London Borough of Enfield
The Corporate Records Management
Policy
Contents
Corporate Records Management Statement
Corporate Records Management Policy and Purpose
Introduction – What Is A Record
Responsibilities
Ownership of records
Filing and Information Classification
Weeding
Backups
Storage & Archiving
Retention Schedule
Confidential Waste Policy and Flow Chart
Destruction
Disaster Recovery Planning
Legal Admissibility
Electronic Storage/Scanning Policy
Office Moves
Copyright
Data Protection Act 1998
Freedom of Information Act
Training
Bibliography
Glossary
Appendix 1 – Clear Desk and Cabinet Policy
Appendix 2 – Retention Schedule
Appendix 3 – Sample Archive Box Label
Appendix 4 – Confidential Waste Policy and Flow Chart
Appendix 5 – Scanning Procedures
Appendix 6 – Statutory Regulations
Appendix 7 – Move Instructions
Author
Owner
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Amanda
Lamming
FM
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Classification
Unclassified
Date of First Issue
January 2008
Status
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1.
Corporate Records Management - Statement
Records Management is a major concern and of exceptional importance to the
Council as it provides the means to record our past activities, our current thoughts
and our vision for the future. Records and information also allow us to comply with
legislation, guidance and standards.
Records provide information to enable us to carry out our business in an efficient
manner. It is therefore the personal responsibility of each of us to ensure correct
and sufficient information is collected, stored in a suitable medium and retained or
destroyed in accordance with the Corporate Retention Schedule.
The retention of records is in many instances a legal requirement, but we must also
remember those that follow after us and decide what records must be kept for the
historians. This does not mean all information must be retained forever as not only
will the majority not be looked at, but also we do not have the capacity to store it.
Because of its importance Records Management should be recognised as a specific
Corporate programme within the Council and should receive the necessary levels of
organisational support to ensure effectiveness.
Remember, many records are unique and not easily reconstructed or replaced.
Records and information are part of the Council’s memory - they need to be
handled in the proper manner.
Chief Executive
Author
Owner
Version
Amanda
Lamming
FM
4
Classification
Unclassified
Date of First Issue
January 2008
Status
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2.
Corporate Records Management Policy and Purpose
London Borough of Enfield is committed to ensure that as part of its core business,
all records (either generated and received by individual employees or third party
organisations) are managed effectively and efficiently.
The Council shall store and capture records to ensure compliance with statutory,
contractual, evidential, legal, regulatory and London Borough of Enfield
requirements.
The aim of the policy is to provide guidance for the creators and users of Council
records and information in order to provide the most effective business processes
and service delivery, and to meet legislative requirements.
Records are recognized as a vital asset and are owned and managed by London
Borough of Enfield. All records are therefore subject to this policy.
Strategy for delivery:
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Establish, maintain and audit documented procedures for identification, capture,
indexing, classification, accessing, change control, filing, storage, maintenance,
retention and final destruction of all records.
Store records in such a way that they meet the highest level of integrity and
security, are readily retrievable to meet the business needs and are stored within
an environment that prevents damage, deterioration or loss.
Establish a single comprehensive document control environment for all records.
Appoint a team of London Borough of Enfield staff to deliver and manage all
relevant records throughout their life cycle.
Endeavour, where practical and economical, to create and store records in
electronic format.
Compliance with the Policy shall be subject to Management Audit. The responsible
person for ensuring compliance with this Policy is the Head of Facilities.
Author
Owner
Version
Amanda
Lamming
FM
4
Classification
Unclassified
Date of First Issue
January 2008
Status
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3.
Introduction – What Is A Record?
Records can be defined as information, recorded in physical form or medium,
received or created by the Council in the course of its business and retained as
evidence of its activities or because of the information contained in them will be
useful for others. Although not exhaustive, examples of items that can constitute
records include:
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Documents (including hand-written, typed, and annotated copies)
Paper based files
Computer files (including word processed documents, databases,
spreadsheets and presentations)
Maps and plans
Electronic mail messages (email)
Web pages (on either the intranet and internet)
Faxes
Brochures and reports
Forms
Audio and video tapes including CCTV and voicemail / voice recording
systems
What is Records Management? Records Management is the development of a
programme to control records throughout their life, from creation to ultimate disposal
either as confidential waste or as an addition to the archives of the London Borough
of Enfield. A good Records Management programme will create a management
resource available as long as it is necessary and enable the full use of this resource
by the Council.
What is the scope of this policy? Although the London Borough of Enfield is
increasingly using electronic storage, the Council is not a paperless office.
Substantial information is still received, created and retained on paper.
This document covers the Records Management policies implemented for software
and conforms to the recommendations of the code of practice for legal admissibility
and evidential weight of information stored electronically (BIP 0008:2004).
The aim of the policy is to provide guidance for the creators and users of Council
records and information in order to provide the most effective business processes
and service delivery, and to meet legislative requirements.
4.
Responsibilities
4.1
The Chief Executive has overall responsibility but delegates the policy and
strategy function to the Council’s Corporate Information Governance Board.
The Assistant Director for Customer Services is Chair of the Council’s
Information Governance Board
Author
Owner
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Amanda
Lamming
FM
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Classification
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The Senior Information Risk Officer (or Owner) is James Rolfe, Director,
Finance, Resources and Customer Services.
The Council has two Caldicott Guardians - Bindi Nagra in Adult Social Care
and Tony Theodoulou in Children's Safeguarding. A Caldicott Guardian is a
senior person responsible for protecting the confidentiality of service-user
information and enabling appropriate information-sharing. Guardians play a
key role in ensuring that the Council and relevant partner organisations satisfy
the highest practicable standards for handling client identifiable information,
and for the appropriate sharing of information.
4.2
The Corporate Records Manager (Head of Facilities) is responsible for advice
on policy and strategy. He or she will also be accountable to the regulatory
authorities, the Council and its Members as well as to the citizens of Enfield
for compliance with statutory obligations, standards and codes of practice.
The day-to-day function is delegated to the Information & Communications
Manager.
Specific responsibilities include:
4.3
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To establish organisational structures, policies, procedures and
standards for the management of records and information.
•
To continue to move towards electronic record keeping, and any
associated cultural change throughout the Council
•
To measure the performance of service unit staff and record keeping
systems.
•
To be aware of and make accessible, all known corporate physical and
electronic records across the Council.
•
To provide Corporate Records Management advice to Council staff.
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To work with managers of information resources to develop a coherent
information architecture across the Council.
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To work with accountable stakeholders including the DPA and FOI
officers and executive management to ensure record keeping systems
support organisational and public accountability.
Service Departments
The Departmental head will assume responsibility for all information and records
within that department. The day-to-day functions may be delegated to a
Departmental Data Co-ordinator who will have the following tasks:
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To monitoring for compliance with the Corporate Records Management
Policy.
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To formally agree which of their Department’s documents are
considered sensitive or require special conditions or levels of security.
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To ensure the necessary skills and training are in place or made
available to those employees needing them. The training includes
Records Management procedures.
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To oversee the effective management of all records within their
department.
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To maintain adequate documentation in support of any Records
Management decision.
•
Maintain an up-to-date information asset register with clear and
accurate information
asset owners who are aware of their responsibilities under the
Information Classification Policy
•
Ensure records are reviewed annually against the retention schedule
and either stored or destroyed securely. This includes archived boxes.
•
Ensuring that records (either physical or electronic), when shared
outside the Council, are shared complying with all Council Information
Governance Policies and the relevant information sharing
agreements/contact clauses.
•
Ensure the secure transit of information (either through secure
electronic interfaces or physical movement of paper records)
•
4.4
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In the case of physical records (e.g. children’s case files requested for
a legal case) to, where possible, make copies rather than sending the
original documentation. However there may be instances where this is
not possible and it may be necessary to take advice from Legal
Services.
Employee responsibilities
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Each piece of information or record will have an owner who is
responsible for content, metadata (details on author, source, software
requirements if electronic, changes etc), accuracy, safekeeping,
destruction and archiving etc.
•
In addition to the general responsibility to ensure confidentiality,
integrity and availability of records that are held by the Council, are
preserved to the highest standard, to create sufficient, appropriate
accurate records to support the conduct and business of the Council.
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Records and information in their care must be maintained in such a
manner to prevent loss or destruction. Staff must sign out paper
documents when working from home or out of the office on business.
In addition, laptops and paperwork should be kept separate when out
of the office as often as possible.
•
Records and information must always be readily available and to this
end must not be misfiled, removed from the premises or locked in
storage with no access when the employee is away from the premises.
•
Employees should be aware of their responsibilities under the Data
Protection Act, the Freedom of Information Act and any other relevant
legislation. If they are not sure of their responsibilities they should
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consult their Head of Department or FOI, DPA or Information Security
representative.
5.
Ownership of information
All information received or created by the Council is a common corporate asset and
not the property of any individual Department or employee.
The Council is in the process of further development of the Information Asset
Register.
6.
Filing and Information Classification
It is recommended that information be clearly marked with a date and signature and
be filed in date order with the latest date to the top. Papers must be secured within
the file cover and not loosely inserted.
Electronic information must be labelled and inserted in an appropriate folder on the
PC. This type of information is to be treated for retention, destruction and archiving
under the same rules as for paper documents. Do not store information on your
PC/laptop hard drive where it cannot be accessed by other staff or would be lost if
the laptop was lost or stolen.
Microforms/CD’s should not be left on desks but should be filed in an appropriate
container with a suitable index and locked away.
The information that the Council collects and maintains is an essential asset that it
relies on to function efficiently and provide excellent services to our residents.
Fundamental to this is that we are able to retrieve all the relevant information when
needed. This is impossible without a structured filing system whether in electronic or
paper form that is organised and managed in a systematic way. A sound filing
system will be:
1. Simple and logical so that does not rely on individual officers to self-manage.
Does it meet the "temp test" so that a new member of staff or temporary staff with a
few basic instructions can easily retrieve information?
2. Accessible to all that require access to the files to do their job (i.e. not kept in
personal drives or cabinets or lockers)
3. Papers are arranged in a logical order (e.g. alphabetically/chronological) and or
separated into different categories (e.g. HR record could have a section on career
progression, pay history, sick absence and disciplinary record)
4. An appropriate indexing/cataloguing system so that paper files can be located
easily. For electronic files the use of a consistent naming convention and Metadata
so that all relevant information can be effectively retrieved.
5. In the case of paper records an effective system of tracking a files location and
whether it is charged out to an officer or in archive store. Also a record of whether
files have been reviewed/destroyed.
6. Effective version control is essential to ensure people use the most current
information when making a decision.
Author
Owner
Version
Amanda
Lamming
FM
4
Classification
Unclassified
Date of First Issue
January 2008
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Under the Council’s Clear Desk and Cabinet Policy (see appendix 1) no paper
should be left out when desks are not in use. All paper must be filed away out of
hours in locked cabinets and lockers.
The information that the council collects and maintains is an essential asset that it
relies on to function efficiently and provide excellent services to our residents.
Fundamental to this is that we are able to retrieve all the relevant information when
needed. This is impossible without a structured filing system whether in electronic or
paper form that are organised and managed in a systematic way.
The Council’s move to Sharepoint will help to address effective filing and version
control but it will require individuals to take care when naming and labelling
documents.
Record naming conventions
'File names' are the names that are listed in the computer file directory and which
users give to new files when they save them for the first time. Naming records
consistently, logically and in a predictable way will distinguish similar records from
one another at a glance, and by doing so will facilitate the storage and retrieval of
records, which will enable users to browse file names more effectively and
efficiently.
Naming records according to an agreed convention should also make file naming
easier for staff because they will not have to „re-think‟ the process each time. Below
are some tips for staff:
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2.
3.
4.
5.
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Keep file names short, but meaningful
Avoid unnecessary repetition
Use capital letters to delimit words or underscores, NOT spaces or hyphens
When including a number in a file name always give it as a two-digit number
(e.g. 01) unless it is a year or another number with more than two digits ( this
means that they appear in the correct order in a file list)
If using a date in the file name always state the date first ‘back to front’, using
four digit years, two digit months and two digit days, e.g.: YYYYMMDD – this
again helps ensure they always appear in the correct date order in a file list
if using a person’s name in the file list – use the surname first and then their
initial or first name
put words like draft and final at the end
Proper labelling of documents All documents (except personal letters and publications) should contain the following
information in the footer on the first page or cover:
• Author/document owner
• Title/File name
• Version number
• Date of issue
• Number of pages (page x of x)
• Classification (see below)
Author
Owner
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Amanda
Lamming
FM
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Classification
Unclassified
Date of First Issue
January 2008
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Status e.g. draft, final version
Subsequent pages should contain the title/file name, version number and pages (x
of x) in addition to the following statement: This is a CONTROLLED document. Any
printed copy must be checked against the current electronic version prior to use.
There are three classifications:Unclassified
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Publicly available information – leaflets, web contacts, annual reports etc
Information that wouldn’t cause any harm or infringe any law if it was
intentionally or accidentally disclosed to the public
Unclassified documents do not need to be marked but staff should use proper
labelling procedures as set out above.
Unclassified information has no storage or distribution requirements other than those
covered by the Clear Desk and Cabinet Policy and health and safety. They can be
destroyed in line with the Council’s normal Retention Policy.
However the Council is asking that all cupboards are locked. If a cupboard/file
contains a variety of papers, the whole cupboard/file is classified according to the
highest classified document within it. By locking all cupboards staff can ensure that
errors are not made.
PROTECT
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Information where damage, financial loss, embarrassment or a breach of
professional etiquette could occur through unauthorised or accidental
disclosure, surveillance or modification.
It could damage or prejudice to:
o An individual if it contains sensitive personal information
o The Council’s or a third party’s commercial interests
o The investigation or prosecution of a crime or apprehension of an
offender
o The effective conduct of public affairs
o Breach a proper understanding to maintain a duty of confidence. (this
is not simply any document marked confidential – it was contain
information that is confidential in nature)
o Breach a statutory restriction on disclosure
In most cases personal information about any living individual would attract a
classification of PROTECT
If large quantities of personal/sensitive information were grouped together or
where information could someone at risk, this would attract a RESTRICTED
classification.
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You may want to use sub-categories to make it clear why you have given a
document PROTECT classification such as the following:
• PROTECT – COMMERCIAL
• PROTECT – PERSONAL
• PROTECT – STAFF
• PROTECT – MANAGEMENT
• PROTECT – CONTRACT
PROTECT documents must be marked as PROTECT and stored in locked
cupboards/password protected networks on local file storage systems.
PROTECT documents can be distributed internally via the Council email system to
people with an enfield.gov.uk address or authorised 3rd parties only. PROTECT
information can only be distributed externally via email if it is password protected
and encrypted or sent via GCSx/secure enhanced file transfer. PROTECT
information should not be faxed.
All protect documents and emails must also contain a security phrase as follows:
The information contained within this email/document has been classified
as PROTECT. This information is for the addressee only and must not be
forwarded to any individual who is not authorised to view it without the
explicit permission of the information owner/author.
The Council is currently working on an IT solution that will enable you to marl
emails as PROTECT or RESTRICTED and insert the relevant wording using a
drop down box. This system is due to go live at the end of the year.
The information owner/author must give consent for any PROTECT information
to be passed internally or externally by post. In these situations (and for internal
post) the envelope should be sealed, clearly addressed and marked PROTECT
and ONLY TO BE OPENED BY.
The information owner/author must give consent for any PROTECT information
to be copied onto a media storage device (USB memory stick, CD etc). These
devices must be a council authorised one and encrypted. See the use of
encrypted device policy for more information which is available on Enfield Eye.
PROTECT information can be deleted from the network/local drives and emails
in accordance with the Council’s retention policies. Physical PROTECT
information must be shredded either personally or by an approved 3rd party. If
the documents are placed in confidential waste sacks and FM are called, they
will ensure the secure disposal of the information. USB memory sticks, diskettes,
CDs must be reformatted or destroyed.
RESTRICTED
•
Author
Owner
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This is information that if subject to unauthorised disclosure, malicious or
accidental surveillance or modification (even within the Council) would cause
serious damage, harm and prejudice by virtue of :
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o
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Significant financial loss
Significant damage to Council image and reputation
Grave embarrassment
Detriment to staff morale
Breach of professional etiquette
Significant harm or prejudice would be likely to cause substantial distress or
damage to an individual, the Council’s (or a third party’s commercial
interests), the investigation/ prosecution of a crime/apprehension of an
offender or the effective conduct of public affairs.. The information would be
of both a sensitive nature and likely to impact heavily on the privacy of a
person, an investigation or the commercial interests of an organisation.
Documents and emails should be clearly marked RESTRICTED and must
contain the following security phrase:
The information contained within this email/document has been classified as
RESTRICTED. This information is for the addressee only and must not be
forwarded to any individual not included on the attached distribution list
without the explicit permission of the information owner/author.
The Council is currently working on an IT solution that will enable you to marl
emails as PROTECT or RESTRICTED and insert the relevant wording using a
drop down box. This system is due to go live at the end of the year.
All RESTRICTED documents must be accompanied by a distribution list.
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RESTRICTED information must be stored in locked cupboards and password
protected and encrypted files. Passwords of all types are deemed
RESTRICTED and must be sent separately from any information.
RESTRICTED information can be sent to the agreed distribution list via the
Council’s internal email system.
RESTRICTED information can only be distributed externally via email if its
password protected and encrypted or sent via GCSx/Secure enhanced file
transfer.
RESTRICTED information can be sent via the internal post if in a sealed
envelope, clearly addressed and labelled RESTRICTED and ONLY TO BE
OPENED BY
RESTRICTED information can only be posted externally is in a sealed
envelope, clearly addressed and labelled RESTRICTED and sent by
RECORDED DELIVERY.
The information owner/author must give consent for any RESTRICTED
information to be copied onto a media storage device (USB memory stick, CD
etc). These devices must be a council authorised one and encrypted.
RESTRICTED information should not be faxed.
RESTRICTED information can be deleted from the network/local drives and
emails in accordance with the Council’s retention policies. Physical
RESTRICTED information must be shredded either personally or by an approved
3rd party. If the documents are placed in confidential waste sacks and FM are
Author
Owner
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Amanda
Lamming
FM
4
Classification
Unclassified
Date of First Issue
January 2008
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called, they will ensure the secure disposal of the information. USB memory
sticks, diskettes, CDs must be reformatted or destroyed.
Breach of the Policy If there is a breach of these rules, staff must report it using the information security
incident form available on Enfield Eye.
Links with the Freedom of Information Act
A classification of PROTECT or RESTRICTED does not necessarily exempt the
information from a Freedom of Information Act request. However, it will prompt you
to consider if an exemption does apply. See the Freedom of Information Policy for
further information on exemptions.
Links with Subject Access Requests If someone requests to see their personal records (and therefore documents
classified as PROTECT or RESTRICTED), it is important you follow the Subject
Access Request procedure in dealing with the request.
Actions for you to take •
•
•
•
•
•
•
•
7.
Ensure you lock all your cupboards – if keys are missing or broken,
email [email protected] for replacements.
Review your files under the Council’s Retention policy including those
in archive storage
Review the templates for your common documents
Identify areas where you would be accessing/creating PROTECT or
RESTRICTED information
Complete the training available on Enfield Eye
Read the full policies available on Enfield Eye if you are unsure
Keep your passwords secure
Alert your manager if you have access to information that you feel you
shouldn’t or if you become aware of a breach of these rules.
Weeding
A Retention Schedule is shown in appendix 2 and is also on the Enfield Eye
..\Retention Schedule\Retention Schedule Mar 14.xls
It contains details of information to be reviewed, retained or destroyed and at what
intervals. Records should be checked regularly to ensure duplicates and nonrelevant information is removed. Queries or questions regarding weeding should be
directed to extension 020 8379 4421 (Records Unit)
See Section 10 for disposal of information.
8.
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Backups
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All prime information must be regularly backed up in some manner e.g. electronic or
paper with the first format being preferable. The time scale between backups will
depend on the importance and financial value of the information. The responsible
manager’s decision on the time scale should be recorded. The back up should not
be stored in the same office as the original. If the information is irreplaceable then
the back up should be stored off-site.
9.
Local Storage
A locked cabinet should be used to store paper, disks or microfilm records.
Storage boxes are available from the Records Unit on 020 8379 4421 and each
must carry a box label (see appendix 3) that must be completed with the following
information:
•
•
•
•
•
•
Service Department and team name.
Contact Number.
List of contents.
Retention period.
Scan and destroy paper or scan and retain paper.
Classification
Which together with the enclosed index, enables such records to be retrieved within
the hour within at the Civic Centre and within 24 hours for out stations. There is a
computerised database that shows where the boxes are stored, how often they are
accessed and whether a file has been returned. Teams may ask for a report to
check their holdings.
Review dates should not be used, only destruction dates. They should be selected
with care and continually moving them forward is discouraged.
Boxes may be sub-divided so that different types may be stored in the same box.
Part filled boxes will not be accepted. Contents should be in the same order as the
client provided index.
Archive Storage Area
• Documents will only be stored in archive boxes supplied from the Document
Management Team. Boxes are retained in purpose built storage racks with
row and shelf referencing for retrieval purposes.
• Each box must have all paper work supplied by Document Management
attached to the box. The index sheet must be placed inside the box for easy
traceability.
• Each box is listed on a manual index sheet on entry to the archive with the
yellow copies attached to the index sheet.
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Owner
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Lamming
FM
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Date of First Issue
January 2008
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• Details of all boxes in the archive are inputted to the DMS computer, thus
providing easy reference and tracking.
• Once entries are completed, the two copies are printed of the Input Form.
One copy is attached to the archive box, the other is sent to the customer.
• Once the forms been attached to the box a further check is done to make
sure the box is on the correct by row & shelf. This is signed off by another
member of staff (not the person who attached the form).
The following procedures are in place for tracking missing files/box.
Checking and tracking mechanisms:
•
•
•
•
Check the box was received into the archive via database. All fields can be
searched on i.e. search on owners, contact details, department or section.
If it’s a specific file that’s missing, check the box’s History of Access
If not successful, check the manual index sheets
If for any reason the box cannot be traced a full manual search of the archive
will take place and the FM Head of Service advised.
Classification of boxes will determine who can retrieve the information. (Protect
Owner only, Restrict –Team only) Boxes should be classified according to the
highest graded information within it.
All documents must be classified and documents stored within the archive boxes
need to marked as unclassified, protect, or restricted. Those with mixed
classifications will attract the highest classification control.
Staff are provided with information on how to classify documents. This information
can be found on the Enfield Eye DO link.
Managers should not enter into any contracts for other off-site long term storage.
Speak to the Corporate Records Manager for advice.
9.1
Archiving for the Archivist
Certain items are listed in the Retention Schedule for archiving or passing to the
Archivist/Local History Officer. If you are about to destroy any information which
may be of use in the future for researchers into the historical events within the
Borough and surrounding area, please contact the Local Studies Officer for advice
(020 8379 2724). Such day-to-day records may contain valuable
historical/genealogical/local history and social science information that may be
useful for the studies of social, economic and political issues. They may also have
sentimental value to past or present persons of the Borough. Records containing
personal information can have a rider on them allowing access to designated
officers only, after 30 years or as determined. Other documents to be considered
are:
•
Author
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Records of department operation and structure.
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Lamming
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•
•
•
•
•
•
Information collected by a service group for its own use e.g. customer
surveys.
Information about past activity which would aid future planning.
Records containing unique information not available elsewhere e.g. burial
records.
Information about policy/decision making e.g. Committee reports and
Minutes.
Records dealing with external involvement e.g. Central Government, Trade
Unions, etc.
Records of research and development.
Retaining whole series of records would be high on space usage, so a limited
number should be selected either by choice, random sampling or systematic
sampling methods.
10.
Retention Schedule (also see appendix 2)
Retention scheduling is the process of documenting a record’s value in the terms of
the length of time it should be retained. Its objectives are to: •
•
•
•
•
•
•
•
•
•
•
•
•
•
Personal data should only be retained where there is a legitimate need.
Dispose promptly of those records whose retention period has ended.
Retain records that are no longer current, but which need to be kept for some
time for statutory or audit purposes.
Preserve records that have a longer-term archival/historical value.
Enables good record keeping practices.
Meets management’s information needs.
Establishes a systematic programme to determine value of records before
destruction.
Saves time by reducing the volume of files to be searched for.
Avoids legal problems.
Promotes efficiency by focusing on those records that are important.
Saves space by removing non-current records from office accommodation to
storage.
Identifies valuable records for archival preservation
Meets the needs of the Data Protection and the Freedom of Information Acts.
All services should review and update their list of archives every year.
The Council has a Corporate Retention Schedule that should be followed by all
Departments. It is managed by the chair of the Information Governance Board who
is responsible for all additions, deletions and amendments. Internal Audit are
consulted on all changes.
11.
Confidential Waste Policy & Flow Chart
The Council has a policy to ensure that the security of waste documents is upheld
until pulping (see appendix 4). This Policy includes the issue of destruction
certificates.
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12.
Destruction
Once it has been decided that information can be destroyed paper records may be
disposed of via the confidential waste system. Electronic data on discs and microfilm
can also be destroyed. The Records Unit can arrange this. There are additional
systems available for the destruction of such items as blank cheques and items of
the highest sensitivity. Information on how to dispose of hard discs is available from
Serco, the Council’s IT partner.
13.
Disaster Recovery Planning
Every Department should have a Business Impact Analysis Plan in order to protect
information and to promote maximum recovery. In the case of electronic records
there may be a need for duplicate hardware and software.
14.
Legal Admissibility
In order to ensure the storage medium is acceptable in a court of law and carries the
same weight of evidence as the original paper version all microforms should comply
with the appropriate British and International Standards.
Electronic storage should follow the recommendations of PID 0008 - A Code of
Practice for Legal Admissibility and Evidential Weight of Information Stored on
Electronic Document Management Systems. - Issued by the British Standards
Institution. BSI has issued a workbook to compliment the Code of Practice.
Completion of this will show with which parts of the Code you comply.
15.
Electronic Storage/Scanning Policy
E-mail and information stored on a PC and used to facilitate the performance of
Council work is a corporate asset and a critical component of the Council’s
communication system. Such information may therefore be used in court of law in
the same manner as information stored on paper or microfilm.
For these reasons the information should be dated and assigned a responsibility e.g.
it should show who the author is. Filing should follow the same standards as for
paper and each folder should show the same information as for a paper file.
There should be consistent naming conventions for records. The Council is
developing a common naming convention.
Electronic records must be protected from physical and intellectual damage (editing,
version control). Their use must be tracked and managed, using the Information
Classification Policy.
Emails that are required to be kept under the retention schedule should be stored in
the relevant case management system/shared drive and not in the email systems.
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No tape or disc should be thrown away or reformatted without being checked for
material needing to be retained by legislation or for historical research. Consider
creating an archive disc or tape.
Services are responsible for data cleansing systems and ensuring the retention
schedule is applied to electronic data.
Document imaging - should be considered if there is a need to:
•
•
•
•
•
•
•
Automate document-based workflow.
Integrate document and data processing.
Manage large volumes of active documents.
Provide multi-access document handling.
Provide on-line document access.
Provide printed copy locally.
Control access to document retrieval.
A back-up copy may still be needed where there is a long term storage need
especially for information that is intended for the archives. This is because the
hardware to read the disc version may not be available in years to come.
The Council also has scanning procedures and a aide memoire for staff. This can be
found in appendix 5.
16.
Office Moves
Clear guidance on managing records during and after office moves is attached in
Appendix 7.
17.
Copyright/Intellectual Property Rights
This is a very complicated legal area and the work of others outside the Council
should not be copied without their permission. Work prepared on the Council’s
equipment during working time is most likely to be copyright of the Council. This
includes e-mail.
18.
Data Protection Act 1998
This covers all information referring to living persons regardless of format
(paper/film/electronic/disc) and reference must be made to the information available
from the Data Protection Officer. Please also refer to the Council’s Data Protection
Policy.
19.
Freedom of Information Act 2000
This legislation opens the majority of the Council’s information to the public.
Employees need to be aware of the Council’s procedures and of the exemptions.
More information is available from the Council’s FOI Officer. Please also refer to the
Council’s Freedom of Information Policy.
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20.
Training
All Council employees are involved in creating, maintaining and using records and it
is important that everyone understands their Records Management responsibilities
as set out in this policy. Managers will ensure that staff are appropriately trained.
21.
Bibliography
The following list is not exhaustive and if there is doubt, advice should be sought
from the Legal Department.
•
British Standard 5454:2000 Recommendations for the storage and exhibition
or archival documents
•
•
•
•
Copyright, Designs and Patents Act 1988
Data Protection Act 1998 (DPA)
BIP 0008:2004 Code of Practice for Legal Admissibility and Evidential Weight
of Information Stored Electronically
EC Directive on the Processing of Personal Data
Electronic Communications Act 2000
Employment Rights Act 1996
European Directive on Environmental Information
Freedom Of Information Act 2000 (FOIA)
ISO 154489 Information and documentation-Records Management
Local Government Act 1972
Lord Chancellor’s Department (LCD) – Code of Practice on the Management
of Records for FOIA
Public Records Office Act 1958 and 1967
22.
Glossary
•
•
•
•
•
•
•
•
Archive
The retention of information for further and possibly
other use after the business use has finished
Capture
The act of registering a document or transaction as a
record and storing it in a record keeping system. Part of
this process will usually include adding metadata to the
record.
Classification Scheme
Systematic identification and (usually hierarchical)
arrangement of business activities, documents, records
and folders in to categories in order that records can be
logically stored or grouped together for efficient
organisation sharing and retrieval.
Document
Often defined as ‘any recorded information or object
that can be treated as a unit of filing’ thus a letter, form
or report can be considered a document.
A document can be described as a record once it
records activity. However, many documents exist in
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their own right. For example an empty printed form is a
document; whereas once it has been completed it can
be registered as a record since its contents record an
activity and give it added meaning.
Electronic Record
A record held in electronic form.
Evidential Weight
The amount of importance or trust placed by the Court
on the evidence being presented.
Filing System
A collection of information regardless of storage format.
Folder
A set of related electronic records and physical
records; folders can be electronic or physical and can
be associated with metadata.
Inventory
A list of file series being used within a Team.
Meta data
Data describing the context, content and structure of
the record (s).
Physical record
A record that is permanently held and managed in a
non-electronic format. e.g. paper, video, microfilm, soil
sample, audiocassette or CD. A printed electronic
record or document is not necessarily a physical
record.
Record
Any evidence in physical or electronic form of
something that was communicated or decided, or
action was taken. Records can be any of the following:records created by the Council in the course of its
business;
‘Public records’ (for example records of courts,
coroners, hospitals and prisons) held on behalf of
central government;
records given to or purchased by the Council; or
deposited with the Council - normally on indefinite loan.
A record should be able to support the needs of the
business to which it relates and be used for
accountability purposes.
Record keeping systems
A system or process (either manual or automatic) that
captures and stores physical or electronic records.
Register
The act of designating a document within a record
keeping system as a physical or electronic record.
Once registered as a record the content of the record
(and its metadata) must not be changed. You can have
different versions but each version or amended copy
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must be registered in its own right to enable the audit
trail to be followed.
Series
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A collection of files relating to common information
related by subject or usage
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APPENDIX 1
LONDON BOROUGH OF ENFIELD
CIVIC CENTRE CLEAR DESK, UNDER DESK AND
CABINET TOP POLICY
1.
This policy is designed to:-
1.1
Support and enhance the New Ways of Working environment.
1.2
Support the London Borough of Enfield’s Data Protection, Display Screen
Equipment and Corporate Health and Safety policies.
1.3
Provide the Enfield Norse cleaning staff with the opportunity to clean desk
and cabinet tops on a regular basis, as per the cleaning specification. The
specification for desk cleaning provides for a weekly damp wipe with
disinfectant, followed by a buff with a clean, dry cloth. However, daily soiling
eg tea stains will be removed on a daily basis.
To achieve this task, the desk top must be clear of all papers etc. with cables
as tidy as possible to the rear of the desk top.
Chair legs will also be dusted weekly and soft furnishings vacuumed as
required.
All cabinets at no higher than one metre will be dusted weekly. Those
cabinets over one metre will be dusted every quarter.
Please note that IT equipment and telephones are not included in the
cleaning specification.
1.4
To aid search teams in the event of a bomb or similar threat.
1.5
To improve the environment, ambience and tidiness of the workplace.
2.
The policy is as follows:
2.1
All taller (those over one metre high) cabinet/locker tops, must be clear at all
times, together with the window air supply units and areas under
desks/tables.
2.2
All desk and lower cabinet tops must be clear of all papers, stationery, all file
types, cups, litter, all personalisation e.g. photos, animal models, in/out trays
and laptops, at the close of business on each working day. (NB. Plants, on
the provision that they are maintained and cabinet tops kept clean, are
permitted on low cabinets).
2.3
All cabinets and lockers should be locked when not in use and the keys held in
a key safe
2.4
A note will be left on the desk/cabinet(s) of those that fail to comply. (any
disability needs will be taken into consideration).
2.5
Should corrective action not be taken within three working days, FM (x4441)
will remove the items concerned. If a person is on leave, their manager will be
responsible for clearance.
2.6
Directors and Assistant Directors will be advised of any instances of
corrective action not being taken by their staff.
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APPENDIX 2
Record Retention Schedule (all formats) – March 2014
Record retention general limits
Records not included in the specific service schedule below – retain for a maximum
4 years or sooner if not required, unless relating to a financial transaction in which
case retain for 7 years. Emails should be retained within the service case
management system or similar secure modes.
Agreements under seal, Leases and tenancy agreements and disposal of freehold
or leasehold property by the Council - retain for 12 years after closure / disposal /
termination of tenancy.
All other record retention targets are service specific as set out below.
The ownership of this schedule is with the Information Governance Board.
Departments are responsible for ensuring that documents are retained in
accordance with the above schedule. Any suggestions for revision of the schedule
may be made to Kate Robertson [email protected] or your
Departmental Information Governance Board Member.
..\Retention Schedule\Retention Schedule Mar 14.xls
APPENDIX 3
BOX STORAGE LABEL
Complete all areas and put inside plastic wallet. If not completed, boxes will not be accepted & will be returned
Manager of Service:-
Signature:-
Ext.:-
Service Centre Name:-
Box No:-
Date Sent to Records Unit:-
Serial No.
Group:SAP Cost Centre:Contents of Box (Please use exact name not general or misc etc A separate index sheet must be used to list all files within this box)
Please tick one of the boxes.
Archive documents
Electronic scanning & Destroy
Are the box contents:
Protected
Restricted
Unclassified
Please tick all that are relevant
Store documents until (destruction date) ……………………………..
Cost Code for Scanning ……………………………………………….
Retention Schedule Category & Title as listed in the Retention Schedule ………………………………....................................................
Can any team member request or view these documents
Yes
No
Do any other Services require access to these documents
Yes
No
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RRU Issue G –
24/08/12
If Yes Name Teams…………………………………
Date of First Issue
Date of Latest Re-Issue
Next Review Date
January 2008
August 2012
August 2013
APPENDIX 4
CONFIDENTIAL WASTE
DISPOSAL POLICY
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Date of next Review
January 2008
August 2013
August 2012
August 2014
Distribution List:
This document is for distribution to all individuals
as identified within the Scope of this Policy. Any
other request to read this document must be
authorised by a member of the Information
Governance Board.
Document History
DATE
ISSUE
SECTION PROCEDURE
NUMBER
NUMBER
28/08/09
02/10/09
1.0
1.1
ALL
ALL
N/A
N/A
29/10/09
1.2
ALL
N/A
20/11/09
17/12/09
12/07/10
1.3
1.4
1.5
7.0
Title
ALL
N/A
N/A
N/A
03/08/10
20/08/12
1.6
2
APPROVAL
Draft
N/A
N/A
Dec 13
3
Draft
N/
REVISION
DETAILS
First Draft
General Revisions from
Stuart Simper and Tee Patel
Revisions by Stuart Simper
and Tee Patel
IGB Approval Date
Tee Patel
Revisions by Stuart Simper
and Ian Davies
Neil Isaacs
Revisions by Stuart Simper
circulated for comment
Revisions by Stuart Simper
circulated for comment
Contents Table
Contents Table…………………………………………………………………………………
1.0 Introduction ………………………………………………………………………………..
1.1
Definition ………………………………………………………………………...
2.0 Scope ………………………………………………………………………………………
3.0 Responsibilities & Policy …………………………………………………………………
3.1
Summary ………………………………………………………………………...
3.2
Good Practice …………………………………………………………………..
3.3
Process Paper …………………………………………………………………..
3.4
Removal of Sacks ………………………………………………………………
3.5
Shredding …………………………………………………………………………
3.6
Disposal of IT Waste ……………………………………………………………
3.6.1 Removable Media (Floppy disks, CD’s, DVD’s, Videos, Cassettes) ……
3.6.2 Other IT Equipment …………………………………………………………..
4.0 Compliance …………………………………………………………………………………
5.0 Exceptions ………………………………………………………………………………….
6.0 Related Documents ………………………………………………………………………..
7.0 Date and Renewal Process ……………………………………………………………….
Confidential Waste Policy. This is a CONTROLLED document and any printed copy must be checked
against the current electronic version prior to use.
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2
3
3
3
3
3
4
4
4
4
4
4
4
5
5
5
5
1.0
Introduction
The following policy details the process of handling, storage, collection and disposal of confidential
waste.
1.1
Definition
Confidential. This is information that if subject to unauthorised disclosure, malicious or accidental
surveillance or modification (even within the Council) would cause serious damage to the interests of
the Council by virtue of significant financial loss, significant damage to Council image, grave
embarrassment, loss of reputation, detriment to staff morale or serious break of professional etiquette.
In addition, if the Information Asset would place an individual in significant and real personal danger,
impede security investigations, or the investigation of crime/fraud this should be treated as
“Confidential”.
2.0
Scope
This Confidential Waste Disposal Policy applies to all Council Members, employees, contractors,
consultants, agency staff, independent contractors and other users of Enfield Council information
systems irrespective of the platforms used or where they are located.
This policy also applies to all Managed Service Providers and organisations that provide a service to
the Council
This policy relates to normal operating conditions and is relevant to all Enfield Council buildings
managed by Facilities Management.
This policy covers confidential paper documents only.
If you have other confidential materials to dispose of, please contact Document Management
(x4452).
3.0
Responsibilities & Policy
Summary
•
•
•
•
•
•
All staff shall segregate paper waste from the general waste stream at source and place
in green bags (Enfield Civic Centre), red bags (other sites) or designated
containers.
Staff working from home or at a place where confidential paper waste facilities are not
available, should retain their paper waste depositing in the appropriate container when
next at the Civic or another office with a confidential paper waste facility.
Do not overfill the bags – bags should be no more than a maximum of 10kg.
Bags should be stored securely and a collection arranged with Facilities Management
who will collect within two working days.
Document Management shall store the documents securely and dispose of them with a
registered waste carrier.
N.B. Shredding – Staff with access to a shredder can shred their own waste. (Please
refer to 3.5)
3.1 Good Practice
All paper document including MFD (Multi-Functional Device) jams of blank paper, out of date
letterheads, printed forms, should also be classed as confidential.
These can be placed in the recycle waste, on condition they are torn up, ensuring that they cannot
later be removed and used inappropriately.
PLEASE ENSURE THAT YOU COLLECT ALL PRINTING MATERIAL FROM YOUR COPY/PRINT
OUTPUT AND LOGOUT.
3.2 Process Paper
Paper confidential waste must be placed in confidential waste sacks. Prior to placing in sacks the
paper must have all staples, paper clips and binders removed and must be torn into pieces.
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Sacks must not be left in public areas.
Confidential Waste Policy. This is a CONTROLLED document and any printed copy must be checked
Against the current electronic version prior to use.
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3.3 Removal of Sacks
Confidential waste is collected on demand as called into the Facilities Management Helpdesk on
x4441.
3.4 Shredding
The use of shredders is permitted. Any shredders purchased after the introduction of this policy
should be ‘cross cut’.
3.5
Disposal of IT Waste
3.5.1
Removable Media (Floppy disks, CD’s, DVD’s Videos, Cassettes)
Removable Media containing confidential information should be reported to the Corporate IT Helpdesk
on x3155 or email [email protected]
3.5.2
Other IT Equipment
The disposal of all other IT equipment e.g. PC’s, printers is to be dealt with by the Corporate IT
department. If a department has the need to dispose of such items a Service Request should be
logged with the Corporate IT helpdesk, who will pass this onto the Managed Service Provider for the
appropriate destruction. Corporate IT Helpdesk on x3155 or email
[email protected]
Confidential Waste Policy. This is a CONTROLLED document and any printed copy must be checked
Against the current electronic version prior to use.
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APPENDIX 4
CONFIDENTIAL WASTE DISPOSAL FLOW CHART
Staff identify confidential
waste (includes all office
paper based products)
and place in receptacle
Receptacle emptied by
FM
Pearce place bales
into containers
Containers are
locked, sealed and
photos taken
FM staff place paper
into locked waste
containers in Civic
Basement/
Goods-In area
Locked waste
containers moved to
Ground Floor Car
Park on collection
days (Tuesday and
Thursday)
Containers are taken
by lorry to UK sites
for
re-cycling
Paper is pulped on
receipt to be made
into copier
paper/toilet tissue
Notes:
a)
b)
Pearce Recycling have started the process for ISO accreditation
Pearce Recycling are accredited with ENISO-14001: 2004 & Registered with Environmental Agency Reg. No. GTL/363092, FCSCO22132
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Final
Date of First Issue
Date of Latest Re-Issue
Next Review Date
Locked waste
containers collected
by Pearce Recycling
and delivered to
St. Albans
January 2008
August 2012
December 2013
Pearce weigh, shred
and bale paper
LBE receive
payment via BACS
LBE receive a
Certificate of
Destruction
Scanning
Procedure
APPENDIX 5
PASS TO LOCAL
STUDIES
OFFICER
Yes
Does it have
historical value?
DESTROY
No
No
SCAN AND
DESTROY
HARDCOPY
SCAN
Does the
document/
record need to
be retained?
Corporate
Records
Retention
Schedule
& STORE
STORAGE
Yes
No
High retrieval
rate?
Yes
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SCAN &
DESTROY
HARDCOPY
High retrieval
rate?
No
No
Is the document
already held
electronically?
No
Yes
Yes
Must save
paper copy?
STORAGE
No
Yes
Unclassified
Final
DESTROY
PAPER
Date of First Issue
Date of Latest Re-Issue
Next Review Date
Scan all
except where
law requires
paper
storage
January 2008
August 2012
December 2013
Yes
Appendix 6
Statutory Regulations
There are various Acts, Statutory Instruments, Government circulars,
International/European/British standards and codes of practice as well as advice
from the Records Management Society and the Society of Archivists that affect the
work of local Government and record keeping. Some of the more obscure
references are found in the Acts of the armed forces and of agriculture. There is
also the complication of an offence under one Act relying on an offence under
another.
The following list is a small selection of Acts that may effect this Authority’s record
keeping. Detailed advice should be sought from the Council’s Legal Team.
Access to Health Records Act 2002 - affected by the Data Protection Act 1998
Activities Centres (Young Persons’ Safety) Act 1995.
Adoption Act 1976
Agriculture Act 1970 (1970 c 40).
Allotments and Small Holdings Act 1926 (16 &17 Geo 5 c52).
Animal Boarding Establishments Act 1963 (1963 c43).
Animal Health Act 1981 (1981 c22).
Banking Act 1979 (1979 c37).
Banking Act 1987 (1987 c22).
Betting, Gaming and Lotteries Act 1963 (1963 c2).
Charities Act 1960 (8 & 9 Eliz 2 c58).
Charities Act 1985 (1985 c20).
Charities Act 1993 (1993 c10).
Child Abduction and Custody Act 1985
Child Support Act 1991
Children Act 1989
Children and Young Persons Acts 1933/1963/1969.
Civil Evidence Act 1995
Commons Act 1899/1908
Commons Registration Act 1965
Common Land (Rectification of Registers) Act 1989
Consumer Protection Act 1987
Copyright Act.
Data Protection Act 1998.
Defence Act 1860 (23 & 24 Vict c 112) as repealed by the Local Government Act
1972.
Employment of Children Act 1973.
Employment Rights Act
Environmental Protection Act 1990 (1990 c 43).
Family Law Act 1986
Family Law Reform Act 1987
Freedom of Information Act 2000
Gaming Act 1968 (1968 c65).
Gaming (Amendment ) Act 1990 (1990 c26).
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Health and Safety at Work Act 1974.
Housing Act 1985
Enclosure Act 1773/1845/1846/1847/1848/1849/1852/1854/1857/1859
Local Authority Social Services Act 1970
Local Government Act 1972 and 1988
Metropolitan Commons Act 1866
Military Lands Act 1903 (3 Edw 7 c47).
Performing Animals (Regulation) Act 1925 (15 & 16 Geo 5 c38).
Plant and Varieties Seeds Act 1964 (1967 c 8).
Public Records Act.
Race Relations Act 1976
Registered Homes Act 1984
Riding Establishments Act 1964 (1964 c70).
Sex Discrimination Act 1975
The Gaming and Amusement Act 1976 (1976 c32).
Town and Country Planning Act 19
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Appendix 7
Move Instructions/Implementing New Ways of Working
Your Relocation Team contacts: Jackie Chow (ext. 3085) and Ryan Jones (ext. 3167) and Darren Sansom (ext. 6127).
Please also consult your manager on the move. The Relocation Team will supply crates (as necessary) and move
labels that you will need to complete with your name team and location details.
All services are responsible for ensuring that all papers, disks and other items are secure in crates. Please ensure
that you correctly and clearly label all crates, PC’s and chairs, attaching labels to the side of crates not on top.
Please do not overfill crates – this makes them too heavy to lift. When your crates are full, please store them in a
secure area, no more than 4 high, not blocking walkways or fire routes.
Confidential paperwork should be placed in separate crates. These crates will need to be coded (not marked as
confidential) by the Relocation Team, so please contact the team as soon as possible.
Services must keep a full inventory of crates and this must be passed to the Relocation Team prior to your move. The list
will be checked with you by the Relocation Team at your destination to ensure that all crates are accounted for. The
Relocation Team will cable tie all crates before moving.
During the physical move(s), a member of the Relocation Team will monitor the confidential crates and ensure that the
crates are securely stored at the new location. On your first working day at your new location the responsibility for the
confidential crates reverts back to you.
The Relocation Team will help you to deal with the emptying of the confidential paperwork crates as the first priority.
The loss of any crates containing confidential information must be reported to the IT Security team.
If crate storage prior to your move becomes an issue, please contact Ryan to seek a solution.
Use the move as an opportunity to discard files etc, placing the unwanted paperwork in confidential waste sacks. Leave
the sacks in a secure area for the Relocation Team to collect. After checking the Retention Schedule, ideally scan
or archive other not often used files etc, using Storewell boxes available via the Relocation Team. When boxed
up, please leave the boxes in a secure area for the Relocation Team to collect. Please refer to the Corporate
Records Management Policy for further advice/information.
Do not forget to remove all posters, memos etc. on noticeboards/walls.
Introduce ‘new ways of working’, i.e. clear desk policy.
All fitted cupboards, storerooms etc within your area/building must be left completely clear of all materials. If these areas
etc cannot be cleared prior to the move, they need to be secured and the keys passed to the Relocation Team for later
action. Please advise the Relocation Team if securing the cupboards, storerooms etc. is an issue.
Please do not pack/label your telephone, PC monitor, keyboard or mouse.
Remove anything that you have pinned etc to your desk screen.
Please ensure that you have packed all personal items and work files form you’re your desk, pedestal and locker.
The desk should be left completely clear apart from the desktop screen, keyboard, mouse and ‘phone.
All pedestal and lockers must be emptied completely with the keys left in the lock, unless specifically agreed with the
Relocation Team.
All cabinets, including those that are not to be moved, should be unlocked with the key(s) left in the lock. All cabinets
should be left completely clear. If, for any reason, a cabinet cannot be completely emptied, it should be locked and the
key(s) passed to the Relocation Team, for later action.
Laptops, the laptop power supply, the laptop Kensington Lock and mobile ‘phones must be taken home with you on the
move date.
Author
Classification
Unrestricted
Date of First Issue
2006
Owner
Stuart
Simper
FM
Issue Status
Draft
Date of Latest ReIssue
April 2014
Version
5
Page
35 of 36
First Aiders / Fire Wardens should make the appropriate changes to their new floor plate signs and advise Tracey Stilling
by email that they are relocating.
Whilst we will endeavour to make the transition to your new location as smooth as possible, please bear with us should you
have any problems. All snagging will be dealt with ASAP.
FM will request the project manager to sign for and keep the crate delivery/collection notes from PHS.
When the move is complete and you are in your new location/layout, please ensure that you empty crates within 10 working
days, arranging collection of empty crates through the Relocation Team.
Please remember that your team will incur rental charges as long as creates remain in use and you will be charged for
any crates that go missing.
FM will check any vacated areas/buildings. Any items found will be treated as waste and all paperwork will be sent for
confidential waste disposal.
Ryan will provide a move satisfaction survey for completion by your team manager.
Author
Classification
Unrestricted
Date of First Issue
2006
Owner
Stuart
Simper
FM
Issue Status
Draft
Date of Latest ReIssue
April 2014
Version
5
Page
36 of 36