HM INSPECTORATE OF EDUCATION: RECORDS MANAGEMENT POLICY Index: Introduction

HM Inspectorate of Education: Records Management Policy 27.10.05

HM INSPECTORATE OF EDUCATION: RECORDS MANAGEMENT POLICY

Index:



Introduction



Information is a Corporate Resource



Personal Responsibility



Information Accessibility



Keeping Records of what we do



Ensuring Information is Accurate and Fit for Purpose

 Compliance with Statutory and Regulatory Requirements



Annex 1 – Personal Responsibilities



Annex 2 – Retention and Disposal strategy


Introduction

1. This paper describes a policy for the management of all Inspectorate files. It takes account of the need for the Inspectorate, as an Agency, to adhere to the principles of the

Public Records Act 1958 and 1967. This Act determines that all files are reviewed regularly for disposal and examined for possible historical preservation by the National Archives of

Scotland (NAS).

2. The policy is also based firmly on the agreed Scottish Executive Information

Management Principles as they apply to HMIE, namely:

Information is a Corporate Resource - HMIE's information is a corporate resource.

Personal Responsibility - Everybody is personally responsible for the effective management of the information they create or use.

Information Accessibility - We make our information accessible to others in HMIE except where there is a specific and agreed reason not to.

Keeping Records of What We Do - We retain details of all the decisions made on behalf of

HMIE.

Ensuring Information is Accurate and Fit for Purpose - We ensure that the information we create on behalf of HMIE is accurate and fit for purpose.

Compliance with Statutory and Regulatory Requirements - We ensure that our information management practices comply with all statutory and regulatory requirements.

Further guidance on compliance with the Information Management principles can be found via: http://intranet/content/departments/HMIE/directorate4/CorporateSer/InfoManagement/docs/Personal_Complian ce_with_Information_Management_Principles_23_9_04.doc

3. The policy considers the impact of the Data Protection Act 1998 (DPA) and Freedom of Information (Scotland) Act 2002 (FOISA), including the Code of Practice on Records

Management and Code of Practice on Access to Scottish Executive Information. It also takes account of advice from SE Records Management Branch, SE Freedom of Information Unit and National Archives Scotland on the appropriate retention period for files and the materials they contain.


Information is a Corporate Resource

4. Information is a resource "owned" by HMIE, not by the individual who creates or receives information on behalf of the organisation.

5. With the enactment of DPA and FOISA, it is essential that the corporate record is reliable, complete and retrievable with a systematic records management system.

6. With this in mind, all HMIE files must be classified under the system of ciphers set out in the associated operational guidance and be organised according to file themes and topics contained within the HMIE filing structure which reflect our corporate responsibilities.

7. All files other than work-in-progress files will be integrated within the HMIE records management filing system, and be registered on a communal and fully indexed masterfile list.

This identifies who is responsible for management of each file. Guidance on file structure and use of database will be issued by December 2005.

8. Until implementation of an Electronic Record and Document Management (ERDM) system, the implementation of which is still under consideration, paper files are the corporate record, the authoritative source and repository of information. As such they must be maintained to ensure that they are complete, accurate, authentic and, subject to the necessary security requirements, accessible. This means that all relevant documents either received or generated electronically must be printed off and placed in the paper file. This filing system will as far as practicable be mirrored electronically in the shared G-Drive across HMIE and electronic copies of key documents and emails should be retained there as well as in the paper record.

9. If an ERDM system is implemented, the electronic record will assume the status of the corporate record. At this point paper copies of documents will not be placed on files. All documentation received in hard copy which is required as part of the corporate record will be scanned and held on the electronic record. It is not the intention to scan existing paper files as part of transition to an electronic record. That would be a significant exercise and resource intensive. This will mean that there will be a transitional period (until the dates for destruction of all paper files have been reached) where we will work with a record partially paper based and partially electronic. At this point paper copies of documents will not be retained on files.

Personal Responsibility

10. While HMIE "owns" the information created and held in its name, responsibility for the standard, accuracy and completeness of how this information is managed and used on a daily basis lies with individual staff. This means that individuals are responsible for ensuring that the information they create or receive is managed appropriately.

A detailed list outlining personal responsibilities can be found in annex 1 of this paper.


Information Accessibility

11. Following the principle that openness is at the heart of what we do, information we create or hold should be accessible to as wide an audience as possible, including to external contacts and the general public, when this is appropriate. Where information is held electronically, this means making the area where it is stored as open as practicable and, externally, publishing the information on the HMIE website or other public source.

Information sharing ensures that staff can find the information they need to do their jobs quickly and easily, avoiding the need to duplicate work.

12. In line with this principle, HMIE will make our information as accessible to as wide an audience as we can unless there is a specific reason not to. Whenever possible, we will publish our information. We have also produced a publication scheme which sets out the information that we publish, in what form it is published, and details of any costs which would be incurred in obtaining information.

The scheme can be accessed via: http://www.hmie.gov.uk/documents/publication/PUBLICATION%20SCHEME%20May%20

2005.pdf

13. The publication scheme does not list all of the information held or published by

HMIE. If information is sought from HMIE which is not included in the scheme, HMIE staff will determine whether this information can be disclosed by following the guidelines on handling requests for information which is found in: http://intranet/content/departments/HMIE/directorate4/CorporateSer/InfoManagement/docs/G uidance_for_handling_non_routine_foi_request_27_1_05.doc

We will comply with the protocol on FOISA handling and other obligations agreed between

HMIE and SE. This protocol can be accessed via: http://intranet/content/departments/HMIE/Dir4New/CorporateSer/InfoManagement/docs/FOI

_requests_&_other_requirements.doc

Detailed guidance on the application of the exemptions can be found in: http://intranet/content/corporate/guidance/information/openness/foi/exemptions/fex-00.asp

http://intranet/content/departments/hmie/directorate4/CorporateSer/InfoManagement/docs/hm ie_foi_caselaw_5_5_05.doc

Keeping Records of What We Do

14. We are required to keep records of what we do. It is critical that records of decisions and actions are complete and accurate. HMIE must be able to provide a full history of its decisions and actions and these must be accessible to those within (and, potentially, outside) the organisation who may reasonably require them. Full records might be needed for a number of reasons, such as demonstrating the chain of events and decisions that led to a particular course of action or to respond to requests for information. This means that details relevant to decisions or actions, including e-mails and notes that are needed to complete the

"story", are retained for an appropriate period and can be found if required.

15. HMIE has an agreed records management schedule to ensure that records are organised effectively and we meet our legal obligations. It is essential that we apply and adhere to the principles of that schedule, which are that we will:


 clarify what information is held and ensure that information is appropriately ordered and readily accessible by storing it appropriately within the corporate file structure;

 clearly annotate materials required as part of the corporate record with the reference number from the file list or with the file name. Electronic files need to be saved within the appropriate area on the G-Drive with a unique document title which clearly relates to the content of the material to assist with retrieval.

Including the date of the document within the title would also help assist retrieval.

 ensure that paper files in frequent use are held by file managers in their local office for ease of access;

 ensure that only current, relevant and consistent material is sorted and stored on the file registered on the corporate list;

 ensure that all materials generated within HMIE are retained only for as long as there is an operational or legislative need to do so. Checklists for retention of all evaluative material in each sector can be found via: http://intranet/content/departments/HMIE/directorate4/CorporateSer/docs/Combin ed_file%20checklist_16505.doc

;

 use the Scottish Executive Records Management Manual as a source of guidance and adhere in particular to Annex 2 of this guidance in relation to the retention and disposal of files. This document can be found by accessing: http://intranet/Content/Corporate/guidance/information/management/rmb/rmb.pdf

 follow the principles outlined by The National Archives as a source of guidance for retention of retention of FOISA materials. This guidance can be found by accessing: http://www.nationalarchives.gov.uk/recordsmanagement/advice/pdf/foi_sched_ret ention.pdf

 consider files for preservation if there is a specific reason to do so. Generally, this will involve those which are of genuine historical interest such as papers from

HMIE Management Board meetings. Guidelines for selecting records for preservation can be found by accessing appendix 3 of the Scottish Executive

Records management Manual;

16. Media containing sensitive information must be disposed of by:



Incineration; or



Shredding, or



Specific removal from ISU.

If facilities are not available locally, media may be sent to CISD Central Helpdesk for disposal.


Disposal of sensitive items must be logged where possible for future reference and to maintain an audit trail.

For more information see IT Security Policy and Standards section 7.5.4.

HMIE’s retention and disposal strategy can be found in annex 2 of this document.

Ensuring Information is Accurate and Fit for Purpose

17. HMIE staff have a responsibility to create and maintain information in a way that is appropriate for its intended purpose. We need to be able to rely on the information we hold to give us, the Scottish Executive Ministers and our external audiences confidence that our decisions are based on accurate and up to date information. We need to provide factually accurate answers in responses to requests for information and it is important that information we produce is seen to be authoritative. This includes the accurate capture of documents as a history of business activities and the accuracy of the content of an individual document as well as only using or recording personal information when there is a specific operational need to do so. Detailed guidance on the use of personal information can be found in: http://intranet/content/departments/HMIE/directorate4/CorporateSer/InfoManagement/docs/G uidance_on_use_of_Personal_Information_6_12_04.doc

Compliance with Statutory and Regulatory Requirements

18. This principle places a responsibility on HMIE staff to comply with guidance relating to legislative and regulatory requirements. It is essential that HMIE sets a positive example by complying fully with such requirements and it is in our own interests to do so since compliance will help us ensure that our information management practices are consistent and appropriate. Guidance that staff have to comply with includes Data Protection, Freedom of

Information, Copyright legislation and the Disability Discrimination Act. Further guidance on compliance with these authorities can be found via: http://intranet/content/departments/HMIE/directorate4/CorporateSer/InfoManagement/docs/D ata_Protection_Guidance.doc

http://intranet/content/departments/lps/cps/foi.htm

http://www.opsi.gov.uk/advice/crown-copyright/copyright-guidance/index.htm

http://www.disability.gov.uk/images_of_disability/access.html

19. Review of this policy

This policy is under constant review, and will be updated in line with emerging requirements.

SMG will review it at its 8 November meeting.

27 October 2005


2. It is the responsibility of HMII as individuals, national specialist, district inspectors or in other roles:

 when file managers to take responsibility for ensuring that their files are sorted properly and contain only relevant material;

 when MI, as file manager, ensure that all team members, including AAs and Lay

Members, return all documentation to them for filing or disposal in line with the relevant sectoral checklist;

 when MI, as file manager, ensure adequate administrative arrangements are agreed with their support staff to assist evaluation activities and ensure that files are sorted properly and contain only relevant material;

 when group chairs or task managers, as file managers, inform CS staff when new files are to be set up for new tasks, commissions or other purposes and;

 when file managers to ensure that papers which might be relevant to more than one file (for example a record of a visit to an establishment associated with a task should be recorded on the task file and the establishment intelligence file) are accurate, complete and annotated to highlight other relevant files;

Annex 1

Personal Responsibilities

1. It is the responsibility of Lead Inspectors with sectoral responsibility:

 to ensure that the evaluation guidance for their inspection or review model fully recognises the requirements of HMIE Records Management Policy and is “fit for purpose”;

 to ensure that evaluation material is recorded in a way compatible with the standards outlined in paragraph 2.

 when file managers, to review files on closure and in conjunction with the

HMCI/HMACI/DI/LI/NS as appropriate, decide whether they should be considered for preservation, and advise CS staff accordingly. In the case of permanent files, identify any materials worthy of preservation before “weeding” takes place. All material not considered for preservation should be destroyed in line with the retention and disposal strategy;

 to pass all appropriate papers and electronic records to CS staff for filing on registered files and electronic folders, annotated with the relevant file name and reference;

 to ensure that working documents held outwith the corporate record are kept to a minimum (generally for ongoing tasks) and are accessible to others. Working files should contain no sole or original documents and should be disposed of once the

HM Inspectorate of Education: Records Management Policy 27.10.05 task is complete and all materials required as part of the corporate record have been filed appropriately;

 to notify HMIE Information Manager of any transfer of responsibilities;

3. It is the responsibility of Office Managers with sectoral responsibility to ensure that administrative guidelines fully recognise this Records Management Policy. This includes prompting file managers in their offices to confirm that file management procedures are being adhered to appropriately.

4.

It is the responsibility of CS staff:

 to place materials on the current paper and electronic file on behalf of HMIE

 when file managers, to take responsibility for ensuring that their files are sorted properly and contain only current and relevant material

 to keep files, particularly evaluation files, complete and up to date in line with file managers instructions and file checklists;

 to alert the relevant file manager to any difficulties in keeping the file complete and up to date;

 to ensure that locally held paper files are properly managed in line with file manager instructions and that material is filed promptly in date order;

 to destroy all paper and electronic materials in line with file checklists and retention/disposal guidelines;

 to open new files and ensure that they are entered on the masterfile index, and include any relevant file notes as instructed by file managers and;

 to dispose of files marked for destruction by file managers, and record the corporate masterfile list, appropriately

5. It is the responsibility of the Information Manager:

 to ensure detailed operational guidance is available for HMIE practitioners;

 to advise on any aspect of records management, and promote good practice

 to arrange adequate training for all HMIE staff, AAs and LMs on effective records management practice and the requirements of FOISA and;

 to oversee the maintenance of the corporate masterfile list and make amendments as required by file managers


Annex 2

Retention and Disposal strategy

File Type

General Inspection and Review files

Scope

Section one of file to contain intelligence material collected since previous evaluation. Section two contains evidence used to inform evaluative reports and administrative papers from GIRP. Section three to contain evidence used to inform any evaluative followthrough report.

Electronic evidence template databases

Contains evidence used to support evaluative reports

Disposal

Files to be reviewed annually for weeding and all material not of continued procedural use or considered worthy of historical preservation, to be destroyed. Sections two and three to be weeded in accordance with relevant sectoral file checklist and all material held on

Section one not deemed worthy of preservation to be disposed of one year after publication of evaluation report unless of continued procedural use.

All evaluation material to be destroyed one year after publication of relevant evaluative report unless followthrough evaluation is required in which case material should be retained until one year after followthrough report published.

Remarks

These are

“permanent” files and will only be closed if material has been deemed of historical interest.

They would then be closed and submitted to NAS for preservation. In these circumstances, a fresh file with a new reference will be opened.

Only QI values and

MPAs will be retained so colleagues need to ensure that they collect any other information required within this one year period. Any 'other' information extracted to central database should not be attributable.


File Type

Policy Liaison with

Scottish Executive

Other Liaison with

Scottish Executive

Divisions and external contacts

Professional casework advice provided to Scottish

Executive Divisions

Scope

Contains copies of any finalised professional policy advice to Scottish

Ministers.

Contains records of other communications with Scottish

Executive Divisions and external contacts and their activities other than casework advice.

Contains copies of any professional casework advice provided to Scottish

Executive Divisions

Disposal

Files to be reviewed every five years for weeding and material more than five years old to be destroyed

(unless of continued procedural use or otherwise agreed with contact). Files to be considered for preservation/destruction five years after last paper.

Files to be reviewed every five years for weeding and material more than five years old to be destroyed

(unless of continued procedural use or otherwise agreed with contact). Files to be considered for preservation/destruction five years after last paper.

Close file one year after last paper (unless of continued procedural use or otherwise agreed with contact) and review for destroy after five years.

Remarks

These are

“permanent” files in the sense that they will remain live as long as material is of procedural use. A separate file to be opened for each relevant Scottish

Executive Division.

These are

“permanent” files in the sense that they will remain live as long as material is of procedural use.

Three Separate files to be opened for each relevant

Division and external contacts to hold records of general information and correspondence, meetings and working groups.

HMIE are expected to develop protocols to ensure that no duplication of materials occurs following provision of advice. This will usually mean that advice will become the property of

Scottish Executive.


File Type

HMIE external plans and strategies.

HMIE internal plans and strategies

HMIE internal structures and corporate operations

Honours

Scope

Contains records of external strategic and management policies and plans including

Corporate Plans.

Contains records of internal strategic and management policies together with HMSCI notices and briefings.

Contains records of meeting papers guidance, business procedures, staff notices and briefings.

Contains case records of candidates and contributions to

Honours Rounds

Disposal

One file for each ongoing strategy or plan. Close file part

five years from first paper or when files become too bulky.

Review for destroy five years after closure unless being considered for preservation. One file for each time limited strategy which will be closed at the end of relevant period.

One file for each ongoing strategy.

Close file part five years from first paper or when files become too bulky. Review for destroy five years after closure unless being considered for preservation. One file for each time limited strategy which will be closed at the end of relevant period.

One file for each structure. Unless of continued procedural use, close file after two years or when files become too bulky. Review for destroy after five years unless being considered for preservation.

Close five years after relevant round.

Destroy five years after closure.

Remarks

New file parts to be opened as required.

Consult with NAS about preservation.





New file opened for each round.


Freedom of

Information

Contains casework material following request

Close one year after material included in schedule is no longer subject to challenge.

Destroy two years after closure

All materials scheduled for destruction which are retained due to an

FOI request should be retained for an additional six months after request is no longer subject to challenge.

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