CORPORATE RECORDS AND RETENTION POLICY Policy for the … · 2014-02-11 · guide based on best practice, and therefore followed for all corporate (non-clinical) records. 1.1.4 Ensuring

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CORPORATE RECORDS AND RETENTION POLICY

Policy for the local management of the

Records Management: NHS Code of Practice

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Version Version 2.0

Knowsley Clinical Commissioning Group Governing Body Ratified By Date Ratified 6th February 2014

Author

Suzanne Crutchley Senior Governance Manager (Information Governance)Cheshire & Merseyside Commissioning Support Unit Telephone: 01244 650551 Email: [email protected]

Responsible Committee / Officers

Knowsley Clinical Commissioning Group: Audit Committee

Date Issue March 2013

Review Date March 2015

Intended Audience All CCG staff

Impact Assessed Yes

Further information about this document: Document name

Corporate Records and Retention Policy Policy for the local management of the Records Management: NHS Code of Practice

Category of Document in The Policy Schedule

Corporate

Contact for further information about this document

Dawn Boyer Head of Corporate Services Telephone: 0151 244 3149 Email: [email protected]

This document should be read in conjunction with

• Information Governance Strategy

• Information Governance Policy

• Freedom of Information Policy

Published by Knowsley Clinical Commissioning Group

Copies of this document are available from

Website: www.knowsleyccg.nhs.uk

Version Control: Version History: Version Number Reviewing Committee / Officer Date

1.0 Knowsley Clinical Commissioning Group Governing Body 21 March 2013

1.1 Information Governance Management Group (the inclusion of Lay Members and Governing Body members at 3.2 and equivalent post holders at 5.3 and other minor changes and updates, including to names and contact details. Note no changes made to the Annex)

4 November 2014

1.2 Audit Committee reviewed and approved 9th

December

mailto:[email protected]

mailto:[email protected]

http://www.knowsleyccg.nhs.uk/

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2013

2.0 Governing Body 6 February 2014 Please note that this Policy is based on the current equivalent for the NHS Business Services Authority, and the Records Management: NHS Code of Practice.

Contents

Section Page

1. INTRODUCTION AND PURPOSE ......................................................................4

2. KEY PERFORMANCE INDICATORS .................................................................8

3. SCOPE OF THE POLICY....................................................................................8

4. OBJECTIVES OF THE POLICY..........................................................................8

5. ROLES AND RESPONSIBILITIES .....................................................................9

6. MONITORING RECORDS MANAGEMENT PERFORMANCE ........................10

7. LEGAL AND PROFESSIONAL OBLIGATIONS...............................................11

8. NHS CONNECTING FOR HEALTH ..................................................................11

9. RECORD CREATION .......................................................................................11

10. INFORMATION QUALITY ASSURANCE .....................................................12

11. RECORD KEEPING ......................................................................................12

12. RECORD MAINTENANCE ............................................................................13

13. DISCLOSURE AND TRANSFER OF RECORDS..........................................13

14. RETENTION AND DISPOSAL ARRANGEMENTS .......................................14

15. APPRAISAL OF RECORDS..........................................................................14

16. RECORD CLOSURE .....................................................................................14

17. RECORD DISPOSAL ....................................................................................14

18. INFORMATION LIFECYCLE MANAGEMENT ..............................................15

Annex: Records Retention Schedule ....................................................................16 The following terms are used in this document

Information Governance Information Governance is a framework to bring together all the legal rules, guidance and best practice that apply to the handling of information.

Glossary of Records Management Terms

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Full descriptions of all the terms used in the Records Management: NHS Code of Practice are listed in full in the Code, available at: http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuid ance/DH_4131747

1. Introduction and Purpose 1.1 Introduction

1.1.1 NHS organisations have a statutory duty to make arrangements for the

safekeeping and eventual disposal of their records.

1.1.2 The primary function of the Policy is to improve the management of all types of NHS records, with regard to their preservation, retention and destruction.

1.1.3 The suggested retention periods should be taken by NHS organisations to be a

guide based on best practice, and therefore followed for all corporate (non-clinical) records.

1.1.4 Ensuring local application of this Policy and its supporting guidelines and

procedures, is the responsibility of all staff.

1.2 Executive Summary

1.2.1 The Corporate Records and Retention Policy for the Clinical Commissioning Group (CCG) sets out the requirements of all staff when managing the retention of records. The Policy is supported by substantial guidelines and procedures, which give further details of how to comply with the actual Policy.

1.2.2 Staff should treat this Policy as guidance based on best practice for managing corporate records. In general terms, this Policy covers all records (documents), which the CCG has produced.

1.2.3 The records management function is recognised as a specific corporate responsibility within the CCG. It provides a managerial focus for records of all types in all formats, including electronic records, throughout their life cycle, from planning and creation through to ultimate disposal. All confidential papers will be disposed of by shredding.

1.2.4 Clearly defined responsibilities and objectives are set out below, and the CCG is committed to ensure adequate resources to achieve them.

1.2.5 This Policy should be read in conjunction with the following CCG Policies:

a) Information Governance Strategy b) Information Governance Policy c) Freedom of Information Policy

http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_4131747



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1.2.6 Archiving of corporate paper documents will be carried out in line with the CCG arrangements in place, which will be reviewed over time as the CCG develops.

1.3 Foreword

1.3.1 This Policy has been produced in light of the requirements of the Records Management: NHS Code of Practice, and should be read in conjunction with the full Code. To download a copy of the Code of Practice please follow this link http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyA ndGuidance/DH_4131747

1.3.2 The Records Management: NHS Code of Practice has been published by the Department of Health as 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. The Code of Practice (referred to as the Code) is a guide to the standards of practice required in the management of NHS records, based on current legal requirements and professional best practice. The guidance applies to all NHS records and contains details of the recommended minimum retention period for each record type.

1.3.3 This Policy supports, amongst others, the Data Protection Act 1998 and the

Freedom of Information Act 2000.

1.3.4 The life of this Policy will be subject to controlled amendments ensuring it remains appropriate as the business, technology and legislation change. This Policy and its supporting guidelines and procedures will be regularly reviewed and compliance with them monitored through Risk Management and Information Governance Assurance procedures. The policy will be reviewed at regular intervals (at least once every two years) and, if appropriate, it will be amended to maintain its currency and relevance.

1.4 Types of record covered by the Code of Practice

1.4.1 The guidelines contained in the Code of Practice apply to NHS records of all

types, regardless of the media on which they are held. These may consist of:

a) Administrative records (including, for example, personnel, estates, financial and accounting records; notes associated with complaint-handling);

b) Photographs, slides, and other images; c) Microform (i.e. microfiche/microfilm); d) Audio and video tapes, cassettes, CD-ROM etc; e) E-mails; f) Computerised records; g) Paper records; h) Scanned records;




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i) Text messages (both outgoing from the NHS and incoming responses).

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1.5 Background and general context

1.5.1 The Records Management: NHS Code of Practice replaces previous guidance as listed below:

a) HSC 1999/053 – For the Record. b) HSC 1998/217 – Preservation, Retention and Destruction of GP General

Medical Services Records Relating to Patients (Replacement for FHSL (94)(30))

c) HSC 1998/153 – Using Electronic Patient Records in Hospitals: Legal Requirements and Good Practice.

1.5.2 Records are a valuable resource because of the information they contain. High-

quality information underpins the delivery of high-quality evidence-based healthcare, and many other key service deliverables. Information has most value when it is accurate, up to date and accessible when it is needed. An effective records management service ensures that information is properly managed and is available whenever and wherever there is a justified need for that information, and in whatever media it is required. Information may be needed:

a) to support patient care and continuity of care; b) to support day-to-day business which underpins the delivery of care; c) to support evidence-based clinical practice; d) to support sound administrative and managerial decision making, as part of

the knowledge base for NHS services; e) to meet legal requirements, including requests under subject access

provisions of the Data Protection Act or the Freedom of Information Act; f) to assist clinical and other types of audits; g) to support improvements in clinical effectiveness through research and also to

support archival functions by taking account of the historical importance of material and the needs of future research; or

h) to support patient choice and control over treatment and services designed around patients.

1.5.3 The Code of Practice identifies the specific actions, managerial responsibilities,

and minimum retention periods for the effective management of all types of NHS records (i.e. both corporate and health records) from creation, as well as day-to- day use of records, and storage, maintenance and ultimate disposal procedures.

1.6 Policy and Strategy

1.6.1 The CCG policy on how it manages all of its records, including electronic records

is approved by the Governing Body and will be made readily available to all staff at all levels of the CCG, both on induction and through regular update training.

1.6.2 The policy sets out the CCG’s commitment to create, keep and manage records

and document its principal activities in this respect.

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1.6.3 The policy also:

a) outlines the role of records management within the CCG, and its relationship to the CCG’s overall strategy;

b) defines roles and responsibilities within the CCG, including the responsibility of individuals to document their actions and decisions in the CCG’s records, and to dispose of records appropriately when they are no longer required;

c) provides a framework for supporting standards, procedures and guidelines; and

d) indicates the way in which compliance with the policy and its supporting standards, procedures and guidelines will be monitored and maintained.

2. Key Performance Indicators

2.1 The following key performance indicators have been identified to measure the effectiveness of this document:

a) staff will know where to access the document; b) staff will know how to archive documents; c) policy to be reviewed by the review date.

3. Scope of the Policy

3.1 This Policy applies to all employees of the CCG, both permanent and temporary.

3.2 It also applies to anyone contracted to the CCG, who, in the course of their work is required to create and/or access corporate records normally restricted to directly employed staff. This includes Lay Members and Governing Body members.

4. Objectives of the Policy

4.1 NHS Records Management

4.1.1 The aims of the NHS Code of Practice are:

a) to establish an Information Governance framework for NHS records management in relation to the creation, use, storage, management and disposal of all types of records;

b) to clarify the legal obligations that apply to NHS records; c) to explain the actions required by the CCG senior managers to fulfil these

obligations; d) to explain the requirement to select records for permanent preservation; e) to set out recommended minimum periods for retention of all types of NHS

records, regardless of the media on which they are held; and f) to indicate where further information on records management may be found.

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4.2 Corporate Records and Retention Policy

4.2.1 The objectives of this Policy are to:

a) Make all staff aware of their responsibilities for the retention of corporate records.

b) Introduce a retention schedule for the CCG’s corporate records. c) Create a controlled environment and formal methods of destruction of

corporate records.

5. Roles and Responsibilities

5.1 The Accountable Officer is personally accountable for records management within the CCG and has a duty to make arrangements for the safekeeping of those records. Each CCG Department must have a comprehensive records management programme which includes cost-effective management of non-current as well as active records, and which takes account of ‘Risk Management’ principles.

5.2 The Head of Corporate Services (as Information Governance Lead) will have lead responsibility for Records Management within the CCG.

5.3 Senior Managers must give their full backing to all the guidelines and procedures as set out and agreed. Senior Managers must also take responsibility to ensure that:

a) All new staff will receive training/guidance in the retention of records, within

one month of joining the CCG. b) All existing staff are made aware of their responsibilities. c) There are adequate disposal arrangements for confidential waste, which all

staff abide by. d) There are adequate storage facilities for back-up media and other storage

devices, which contain person identifiable information and sensitive/confidential corporate/staff information.

5.4 All line managers and supervisors must ensure that their staff are adequately trained and apply the appropriate guidelines.

5.5 The Caldicott Guardian is responsible within the CCG for approving and ensuring that national and local guidelines and protocols on the handling and management of confidential patient information are in place.

5.6 The Senior Information Risk Owner (SIRO) is responsible within the CCG for approving and ensuring that national and local guidelines and protocols on the handling and management of confidential corporate information and person identifiable information (non-patient) are in place.

5.7 Each individual has a key role to play in effective record keeping. Everyone working for or with the NHS who records, handles, stores, or otherwise comes across information

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has a personal responsibility to apply the appropriate guidelines for the retention and eventual destruction of information.

5.8 Under the Public Records Act all NHS employees are responsible for any records that they create or use in the course of their duties. Thus any records created by an employee of the NHS are public records and may be subject to both legal and professional obligations. A description of these obligations can be found in Annex C of the Code.

5.9 It is essential that the manager(s) responsible for the records management function will work in close association with the manager(s) responsible for freedom of information, data protection and other information governance work areas.

5.10 All staff, whether clinical or administrative, must be appropriately trained so that they are fully aware of their personal responsibilities in respect of record keeping and records management, and that they are competent to carry out their designated duties. This should include training for staff in the use of electronic records systems. It should be done through both generic and specific training programmes, complemented by CCG policies and procedures and guidance documentation.

5.11 Corporate records are core resources for the CCG. They must be properly formatted, produced consistently, safeguarded and used efficiently, and all staff (managerial, administrative, professional and medical) must follow this Policy and its supporting guidelines and procedures.

5.12 All NHS records are public records under the terms of the Public Records Act 1958 sections 3 (1)–(2). The Secretary of State for Health and all NHS organisations have a duty under the Public Records Act to make arrangements for the safe keeping and eventual disposal of all types of their records. This is carried out under the overall guidance and supervision of the Keeper of Public Records, who is answerable to Parliament.

5.13 Directors (and equivalent post holders) and Senior Managers of all NHS organisations are personally accountable for records management within their organisation. NHS organisations are also required to take positive ownership of, and responsibility for, the records legacy of predecessor organisations and/or obsolete services.

5.14 In addition, NHS organisations need robust records management procedures to meet the requirements set out under the Data Protection Act 1998 and the Freedom of Information Act 2000.

6. Monitoring Records Management Performance 6.1 A number of bodies monitor NHS performance in respect of records management. The Audit Commission regularly conducts studies into records management and related information quality issues. The Department of Health collects performance details as part of the annual Information Governance Toolkit assessment and these will inform the work

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of both the Healthcare Commission and the Audit Commission. The NHS Litigation Authority also undertakes a risk assessment survey as an integral part of the Clinical Negligence Scheme for Trusts (CNST).

6.2 Other bodies likely to comment on records management performance include the Information Commissioner when investigating alleged breaches of Data Protection or Freedom of Information legislation or in promoting the Lord Chancellor’s Code of Practice on Records Management under section 46 of the Freedom of Information Act.

7. Legal and Professional Obligations

7.1 All individuals who work for an NHS organisation are responsible for any records which they create or use in the performance of their duties. Furthermore, any record that an individual creates is a public record.

7.2 The key statutory requirement for compliance with records management principles is the Data Protection Act 1998, where personal information is held. It provides a broad framework of general standards that have to be met and considered in conjunction with other legal obligations. The Act regulates the processing of personal data, held both manually and on computer. It applies to personal information generally, not just to health records. Therefore the same principles apply to records of employees and contract workers held by employers, for example in finance, personnel and occupational health departments.

8. Health and Social Care Information Centre

8.1 The impact of the Government’s health reform agenda will fundamentally affect the way the NHS approaches the management of all electronic records. The NHS Care.Data and other initiatives are central to these reforms and will transform the way both health and social care information is managed.

9. Record Creation

9.1 Records of operational activities should be complete and accurate in order to allow employees and their successors to undertake appropriate actions in the context of their responsibilities, to facilitate an audit or examination of the CCG by anyone so authorised, to protect the legal and other rights of the CCG, its staff and any other people affected by its actions, and provide authentication of the records so that the evidence derived from them is shown to be credible and authoritative.

9.2 Records created by the CCG should be in Corporate House Style and arranged in a record-keeping system that will enable the CCG to obtain the maximum benefit from the quick and easy retrieval of information. The CCG’s records will be created and stored on the CCG’s network and/or intranet.

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10. Information Quality Assurance 10.1 It is important that all NHS organisations train staff appropriately and provide regular update training. In the context of records management and information quality, organisations need to ensure that their staff are fully trained in record creation, use and maintenance, including having an understanding of:

a) what they are recording and how it should be recorded; b) why they are recording it; c) how to validate information against other records – to ensure that staff are

recording the correct data; d) how to identify and correct errors – so that staff know how to correct errors

and how to report errors if they find them; e) the use of information – so staff understand what the records are used for (and

therefore why timeliness, accuracy and completeness of recording is so important); and

f) how to update information and add in information from other sources. 10.2 Implementing and maintaining an effective records management service depends on knowledge of what records are held, where they are stored, who manages them, in what format(s) they are made accessible, and their relationship to organisational functions (for example finance, IT, HR). A Department information survey or record audit is essential to meeting this requirement. This survey will also help to enhance control over the records, and provide valuable data for developing records appraisal and disposal policies and procedures.

10.3 Paper and electronic record keeping systems should conform to the Corporate House Style and should contain descriptive and technical documentation to enable the system to be operated efficiently and the records held in the system to be understood. The documentation should provide an administrative context for effective management of the records.

10.4 The record keeping system should either adhere to the Corporate House Style or should include a documented set of rules for referencing, titling, indexing and, if appropriate, the protective marking of records. These should be easily understood to enable the efficient retrieval of information when it is needed and to maintain security and confidentiality.

11. Record Keeping

11.1 The movement and location of records should be controlled to ensure that a record can be easily retrieved at any time, that any outstanding issues can be dealt with, and that there is an auditable trail of record transactions.

11.2 Storage accommodation for current records should be clean and tidy, should prevent damage to the records and should provide a safe working environment for staff.

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11.3 For records in digital format, maintenance in terms of back-up and planned migration to new platforms should be designed and scheduled to ensure continuing access to readable information.

11.4 Equipment used to store current records on all types of media should provide storage that is safe and secure from unauthorised access and which meets health and safety and fire regulations, but which also allow maximum accessibility of the information commensurate with its frequency of use.

11.5 When paper records are no longer required for the conduct of current business, their placement in a designated secondary storage area may be a more economical and efficient way to store them. Procedures for handling records should take full account of the need to preserve important information and keep it confidential and secure. There should be archiving procedures in place for both paper and electronic records.

11.6 A contingency or business continuity plan should be in place to provide protection for all types of records that are vital to the continued functioning of the CCG. Key expertise in relation to environmental hazards, assessment of risk, business continuity and other considerations is likely to rest with information security staff and their advice should be sought on these matters.

12. Record Maintenance 12.1 For reasons of business efficiency or in order to address problems with storage space, NHS organisations may consider the option of scanning into electronic format records which exist in paper format. Where this is proposed, the factors to be taken into account should be taken from the Code.

13. Disclosure and Transfer of Records

13.1 There are a range of statutory provisions that limit, prohibit or set conditions in respect of the disclosure of records to third parties, and similarly, a range of provisions that require or permit disclosure. The key statutory requirements can be found in Annex C of the Code. Designated staff within the CCG have special expertise in, or can advise on, particular types of disclosure e.g. the Caldicott Guardian and the Senior Information Risk Owner.

13.2 The mechanisms for transferring records from one organisation to another should also be tailored to the sensitivity and confidentiality of the material contained within the records and the media on which they are held. Information Security staff can advise on appropriate safeguards.

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14. Retention and Disposal Arrangements 14.1 Detailed guidance on retention periods for a full range of NHS personal health and different types of business and corporate records is provided in Annex D of the Code.

14.2 It is particularly important under freedom of information legislation that the disposal of records – which is 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 the CCG and which are enforced by properly trained and authorised staff.

14.3 Archiving of corporate paper documents will be carried out in line with the CCG arrangements in place.

15. Appraisal of Records

15.1 Appraisal refers to the process of determining whether records are worthy of permanent archival preservation. This should be undertaken in consultation with the CCG Managers who have ‘records management’ responsibilities.

15.2 The retention schedules in Annex D of the Code outline the recommended minimum retention periods for all types of NHS records. The purpose of this appraisal process is to ensure that the records are examined at the appropriate time to determine whether or not they are worthy of archival preservation, whether they need to be retained for a longer period as they are still in use, or whether they should be destroyed.

16. Record Closure

16.1 Records should be closed (i.e. made inactive and transferred to secondary storage) as soon as they have ceased to be in active use other than for reference purposes.

16.2 An indication that a file of paper records or folder of electronic records has been closed, together with the date of closure, should be shown on the record itself as well as noted in the index or database of the files/folders.

16.3 Where possible, information on the intended disposal of electronic records should be included in the metadata when the record is created.

17. Record Disposal

17.1 The CCG retention/disposal schedule is taken from the retention schedules contained in the Code. The CCG schedule covers all records held by the CCG, including electronic records.

17.2 In the event of any records selected for archival preservation and no longer in regular use by the CCG, these will be transferred as soon as possible to an archival institution (for

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example a Place of Deposit – see Annex E of the Code) that has adequate storage and public access facilities.

17.3 It is the responsibility of the CCG to ensure that the methods used throughout the destruction process provide adequate safeguards against the accidental loss or disclosure of the contents of the records. Most NHS records are confidential records. All confidential papers will be disposed of by shredding.

17.4 A record of the destruction of records, showing their reference, description and date of destruction will be maintained and preserved by the nominated Records Manager, so that the CCG is aware of those records that have been destroyed and are therefore no longer available. Disposal schedules will constitute the basis of such a record.

17.5 If a record due for destruction is known to be the subject of a request for information, or potential legal action, destruction should be delayed until disclosure has taken place or, if the authority has decided not to disclose the information, until the complaint and appeal provisions of the Freedom of Information Act 2000 have been exhausted or the legal process completed.

18. Information Lifecycle Management

18.1 Information Lifecycle Management is included within this Corporate Records and Retention Policy.

18.2 All NHS records produced are subject to a range of legislation, including the Data Protection Act 1998, the Freedom of Information Act 2000 and the Environmental Information Regulations 2004.

18.3 Information Lifecycle Management guides staff on the appropriate manner for the creation, storage, maintenance, use, archiving and disposal of it corporate records.

18.4 It is important that employees recognise information security issues arising from the storage of person identifiable data (PID) and that they continue to use information in accordance with the Data Protection and Freedom of Information Acts, and the NHS Records Management Code of Practice.

18.5 For broader guidance on corporate records management, this statement should be read in conjunction with the following policies:

a) Freedom of Information Policy (which includes the Environmental Information

Regulations 2004) b) Information Governance Strategy

18.6 The Caldicott Guardian continues to be responsible for protecting patients’ interests regarding the use of patient identifiable information. They are responsible for ensuring that patient identifiable information is shared in a secure and responsible manner.

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18.7 The Senior Information Risk Owner (SIRO) continues to be responsible for ensuring that identified information threats are followed up and risks managed.

Annex 1 : Records Retention Schedule 1.0 The following is taken from the Records Management: NHS Code of Practice Annex D2: Business and Corporate (Non-Health) Records Retention Schedule available at:

http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/documents/digitalasset/dh _093028.pdf

1.1 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 (see Note below) 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.

1.2 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):

a) administrative records (including personnel, estates, financial and accounting b) records, and notes associated with complaint handling) c) photographs, slides and other images (non-clinical) d) microform (i.e. microfiche/microfilm) e) audio and video tapes, cassettes, CD-ROMs, etc f) e-mails g) computerised records; and h) scanned documents

1.3 The schedule is split into the following types of records:

a) Administrative (corporate and organisation) b) Biomedical Engineering c) Estates/engineering d) Financial e) IM & T f) Other g) Personnel/human resources h) Purchasing/supplies

Notes

1.4 Where an organisation has an existing relationship with an approved Place of Deposit, it should consult the Place of Deposit in the first instance. Where there is no pre-existing relationship with a Place of Deposit, organisations should consult The National Archives.

1.5 The coding below denotes the status of the type of record and its retention period:

http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/documents/digitalasset/dh_093028.pdf

http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/documents/digitalasset/dh_093028.pdf

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a) C = a previously existing record type (i.e. referenced in the previous retention schedule dated March 2006) but a Change to the retention period.

b) N =a New record type (either not referenced in the previous retention schedule or

a more explicit description of a record type than previously published). c) S = a previously existing record type, with the Same retention period.

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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)


C

Adoption records (i.e. administrative records relating the adoption process)

75th anniversary of the date of birth of the child to whom it relates or, if the child dies before attaining the age of 18,15 years beginning with the date of the 18th birthday

Children and Young Persons Arrangements for Placement of Children (General) (Regulations 1991,SI 1991, No. 890 regs. 8, 9, 10 – children’s records) Adoption Regulations 2004(reg. 34)


N

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DERIVATION

FINAL ACTION

CODE

Advance letters (e.g. 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


S

Agreements (see Contracts)

Ambulance Records – Administrative (i.e. records containing non-clinical details only) e.g. records of journeys

2 years from the end of the year to which they relate


N

Annual/corporate reports

3 years

See note 1

S

Appointment Records (GP)

2 years (Provided that any patient-relevant information has

Destroy under confidential

N

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DERIVATION

FINAL ACTION

CODE

been transferred to the patient record) At the end of the 2 year retention period GP practices should consider if there is an on-going administrative need to keep the records/books for longer. If there IS an on-going need to retain these records/books, then a further review date should be set (either 1 or 2 more years)

conditions – once a decision has been made that there is no on-going administrative need to retain the records.

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

S

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DERIVATION

FINAL ACTION

CODE

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 they must be destroyed under confidential conditions.

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


N

Business plans, including local delivery plans

20 years

Destroy

S

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DERIVATION

FINAL ACTION

CODE

Catering forms

6 years


S

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


S S

Complaints (See also litigation dossiers) Correspondence, investigation and outcomes Returns made to DH

8 years from completion of action Files closed annually and kept for 6 years following closure NB: Current policy on the handling of complaints is under review and further guidance will be issued in due course


C

Copyright declaration forms (Library Service)

6 years

Copyright, Designs and Patents Act 1988


N

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DERIVATION

FINAL ACTION

CODE

conditions

Data Input Forms (where the data/information has been input to a computer system)

2 years


N

Diaries (office)

1 year after the end of the calendar year to which they refer


S

Exposure monitoring records

5 years from the date the record was made

Control of Substances Hazardous to Health Regulations 2002 (reg. 10(5))


S

’Find-a-Doc’ records (kept by PCT’s) contact sheets and letters assignment cases/letters records of negotiations with GMS contract managers re: patient registration with a GP

6 months 2 years 2 years


N

Flexi working hours (personal record of hours actually worked)

6 months


S

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DERIVATION

FINAL ACTION

CODE

Freedom of Information requests

3 years after full disclosure; 10 years if information is redacted or the information requested is not disclosed


S

GMS1 forms (registration with GP)

3 years


S

Health and safety documentation

3 years


S

History of organisation or predecessors, its organisation and procedures (e.g. establishment order)

30 years

See note 1

S

Hospital (trust) services i.e. service that the Trust provides e.g. catering, hotel services

10 years

Destroy

S

Incident forms

10 years

Destroy under

C

25



DERIVATION

FINAL ACTION

CODE

confidential conditions

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

Laundry lists and receipts

2 years from completion of audit


S

Library registration forms

2 years after registration

Destroy

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


S S

Manuals – policy and procedure

10 years after life of the system

Destroy

S

26



DERIVATION

FINAL ACTION

CODE

(administrative and clinical, strategy documents)

(or superseded) to which the policies or procedures refer

(policy documents may have archival value – see note 1)

Maps

Lifetime of the organisation

See note 1

S

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


S

Mental Health Act Administration Records

5 years NB There is no obligation to treat this type of mental health record as being part of a patient’s health record. There may, however, be exceptions, such as where they are required to be kept as evidence

HC(91)29 (NHS) SI 2001/3869, reg.47 (Independent Sector)


N

27



DERIVATION

FINAL ACTION

CODE

in actual or expected litigation or where they are needed by a healthcare professional in order to provide healthcare. Each healthcare practitioner has discretion as to the information which s/he wishes to include as part of a patient record. If in any particular case a healthcare practitioner requires a document which forms part of the mental health act administration record to be included in a patient’s record (because he or she regards it as relevant to the patient’s healthcare), it should then be regarded as part of the patient’ health record

Mortgage documents (acquisition, transfer and disposal)

6 years after repayment

See note 1

S

Nominal rolls

6 years (maximum)


S

28



DERIVATION

FINAL ACTION

CODE

Papers of minor or short-lived importance not covered elsewhere, e.g.: 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


S

Patient Advice & Liaison Service (PALS) records

10 years after closure of the case


N

Patient information leaflets

6 years after the leaflet has

See note 1

C

29



DERIVATION

FINAL ACTION

CODE

been superseded

Patients’ property books/registers (property handed in for safekeeping)

6 years after the end of the financial year in which the property was disposed of or 6 years after the register was closed


S

Patient Surveys (re access to services etc)

2 years


N

Phone Message Books

2 years NB Any clinical information should be transferred to the patient health record


N

Police Statements (made in the context of Accident and Emergency episodes. Statements are requested by the Police to the A&E staff in relation to alleged injuries of or by patients coming through A&E)

10 years (congruent retention period as Incident Forms)


N

Press cuttings

1 year

Destroy

S

30



DERIVATION

FINAL ACTION

CODE

(where bound volumes exist, see note 1)

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


S

Project team files (summary retained)

3 years


S

Public Consultations e.g. about future provision of services

5 years


N

31



DERIVATION

FINAL ACTION

CODE

Quality and Outcomes Framework (QOF) documents (GP Practice records)

2 years


N

Quality assurance records (e.g. Healthcare Commission, Audit Commission, King’s Fund Organisational Audit, Investors in People)

12 years


S

Receipts for registered and recorded mail

2 years following the end of the financial year to which they relate


S

Records documenting the archiving, transfer to public records archive or destruction of records

30 years

See note 1

S

Records of custody and transfer of keys

2 years after last entry


S

32



DERIVATION

FINAL ACTION

CODE

conditions

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


S

Requisitions

18 months


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 (e.g. equipment, services)

6 years

Limitation Act 1980


S

33



DERIVATION

FINAL ACTION

CODE

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


S

Surgical appliances forms AP 1, 2, 3 and 4



S

Time sheets (relating to a Group or Department e.g. Ward where the timesheets are kept as a tool to manage resources, staffing levels)

6 months


N

BIOMEDICAL ENGINEERING

Sterilix Endoscopic Disinfector Daily

11 years

Consumer Protection Act

Destroy under

N

34



DERIVATION

FINAL ACTION

CODE

Water Cycle Test,

1987


Sterilix Endoscopic Disinfector Daily Water Purge Test, Nynhydrin Test

11 years

Consumer Protection Act 1987


N

ESTATES/ENGINEERING

Buildings and engineering works, including major projects abandoned or deferred – key records (e.g. 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 (e.g. executed agreements, conditions of contract, specifications, ’as built’ record drawings, documents on the appointment and conditions of

30 years

See note 1

S

35



DERIVATION

FINAL ACTION

CODE

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


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

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

36



DERIVATION

FINAL ACTION

CODE

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



N

Inspection reports (e.g. 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

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

37



DERIVATION

FINAL ACTION

CODE

Leases – the grant of leases, licences and other rights over property

Period of the lease plus 12 years

Limitation Act 1980


S

Maintenance contracts (routine)

6 years from end of contract


S

Manuals (operating)

Lifetime of equipment

Review if issues (e.g. HSE) are outstanding

S

Medical device alerts

Retain until updated or withdrawn (check MHRA website)

www.mhra.gov.uk


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

http://www.mhra.gov.uk/

38



DERIVATION

FINAL ACTION

CODE

Plans – building (detailed)


May have historical value (see note 1)

S

Plans – engineering


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


See note 1

C

39



DERIVATION

FINAL ACTION

CODE

Surveys – building and engineering works

Lifetime of building or installation

See note 1

S

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)



S

Accounts – working papers



S

40



DERIVATION

FINAL ACTION

CODE

Advice notes (payment)

1.5 years


S

Audit records (internal and external audit) – original documents



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


N

Bank statements



S

Banks Automated Clearing System (BACS) records

6 years after year end


S

Benefactions (records of)

5 years after end of financial year in which the trust monies become finally spent or the gift

See note 1

S

41



DERIVATION

FINAL ACTION

CODE

in kind is accepted. In cases where the Benefaction Endowment Trust fund/capital/interest remains permanent, records should be permanently retained by the organisation

Bills, receipts and cleared cheques

6 years


S

Budgets (including working papers, reports, virements and journals)



S

Capital charges data



S

Capital paid invoices (see Invoices)

Cash books

6 years after end of financial

Limitation Act 1980

Destroy under

S

42



DERIVATION

FINAL ACTION

CODE

year to which they relate


Cash sheets

6 years after end of financial year to which they relate

Limitation Act 1980


S

Contracts – financial

Approval files – 15 years Approved suppliers lists – 11 years


C

Contracts – non-sealed (property) on termination

6 years after termination of contract

Limitation Act 1980


S

Contracts – non-sealed (other) on termination

6 years after termination of contract

Limitation Act 1980


S

Contracts – sealed (and associated records)

Minimum of 15 years, after which they should be reviewed

See note 1

S

43



DERIVATION

FINAL ACTION

CODE

Contractual arrangements with hospitals or other bodies outside the NHS, including papers relating to financial settlements made under the contract (e.g. waiting list initiative, private finance initiative)



S

Cost accounts



S

Creditor payments



S

Debtors’ records – cleared



S

Debtors’ records – uncleared



S

44



DERIVATION

FINAL ACTION

CODE

Demand notes



S

Estimates, including supporting calculations and statistics



S

Excess fares



S

Expense claims, including travel and subsistence claims, and claims and authorisations



S

Fraud case files/investigations

6 years


S

Fraud national proactive exercises

3 years


S

45



DERIVATION

FINAL ACTION

CODE

Funding data



S

General Medical Services payments



S

Invoices


Limitation Act 1980


S

Ledgers, including cash books, ledgers, income and expenditure journals, nominal rolls, non- exchequer funds records (patient monies)


Limitation Act 1980


S

Non-exchequer funds records (i.e. funding received by the organisation that does not directly relate to patient care e.g. charitable funds)

30 years Company charities are required by company law to keep their accounts and accounting

Although technically exempt from the Public

N

46



DERIVATION

FINAL ACTION

CODE

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).

Records Act, it would be appropriate for authorities to treat these records as if they were not exempt

Patient Monies (i.e. smaller sums of donated money)

6 years


N

PAYE records

6 years after termination of employment


S

Payments



S

Payroll (i.e. list of staff in the pay of the organisation)



S

47



DERIVATION

FINAL ACTION

CODE

For superannuatio n purposes, organisations may wish to retain such records until the subject reaches benefit age

Positive predictive value performance indicators

3 years


S

Private Finance Initiative (PFI)

30 years

See note 1

S

Receipts


Limitation Act 1980


S

Salaries (see Wages)

Superannuation accounts

10 years

Destroy under

S

48



DERIVATION

FINAL ACTION

CODE


Superannuation registers

10 years


S

Tax forms

6 years


S

Transport (staff pool car documentation)

3 years unless litigation ensues


S

Trust documents without permanent relevance/not otherwise mentioned

6 years


S

Trusts administered by Strategic Health Authorities (terms of)

30 years

See note 1

S

49



DERIVATION

FINAL ACTION

CODE

VAT records



S

Wages/salary records


Destroy under confidential conditions For superannuatio n purposes, organisations may wish to retain such records until the subject reaches benefit age.

S

IM & T

Documentation relating to computer programmes written in-house

Lifetime of software


S

50



DERIVATION

FINAL ACTION

CODE

Software licences

Lifetime of software


S

OTHER

Chaplaincy records

2 years

May have archival value – see note 1

S

Contractor Applications (Doctors, Dentists, Opticians & Pharmacists)

6 years after end of contract for approvals 6 years for non-approvals.


N

Contractor Records (e.g. Ophthalmic Opticians, Ophthalmic Medical Practitioners, Pharmacists, Pharmacy Premises, General Optical Council amendments to the register, Previous Pharmacy rotas and supporting information (prior to 2005 – new regulations),

7 years

NHS(General Ophthalmic Services) Regs 1986: A contractor shall keep a proper record in respect of each patient to whom he provides general ophthalmic services,


N

51



DERIVATION

FINAL ACTION

CODE

Copies of previous Pharmacy and Ophthalmic local lists, Correspondence relating to pharmacies supplying oxygen and visiting Residential/Nursing homes (prior to new regulations)

giving appropriate details of sight testing. Subject to paragraph 8(5) a contractor shall retain all such records for a period of seven years, and shall during that period produce them when required to do so by a CCG or the Secretary of State. Follow link below for more detail http://www.dh.gov.uk/ass etRoot/04/10/12/ 42/04101242.pdf

Doctors Postgraduate Educational Allowance/ Personal Development Plan files and supporting general correspondence – Records kept by PCT’s

GP Seniority (prior to 2004 – new regulations)

NHS(General Ophthalmic Services) Regs 1986: A contractor shall keep a proper record in respect of each patient to whom he provides general ophthalmic services, giving appropriate details of sight testing.


N

http://www.dh.gov.uk/ass


52



DERIVATION

FINAL ACTION

CODE

Subject to paragraph 8(5) a contractor shall retain all such records for a period of seven years, and shall during that period produce them when required to do so by a CCG or the Secretary of State. Follow link below for more detail http://www.dh.gov.uk/ass etRoot/04/10/12/ 42/04101242.pdf

Family Health Service Appeals Authority tribunal and case files

Case files – 10 years Decision records – until individual’s 80th birthday

See note 1 Destroy under confidential conditions

S

GP retirements/moved away

6 years after individual leaves service, at which time a summary of the file must be kept until the individual’s 70th birthday

See note 1

N

Research and development

30 years

Medical Research

See note 1

N



53



DERIVATION

FINAL ACTION

CODE

(organisation) i.e. all the organisation’s records associated with research and development and not individual trial records or information on patients.

Council

PERSONNEL/HUMAN RESOURCES

NB Both medical staff records and agency locums staff records should be treated as personnel records and retained accordingly.

Consultants (records relating to the recruitment of)

5 years

NHS (Appointment of Consultants) Regulations, good practice guidelines, page 11, para. 5.3 http://www.dh.gov.uk/ass etRoot/04/10/27/ 50/04102750.pdf


S



54



DERIVATION

FINAL ACTION

CODE

CVs for non-executive directors (successful applicants)

5 years following term of office


S

CVs for non-executive directors (unsuccessful applicants)

2 years


S

Duty rosters i.e. organisation or departmental rosters, not the ones held on the individual’s record.

4 years after the year to which they relate


N

Industrial relations (not routine staff matters), including industrial tribunals

10 years


S

Job advertisements

1 year

Destroy

S

Job applications (successful)

3 years following termination of employment


S

55



DERIVATION

FINAL ACTION

CODE

Job applications (unsuccessful)

1 year


S

Job descriptions

3 years


S

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

Destroy under confidential conditions See note 1

N

56



DERIVATION

FINAL ACTION

CODE

to retain as much as possible from the original file.

Letters of appointment

6 years after employment has terminated or until 70th birthday, whichever is later


S

Nurse training records (from hospital- based nurse training schools prior to the introduction of academic-based training)

30 years

See note 1

N

Pension Forms (all)

7 years

HMRC Technical Pension Notes for registered pension schemes under regulation 18 of SI2006/567 – ‘RPSM12300020 – Scheme Administrator Information Requirements and


N

57



DERIVATION

FINAL ACTION

CODE

Administration for General Retention of Records’

Personnel/human resources records –major (e.g. 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

Personnel/human resources records

2 years after the year to which

Destroy under

N

58



DERIVATION

FINAL ACTION

CODE

– minor (e.g. 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

they relate


Staff car parking permits

3 years


S

Study leave applications

5 years


S

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


N

59



DERIVATION

FINAL ACTION

CODE

months (as the master timesheet is held on the personnel file)

Training plans

2 years


S

PURCHASING/SUPPLIES

Approval files (contracts)

6 years after end of the year the contract expired


S

Approved suppliers lists

11 years



S

Delivery notes



S

Products (liability)

11 years



S

60



DERIVATION

FINAL ACTION

CODE

conditions

Stock control reports

18 months


S

Stores records – major (e.g. stores ledgers)

6 years


S

Stores records – minor (e.g. requisitions, issue notes, transfer vouchers, goods received books)

18 months


S

Supplies records – minor (e.g. invitations to tender and inadmissible tenders, routine papers relating to catering and demands for furniture, equipment, stationery and other supplies)

18 months


S

Tenders (successful)

Tender period plus 6 year limitation period

Limitation Act 1980


S

61



DERIVATION

FINAL ACTION

CODE

conditions

Tenders (unsuccessful)

6 years

Limitation Act 1980


S

62 Remote Access Policy Version 2 June 2013 Current Version Is held on the policy section of the intranet

Documents

CORPORATE RECORDS AND RETENTION POLICY Policy for the … · 2014-02-11 · guide based on best practice, and therefore followed for all corporate (non-clinical) records. 1.1.4 Ensuring