information Governance Lead
Information Governance Steering Group
All instances of records management are recorded and any safeguard required is initiated
Completion of a Data Flow Mapping exercise and Information Asset Register
Yearly Information Governance Lead
Information Governance Steering Group
9.02 Non Compliance Noncompliance with this Policy by staff will be brought to the attention of the Information Governance Steering Group.
Failure to comply with the standards and appropriate governance of information as detailed in this policy and supporting procedures can result in disciplinary action. All staff are reminded that this policy covers several aspects of legal compliance that as individuals they are responsible for.
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Failure to maintain these standards can result in criminal proceedings against the individual.
10.0 Implementation and dissemination of document
The Policy, once approved by the CCG’s governing body, or delegated group, will be shared with all staff through the all staff email, updated on the intranet, and shared with the CCG’s Management Board. A team briefing will be provided to support this dissemination.
11.0 Training Requirements
Training will be carried out for this policy in line with the Information Governance Training Needs Assessment.
12.0 Latest Version
The audience of this document should be aware that a physical copy may not be the latest version. The latest version, which supersedes all previous versions, is available on the CCG Internet and Intranet.
13.0 Associated Documents
As a new organisation, the CCG is still developing a broad range of policies, protocols and procedures, which will be subject to further updates and additions. Related CCG policies, protocols and procedures currently include:
Consent to use PCD Policy
E-mail Policy
Information Governance Policy
Internet Policy
Mobile Device Policy
Records Management Policy
Acceptable Use Protocol
Confidentiality Code of Conduct Protocol
Freedom of Information Protocol
Information Sharing Protocol
Information Lifecycle Protocol
Pseudonymisation Protocol
Safe Haven Protocol
Confidentiality Audit Procedure
Subject Access to Health Records Procedure
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Supporting documentation also includes:
Information Governance Management Framework
Information Communication and Technology Framework
Information Governance Strategy
Information Governance Acronyms Document
Information Governance Roles & Responsibilities Document
Information Governance Steering Group Terms of Reference
Information Governance Training Needs Assessment
14.0 Appendices
Appendix 1 Equality Impact Assessment Checklist Appendix 2 Consultation history Appendix 3 Category A Protected Personal Data Appendix 4 Business and Corporate (Non-Health) Retention Schedule
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Appendix 1 Equality & Equity Impact Assessment Checklist
This is a checklist to ensure relevant equality and equity aspects of proposals have been addressed either in the main body of the document or in a separate equality & equity impact assessment (EEIA)/ equality analysis. It is not a substitute for an EEIA which is required unless it can be shown that a proposal has no capacity to influence equality. The checklist is to enable the policy lead and the relevant committee to see whether an EEIA is required and to give assurance that the proposals will be legal, fair and equitable.
The word proposal is a generic term for any policy, procedure or strategy that requires assessment.
Challenge questions Yes/No What positive or negative impact do you assess there
may be?
1. Does the proposal affect one group more or less favourably than another on the basis of:
Race No
Pregnancy and Maternity No
Sex No
Gender and Gender Re-Assignment No
Marriage or Civil Partnership No
Religion or belief No
Sexual orientation (including lesbian, gay bisexual and transgender people)
No
Age No
Disability (including learning disabilities, physical disability, sensory impairment and mental health problems)
No
2. Will the proposal have an impact on lifestyle?
(e.g. diet and nutrition, exercise, physical activity, substance use, risk taking behaviour, education and learning)
No
3. Will the proposal have an impact on social environment?
(e.g. social status, employment (whether paid or not), social/family support, stress, income)
No
4. Will the proposal have an impact on physical environment?
(e.g. living conditions, working conditions, pollution or climate change, accidental injury, public safety, transmission of infectious disease)
No
5. Will the proposal affect access to or experience of services?
(e.g. Health Care, Transport, Social Services, Housing Services, Education)
No
Document Author 14.8.13
Signature:
Equalities Lead (Carol Berry) 16.8.13
Signature:
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Appendix 2 Consultation History
Stakeholders Name
Area of expertise
Date sent Date received Comments Changes made
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Appendix 3 Category A Protected Personal Data
Group 1: one or more of the pieces of information which can be used along with public domain information to identify an individual
combined with
Group 2: information about that individual whose release is likely to cause harm or distress
Name / addresses (home or business or both) / postcode / email / telephone numbers/driving licence number / date of birth [Note that driving licence number is included in this list because it directly yields date of birth and first part of surname]
Sensitive personal data as defined by s2 of the Data Protection Act 1998: racial or ethnic origin political opinions religious beliefs or other beliefs of a similar nature membership of a trade union physical or mental health or condition sexual life the commission or alleged commission of any offence or any proceedings or sentencing relating to any offence committed or alleged to have been committed. Sensitive personal data will also include: DNA or finger prints / bank, financial or credit card details / mother's maiden name / National Insurance number / Tax, benefit or pension records / employment record / school attendance or records / material relating to social services including child protection and housing .
These are not exhaustive lists. Sensitive Data should be clearly identified in the Information Asset Register entry for the information set.
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Appendix 4 Business and Corporate (Non Health) Retention Schedule
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
ADMINISTRATIVE (CORPORATE AND ORGANISATION)
Accident forms (see also Litigation dossiers)
10 years Destroy under confidential conditions
S
Accident register (Reporting of Injuries, Diseases and Dangerous Occurrences register) – see also Incident forms
10 years
Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (reg. 7); Social Security (Claims and Payments) Regulations (reg. 25)
Destroy under confidential conditions
C
Advance letters (eg DH guidance) 6 years Destroy S
Agendas of board meetings, committees, sub-committees (master copies,including associated papers)
30 years See note 1 S
Agendas (other) 2 years Destroy under confidential conditions
S
Agreements (see Contracts)
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Assembly/Parliamentary questions, MP enquiries
10 years
As these documents include all information provided by the organisation in response to a PQ (e.g. background note to the Minister or the Minster may amend the response) all of which may not be used in the response and therefore it will not be in the public domain on House of Commons records must be destroyed under confidential conditions
S
Audit Records (e.g. Organisational Audits, Records Audits, Systems Audits) – Internal & External in any format (paper, electronic etc)
2 years from the date of completion of the audit
Destroy under confidential conditions
N
Annual/corporate reports 3 years See note 1 S
Business plans, including local delivery plans
20 years Destroy S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Close circuit TV images 31 days Information Commissioner’s Code of Conduct
Erase permanently S
Commissioning decisions – Appeal documentation – Decision documentation
– 6 years from date of appeal decision – 6 years from date of decision
Destroy under confidential conditions
S S
– Returns made to DH
NB: Current policy on the handling of complaints is under review and further guidance will be issued in due course
Data Input Forms (where the data/information has been input to a computer system)
2 years Destroy under confidential conditions
N
Diaries (office) 1 year after the end of the calendar year to which they refer
Destroy under confidential conditions
S
Exposure monitoring records 5 years from the date the record was made
Control of Substances Hazardous to Health Regulations 2002 (reg. 10(5))
Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Flexi working hours (personal record of hours actually worked)
6 months Destroy under confidential conditions
S
Freedom of Information requests
3 years after full disclosure; 10 years if information is redacted or the information requested is not disclosed
Destroy under confidential conditions
S
Health and safety documentation 3 years Destroy under confidential conditions
S
History of organisation or predecessors, its organisation and procedures (eg establishment order)
30 years See note 1 S
Incident forms 10 years Destroy under confidential conditions
C
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Indices (records management)
Registry lists of public records marked for permanent preservation, or containing the record of management of public records – 30 years File lists and document lists where public records or their management are not covered – 30 years
See note 1 Destroy under confidential conditions
S S
Litigation dossiers (complaints including accident/incident reports) Records/documents relating to any form of litigation
10 years Where a legal action has commenced, keep as advised by legal representatives
Destroy under confidential conditions
S S
Manuals – policy and procedure (administrative and clinical, strategy documents)
10 years after life of the system (or superseded) to which the policies or procedures refer
Destroy (policy documents may have archival value – see note 1)
S
Maps Lifetime of the organisation See note 1 S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Meetings and minutes papers of major committees and sub-committees (master copies)
30 years See note 1 S
Meetings and minutes papers (other, including reference copies of major committees)
2 years Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Papers of minor or short-lived importance not covered elsewhere, eg: – advertising matter – covering letters – reminders – letters making appointments – anonymous or unintelligible letters – drafts – duplicates of documents known to be preserved elsewhere (unless they have important minutes on them) – indices and registers compiled for temporary purposes – routine reports – punched cards – other documents that have ceased to be of value on settlement of the matter involved
2 years after the settlement of the matter to which they relate
Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Patient Advice & Liaison Service (PALS) records
10 years after closure of the case
Destroy under confidential conditions
N
Patient information leaflets 6 years after the leaflet has been superseded
See note 1 C
Phone Message Books
2 years NB Any clinical information should be transferred to the patient health record
Destroy under confidential conditions
N
Press cuttings 1 year Destroy (where bound volumes exist, see note 1)
S
Press Releases 7 years see note 1 N
Project files (over £100,000) on termination, including abandoned or deferred projects
6 years See note 1 S
Project files (less than £100,000) on termination
2 years Destroy under confidential conditions
S
Project team files (summary retained) 3 years Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Public Consultations e.g. about future provision of services
5 years Destroy under confidential conditions
N
Quality assurance records (eg Healthcare Commission, Audit Commission, King’s Fund Organisational Audit, Investors in People)
12 years Destroy under confidential conditions
S
Receipts for registered and recorded mail 2 years following the end of the financial year to which they relate
Destroy under confidential conditions
S
Records documenting the archiving, transfer to public records archive or destruction of records
30 years See note 1 S
Reports (major) 30 years See note 1 S
Requests for access to records, other than Freedom of Information or subject access requests
6 years after last action Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Requisitions 18 months Destroy under confidential conditions
S
Research ethics committee records 3 years from date of decision
See note 1 C
Serious incident files 30 years See note 1 S
Specifications (eg equipment, services) 6 years Limitation Act 1980 Destroy under confidential conditions
S
Statistics (including Korner returns, contract minimum data set, statistical returns to DH, patient activity)
3 years from date of submission
Destroy S
Subject access requests (DPA and AHR)– records of requests
3 years after last action Destroy under confidential conditions
S
Surgical appliances forms AP 1, 2, 3 and 4 2 years from completion of audit
Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
ESTATES/ENGINEERING
Buildings and engineering works, including major projects abandoned or deferred – key records (eg final accounts, surveys, site plans, bills of quantities)
30 years See note 1 S
Buildings and engineering works, including major projects abandoned or deferred – town and country planning matters and all formal contract documents (eg executed agreements, conditions of contract, specifications, ’as
30 years See note 1 S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
built’ record drawings, documents on the appointment and conditions of engagement of private buildings and engineering consultants)
Buildings – papers relating to occupation of the building (but not health and safety information)
3 years after occupation ceases
Construction Design Management Regulations 1994
Destroy under confidential conditions
S
Deeds of title
Retain while the organisation has ownership of the building unless a Land Registry certificate has been issued, in which case the deeds should be placed in an archive. If there is no Land Registry certificate, the deeds should pass on with the sale of the building
See note 1 S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Drawings – plans and buildings (architect signed, not copies)
Lifetime of the building to which they relate
See note 1 S
Engineering works – plans and building records
Lifetime of the building to which they relate
See note 1 S
Equipment – records of non-fixed equipment, including specification, test records, maintenance records and logs
11 years If the records relate to vehicles (ambulances, responder cars, fleet vehicles etc) and where the vehicle no longer exists, providing there is a record that it was scrapped, the records can be destroyed
Consumer Protection Act 1987
Destroy under confidential conditions
N
Inspection reports (eg boilers, lifts)
Lifetime of installation If there is any measurable risk of a liability in respect of installations beyond their operational lives, the records should be retained indefinitely
See note 1 S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Inventories of furniture, medical and surgical equipment not held on store charge and with a minimum life of 5 years
Keep until next inventory See note 1 C
Inventories of plant and permanent or fixed equipment
5 years after date of inventory
See note 1 S
Land surveys/registers 30 years See note 1 S
Leases – the grant of leases, licences and other rights over property
Period of the lease plus 12 years
Limitation Act 1980 Destroy under confidential conditions
S
Maintenance contracts (routine) 6 years from end of contract
Destroy under confidential conditions
S
Manuals (operating) Lifetime of equipment Review if issues (eg HSE) are outstanding
S
Medical device alerts Retain until updated or withdrawn (check MHRA website)
www.mhra.gov.uk
Destroy under confidential conditions
S
Photographs of buildings 30 years See note 1 S
Plans – building (as built) Lifetime of building May have historical value – see note 1
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Plans – building (detailed) Lifetime of building May have historical value (see note 1)
S
Plans – engineering Lifetime of building See note 1 S
Property acquisitions dossiers 30 years See note 1 S
Property disposal dossiers 30 years See note 1 S
Radioactive waste 30 years Radioactive Substances Act 1993
See note 1 S
Site files Lifetime of site See note 1 S
Structure plans (organisational charts) i.e. the structure of the building plans
Lifetime of building See note 1 C
Surveys – building and engineering works Lifetime of building or installation
See note 1 S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
FINANCIAL
Accounts – annual (final – one set only) 30 years See note 1 S
Accounts – minor records (pass books, paying-in slips, cheque counterfoils, cancelled/ discharged cheques (for cheques bearing printed receipts, see Receipts), accounts of petty cash expenditure, travel and subsistence accounts, minor vouchers, duplicate receipt books, income records, laundry lists and receipts)
2 years from completion of audit
Destroy under confidential conditions
S
Accounts – working papers 3 years from completion of audit
Destroy under confidential conditions
S
Advice notes (payment) 1.5 years Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Audit records (internal and external audit) – original documents
2 years from completion of audit
Destroy under confidential conditions
N
Audit reports – internal and external (including management letters, value for money reports and system/final accounts memoranda)
2 years after formal completion by statutory auditor
Destroy under confidential conditions
N
Bank statements 2 years from completion of audit
Destroy under confidential conditions
S
Banks Automated Clearing System (BACS) records
6 years after year end Destroy under confidential conditions
S
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Benefactions (records of)
5 years after end of financial year in which the trust monies become finally spent or the gift in kind is accepted. In cases where the Benefaction Endowment Trust fund/capital/ interest remains permanent, records should be permanently retained by the organisation
See note 1 S
Bills, receipts and cleared cheques 6 years Destroy under confidential conditions
S
Budgets (including working papers, reports, virements and journals)
2 years from completion of audit
Destroy under confidential conditions
S
Capital charges data 2 years from completion of audit
Destroy under confidential conditions
S
Capital paid invoices (see Invoices)
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TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Cash books 6 years after end of financial year to which they relate
Limitation Act 1980 Destroy under confidential conditions
S
Cash sheets 6 years after end of financial year to which they relate
Limitation Act 1980 Destroy under confidential conditions
S
Contracts – financial Approval files – 15 years Approved suppliers lists – 11 years
Destroy under confidential conditions
C
Contracts – non-sealed (property) on termination
6 years after termination of contract
Limitation Act 1980 Destroy under confidential conditions
S
Contracts – non-sealed (other) on termination
6 years after termination of contract
LimitationAct 1980 Destroy under confidential conditions
S
Contracts – sealed (and associated records)
Minimum of 15 years, after which they should be reviewed
See note 1 S
Records Management Policy Page 34 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Contractual arrangements with hospitals or other bodies outside the NHS, including papers relating to financial settlements made under the contract (eg waiting list initiative, private finance initiative)
6 years after end of financial year to which they relate
Destroy under confidential conditions
S
Cost accounts 3 years after end of financial year to which they relate
Destroy under confidential conditions
S
Creditor payments 3 years after end of financial year to which they relate
Destroy under confidential conditions
S
Debtors’ records – cleared 2 years from completion of audit
Destroy under confidential conditions
S
Debtors’ records – uncleared 6 years from completion of audit
Destroy under confidential conditions
S
Demand notes 6 years after end of financial year to which they relate
Destroy under confidential conditions
S
Records Management Policy Page 35 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Estimates, including supporting calculations and statistics
3 years after end of financial year to which they relate
Destroy under confidential conditions
S
Excess fares 2 years after end of financial year to which they relate
Destroy under confidential conditions
S
Expense claims, including travel and subsistence claims, and claims and authorisations
5 years after end of financial year to which they relate
Destroy under confidential conditions
S
Fraud case files/investigations 6 years Destroy under confidential conditions
S
Fraud national proactive exercises 3 years Destroy under confidential conditions
S
Funding data 6 years after end of financial year to which they relate
Destroy under confidential conditions
S
General Medical Services payments 6 years after year end Destroy under confidential conditions
S
Invoices 6 years after end of financial year to which they relate
Limitation Act 1980 Destroy under confidential conditions
S
Records Management Policy Page 36 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Ledgers, including cash books, ledgers, income and expenditure journals, nominal rolls, non-exchequer funds records (patient monies)
6 years after end of financial year to which they relate
Limitation Act 1980 Destroy under confidential conditions
S
Non-exchequer funds records (i.e. funding received by the organisation that does not directly relate to patient care eg charitable funds)
30 years Company charities are required by company law to keep their accounts and accounting records for at least three years but the Charity Commission recommends that they be kept for at least 6 years. The majority of non- company charities must keep their accounts and accounting records for six years (Part VI Charities Act 1993).
Although technically exempt from the Public Records Act, it would be appropriate for authorities to treat these records as if they were not exempt
N
Records Management Policy Page 37 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Patient Monies (i.e. smaller sums of donated money)
6 years Destroy under confidential conditions
N
PAYE records 6 years after termination of employment
Destroy under confidential conditions
S
Payments 6 years after year end Destroy under confidential conditions
S
Payroll (ie list of staff in the pay of the organisation)
6 years after termination of employment
Destroy under confidential conditions For superannuation purposes, organisations may wish to retain such records until the subject reaches benefit age
S
Positive predictive value performance indicators
3 years Destroy under confidential conditions
S
Private Finance Initiative (PFI) 30 years See note 1 S
Receipts 6 years after end of financial year to which they relate
Limitation Act 1980 Destroy under confidential conditions
S
Salaries (see Wages)
Records Management Policy Page 38 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Superannuation accounts 10 years Destroy under confidential conditions
S
Superannuation registers 10 years Destroy under confidential conditions
S
Tax forms 6 years Destroy under confidential conditions
S
Transport (staff pool car documentation) 3 years unless litigation ensues
Destroy under confidential conditions
S
Trust documents without permanent relevance/not otherwise mentioned
6 years Destroy under confidential conditions
S
Trusts administered by Strategic HealthAuthorities (terms of)
30 years See note 1 S
VAT records 6 years after end of financial year to which they relate
Destroy under confidential conditions
S
Records Management Policy Page 39 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Wages/salary records 10 years after termination of employment
Destroy under confidential conditions For superannuation purposes, organisations may wish to retain such records until the subject reaches benefit age
S
Records Management Policy Page 40 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
IM & T
Documentation relating to computer programmes written in-house
Lifetime of software Destroy under confidential conditions
S
Software licences Lifetime of software Destroy under confidential conditions
S
Research and development (organisation) i.e. all the organisation’s records associated with research and development and not individual trial records or information on patients.
30 years Medical Research Council
See note 1 N
Records Management Policy Page 41 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
PERSONNEL/HUMAN RESOURCES
NB Both medical staff records and agency locums staff records should be treated as personnel records and retained accordingly.
CVs for non-executive directors (successful applicants)
5 years following term of office
Destroy under confidential conditions
S
CVs for non-executive directors (unsuccessful applicants)
2 years Destroy under confidential conditions
S
Industrial relations (not routine staff matters), including industrial tribunals
10 years Destroy under confidential conditions
S
Job advertisements 1 year Destroy S
Job applications (successful) 3 years following termination of employment
Destroy under confidential conditions
S
Job applications (unsuccessful) 1 year Destroy under confidential conditions
S
Job descriptions 3 years Destroy under confidential conditions
S
Records Management Policy Page 42 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Leavers’ dossiers
6 years after individual has left Summary to be retained until individual’s 70th birthday or until 6 years after cessation of employment if aged over 70 years at the time. The summary should contain everything except attendance books, annual leave records, duty rosters, clock cards, timesheets, study leave applications, training plans
The 6 year retention period is to take into account any ET claims, or EL claims that may arise after the employee leaves NHS employment, requests for information from the NHS pensions agency etc. Claims of this nature can include periods of up to 6 years or more prior to the claim and where evidence could be needed from a number of sources, it is appropriate to retain as much as possible from the original file.
Destroy under confidential conditions See note 1
N
Letters of appointment
6 years after employment has terminated or until 70th birthday, whichever is later
Destroy under confidential conditions
S
Records Management Policy Page 43 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Pension Forms (all) 7 years
HMRC Technical Pension Notes for registered pension schemes under regulation 18 of SI2006/567 – ‘RPSM1 2300020 – Scheme Adminstrator Information Requirements and Adminstration for General Retention of Records’
Destroy under confidential conditions
N
Records Management Policy Page 44 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Personnel/human resources records –major (eg personal files, letters of appointment, contracts, references and related correspondence, registration authority forms, training records, equal opportunity monitoring forms (if retained)) NB Includes locum doctors
6 years after individual leaves service, at which time a summary of the file must be kept until the individual’s 70th birthday Summary to be retained until individual’s 70th birthday or until 6 years after cessation of employment if aged over 70 years at the time. The summary should contain everything except attendance books, annual leave records, duty rosters, clock cards, timesheets, study leave applications, training plans
The 6 year retention period is to take into account any ET claims, or EL claims that may arise after the employee leaves NHS employment, requests for information from the NHS pensions agency etc. Claims of this nature can include periods of up to 6 years or more prior to the claim and where evidence could be needed from a number of sources, it is appropriate to retain as much as possible from the original file.
See note 1 N
Records Management Policy Page 45 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Personnel/human resources records – minor (eg attendance books, annual leave records, duty rosters (i.e. duty rosters held on the individual’s record not the organisation or departmental rosters), clock cards, timesheets (relating to individual staff members)) NB Includes locum doctors
2 years after the year to which they relate
Destroy under confidential conditions
N
Staff car parking permits 3 years Destroy under confidential conditions
S
Study leave applications 5 years Destroy under confidential conditions
S
Records Management Policy Page 46 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Timesheets (for individual members of staff)
2 years after the year to which they relate NB Timesheets (for all individuals including locum doctors) held on the personnel record are minor records – retain for 2 years. Timesheets held elsewhere – i.e. on the ward retain for 6 months (as the master timesheet is held on the personnel file)
Destroy under confidential conditions
N
Training plans 2 years Destroy under confidential conditions
S
Records Management Policy Page 47 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
PURCHASING/SUPPLIES
Approval files (contracts) 6 years after end of the year the contract expired
Destroy under confidential conditions
S
Approved suppliers lists 11 years Consumer Protection Act 1987
Destroy under confidential conditions
S
Delivery notes 2 years after end of financial year to which they relate
Destroy under confidential conditions
S
Products (liability) 11 years Consumer Protection Act 1987
Destroy under confidential conditions
S
Stock control reports 18 months Destroy under confidential conditions
S
Stores records – major (eg stores ledgers) 6 years Destroy under confidential conditions
S
Stores records – minor (eg requisitions, issue notes, transfer vouchers, goods received books)
18 months Destroy under confidential conditions
S
Records Management Policy Page 48 of 48
TYPE/SUBTYPE OF RECORD MINIMUM RETENTION PERIOD
DERIVATION FINAL ACTION CODE
Supplies records – minor (eg invitations to tender and inadmissible tenders, routine papers relating to catering and demands for furniture, equipment, stationery and other supplies)
18 months Destroy under confidential conditions
S
Tenders (successful) Tender period plus 6 year limitation period
Limitation Act 1980 Destroy under confidential conditions
S
Tenders (unsuccessful) 6 years Limitation Act 1980 Destroy under confidential conditions
S