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Executive Summary
HEE’s records are its corporate memory, providing evidence of actions and decisions and representing a vital asset to support daily functions and operations. They support policy formation and managerial decision-making, protect the interests of HEE and its partners, the rights of its staff and members of the public with whom it has dealings. They support
consistency, continuity, efficiency and productivity and help HEE to deliver its services in consistent and equitable ways.
This policy sets out HEE’s approach to records management, through the proper control of the content, storage and volume of records, reduces vulnerability to legal challenge or financial loss and promotes best value in terms of human and space resources through greater coordination of information and storage systems
Contents Paragraph Page 1 Introduction 5 2 Purpose 5 3 Scope 5 4 Responsibilities 6 5 Objectives 6 6 Standards to be maintained 7
7 Transfer of records to The National Archives 8
8 Personal Documents 8
9 Equality Impact Assessment 8
10 Education & Training Requirements 8
11 Associated Documents 9
12 References 9
Annex A Procedure for the creation, maintenance and disposal of HEE records
12 Table 1 Summary: Business & Corporate (Non-Health) Records
Retention Schedule
1. Introduction
1.1. Health Education England (HEE) is dependent on its records to operate efficiently and account for its actions. This policy defines a structure for HEE to ensure adequate records are maintained and they are managed and controlled effectively and at best value, commensurate with legal, operational and information needs. 2. Purpose
2.1. HEE’s records are its corporate memory, providing evidence of actions and decisions and representing a vital asset to support daily functions and operations. They support policy formation and managerial decision-making, protect the interests of HEE and its partners, the rights of its staff and members of the public with whom it has dealings. They support consistency, continuity, efficiency and productivity and help HEE to deliver its services in consistent and equitable ways.
2.2. Records management, through the proper control of the content, storage and volume of records, reduces vulnerability to legal challenge or financial loss and promotes best value in terms of human and space resources through greater coordination of information and storage systems.
2.3. All HEE records are Public Records under the Public Records Acts 1967 and must be kept in accordance with following statutory and NHS guidelines:
• Public Records Acts 1958 and 1967 • Data Protection Act 1998
• Freedom of Information Act 2000 • HSC 1999/053 For the Record
• Audit Commission, Setting the Record Straight, 1995
• International Standard on Records Management (ISO 15489)
2.4. Records Management is a core component of business planning and is integrated fully into the annual business planning cycle
3. Scope
3.1. This policy relates to all records held by HEE relating to information created or received in the course of business and captured in readable form in any medium, providing evidence of the functions, activities and transactions of the organisation. They include:
• Administrative records;
• Records in electronic format; and
• Personal data as defined by the Data Protection Act 1998.
3.2. They do not include copies of documents created by other organisations such as Department of Health, kept for reference or for information only.
3.3. All records created in the course of the business of HEE and corporate records are public records under the terms of the Public Records Act 1958 and 1967. This includes email messages and other electronic records.
4. Responsibilities
4.1. The Chief Executive has overall responsibility for ensuring that records are managed responsibly within the Institute.
4.2. HEE’s Corporate Secretary is responsible for day to day co-ordination of records management in the organisation, identifying key corporate records and providing guidance and advice on their management and retention.
4.3. The Senior Leadership Team will be responsible for ensuring that the policy is implemented across HEE.
4.4. It is the responsibility of all staff to ensure that they keep appropriate records of their work and manage those records in keeping with this policy and with any relevant guidance produced by the Institute.
5. Objectives
5.1. There are seven main objectives of this policy.
5.2. Accountability – that adequate records are maintained to account fully and transparently for all actions and decisions in particular:
• To protect legal and other rights of staff or those affected by those actions • To facilitate audit or examination
• To provide credible and authoritative evidence
5.3. Quality – that records are complete and accurate and the information they contain is reliable and their authenticity can be guaranteed
5.4. Accessibility – that records and the information within them can be efficiently retrieved by those with a legitimate right of access, for as long as the records are held by the organisation
5.5. Security – that records will be secure from unauthorised or inadvertent alteration or erasure, that access and disclosure will be properly controlled and audit trails will track all use and changes. Records will be held in a robust format which remains readable for as long as records are required.
5.6. Retention and disposal – that there are consistent and documented retention and disposal procedures to include provision for permanent preservation of archival records
5.7. Training – that all staff are made aware of their record-keeping responsibilities through generic and specific training programmes and guidance and where significant new systems are introduced, tailored training programmes are put in place to guide staff through the process of change.
5.8. Performance measurement – that the application of records management procedures are regularly monitored against agreed indicators and action taken to improve standards as necessary.
6. Standards to be maintained
6.1. This policy will be implemented by a series of programmes of work which will deliver clear practice and procedures to include:
6.2. Records creation (Annex A)
• Creation of adequate records to document essential activities;
• Structured information (content management, version control) to facilitate shared systems based on functional requirements;
• Referencing and classification for effective retrieval of accurate information; • Documented guidelines on creation and use of record systems
6.3. Records maintenance (Annex A)
• Assignment of responsibilities to protect records from loss or damage over time; • Access controls to prevent unauthorised access or alteration of records;
• Defined security levels for access to electronic records and procedures to amend access authorisations as appropriate when staff move
• Tracking systems to control movement/audit use of records; • Identification and safeguarding key or vital records;
• Arrangements for business continuity; • Training and guidance
6.4. Records disposal (Annex A)
• Systematic retention schedules and procedures for consistent and timely disposal;
• Central storage systems for records requiring long-term retention to include electronic archiving systems;
• Mechanisms for regular transfer of records designated for permanent preservation to appropriate archives
• Secure destruction of confidential information including sensitive personal data 6.5. Training and guidance
• Inclusion of records management functions in job processes where appropriate; • Generic and specific guidance on record-keeping standards and procedures; • Training programmes
• Development of effective indicators and review systems to improve records management standards.
7. Transfer of records to the National Archive (Public Records Office)
7.1. All records produced HEE, in any media, are public records and, as such, are subject to the Public Records Act 1958. However, not all public records are worthy of permanent preservation after their administrative usefulness has ended.
7.2. The Corporate Secretary will identify and select any notable or precedent cases which are likely to warrant permanent preservation in the National Archive. 8. Personal Documents
8.1. It is recognised that staff will occasionally use their work computers for their own personal use, which is for material not related to the business of HEE.
8.2. Such material must not be stored on the shared file server, but on the hard drive of the individual’s PC. It should be understood therefore that this information is not secured and it is the responsibility of the individual member of staff to organise back up facilities if this is required.
9. Equality Impact Assessment (EIA)
9.1. This policy applies to all HEE staff irrespective of age, race, colour, religion, disability, nationality, ethnic origin, gender, sexual orientation or marital status, domestic circumstances, social and employment status, HIV status, gender reassignment, political affiliation or trade union membership. In implementing the Records Management policy, HEE will implement reasonable adjustments where appropriate.
10. Education and Training Requirements
10.1. There is an obligation upon every line manager to ensure that staff are informed and instructed with regards to information governance and that such activities are properly recorded and records maintained.
10.2. As an employee of HEE, you are required to participate in information governance training relevant to you and to read this policy document carefully and raise any queries that you may have with your line manager or the Corporate Governance Team.
11. Associated Documentation
Acceptable use of Mobile Devices & ICT Facilities Freedom of Information Publication Scheme Information governance
Induction
Procedure for the creation, maintenance and disposal of HEE records
12. References
Public Records Acts 1958 and 1967 Data Protection Act 1998
Freedom of Information Act 2000
Audit Commission, Setting the Record Straight, 1995
International Standard on Records Management (ISO 15489) Records Management, NHS Code of Practice, Part 2 (2nd Edition)
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