Records are examined or reviewed in order to determine if they should be destroyed, retained for further consideration, or permanently preserved.
This is because their full value could not be determined at an earlier stage.
Procedures should be put in place in all organisations to ensure that appropriately trained personnel appraise records at the appropriate time.
Records should be kept for as long as they are needed to meet the operational needs of the organisation, and legal and regulatory requirements.
The Public Record Office of Northern Ireland (PRONI) has responsibility for assessing the value of records for historical/research purposes and deciding whether or not they should be permanently preserved.
The Records Management Officer within the organisation should decide the most appropriate person(s) to carry out file review(s) in line with the Organisation’s Disposal Schedule.
This should be a senior manager with an understanding of the subject area.
If an officer of the appropriate grade is not available in the branch, the next appropriate highest-ranking officer with an understanding of the subject area should be selected to complete the review.
The reviewing officer should:
- understand the business process and the importance of the records to that process
- assess its importance as evidence of what was done, why, when, where and by whom which forms the basis for public and internal accountability
- understand the legal or regulatory retention requirements that must be complied with and what records need to be retained in order to do so.
- determine its value as a source of information about the Organisation, its operations, relationships and environment
- consider only the administrative value of the records and ask these useful questions to arrive at their decision
- is there a continuing need to retain this record for the conduct of day-to-day business?
- is there clear evidence of a future need for constant reference to this record?
- will it be needed to deal with enquiries in the future?
- how many enquiries are likely?
- is the information needed for statistical analysis within the organisation?
- are there bodies of statistical information upon which future policies and forecasts may be based?
- is the information required for conducting legal proceedings in the event of a legal action being taken by, or against the organisation?
- is there a legal requirement to retain these records (e.g. Health and Safety regulations)?
- is there a financial need to retain these records (e.g. for audit purposes)?
- is there a professional reason (e.g. continuity of care, research, audit)?
- is the information significant because it provides precedents or is required for authorisation purposes?
- is the information otherwise available whether within the HSC, or in published form?
- are there unsubstantiated allegations which need to be removed?
Where there are records which have been omitted from the Disposal Schedule in Part 2 of GMGR, or when new types of records emerge, Information Management Branch (IMB) in the DoH should be consulted.
A file may be reviewed a number of times:
On closure - A file should be reviewed immediately when it is closed. The long term value may be quite clear at this stage.
First review - Review five years after the file was closed. Procedures need to be put in place to ensure that these records are reviewed at the appropriate stage.
Second review - There may be occasions when it proves impossible to reach a decision on a file at first review. Such files may be put away for examination at a later stage.
The “second review” should take place 20 years from the date of the last paper on the file and not more than 25 years from the date the file was opened.
The reviewing officer can make one of the following decisions at first review:
Immediate destruction - Where the file has no further administrative value the reviewing officer should arrange for PRONI to examine and authorise destruction if they consider there is no need to preserve.
Retain for 5/10 years - If there is short to medium term administrative need the file can be retained for 5 or 10 years. When the retention period elapses the reviewing officer should arrange for PRONI to examine and authorise destruction if they consider there is no need to preserve.
Retain for 15 years - Where the file is required for long-term administrative reasons it is retained until second review is due.
The second review exercise gives PRONI the opportunity to decide if files, already retained for 15 years for administrative reasons, are suitable for permanent preservation.
The file should be examined by PRONI first and if they decide it has no long-term preservation value, the file should be passed to the reviewing officer to decide if the file can be destroyed.
The reviewing officer must decide how long to retain records that are not required for preservation by PRONI and where possible consider destruction.
If however an administrative need to keep them is established, then the reviewing officer must document the reasons why.
The options available to the reviewing officer are:
Destroy immediately - If the file has no further administrative value it should be destroyed.
Retain - If the file is still required for administrative need, the reviewing officer must document the reasons for the specified retention. The file should then be destroyed on the disposal date, without further referral to the reviewing officer.
In exceptional circumstances a 'Special Review' may be carried out by PRONI.
This means that the records will be made available to PRONI, without prior investigation by the functionally responsible organisation, in order to assess their value as historical records.
Where the disposal schedule dictates a special review, the Records Management, Cataloguing and Access section of PRONI should be contacted to determine and agree the practical arrangements for the special review.
Organisations must have procedures in place for recording the disposal decisions made following appraisal.
An assessment of the volume and nature of records due for appraisal, the time taken to appraise records, and the risks associated with destruction or delay in appraisal will provide information to support an organisation’s resource planning and workflow.
Records should be closed (i.e. made inactive) as soon as they have ceased to be in active use other than for reference purposes.
An indication that a file of paper records or folder of electronic records has been closed, together with the date of closure, should be shown on the record itself as well as noted in the index or database of the files/folders.
Where possible, information on the intended disposal of electronic records should be included in the metadata when the record is created.
All paper files should be closed:
- no later than 5 years after opening (with some exceptions e.g. patient/client case files, personnel files relating to individual employees)
- as directed in Disposal Schedules (Local disposal schedules should advise when files should be closed)
- when the depth of papers reaches 2.5cm limit. File covers are designed to be a protection for the records contained within. When the depth of papers reaches more than 2.5cm the file becomes hard to manage. Where this is the case the file should be closed and a continuation file opened
- when the subject matter is finished
- at the end of a calendar or financial year where the file title relates to a particular year
- when no new papers have been added to the file for two years. A new file can be opened again if it becomes appropriate. Exceptions to this rule will be patient/client case files, personnel files relating to individual employees
Once a file is closed no further papers should be added. A yellow closure sheet must be inserted to every file closed.
This reminds staff requesting a closed file that no further papers should be added.
At this stage you should record on the file cover the date:
- of the earliest and latest papers
- of first review
- the file is due to be destroyed
- the file should be transferred to PRONI, whichever is appropriate
The word closed should be stamped on the outside of the file, using a ‘closed’ rubber stamp.
If, when a file is being closed, the subject to which it relates remains ‘live’ a continuation file should be opened.
The storage of closed records should follow accepted standards relating to environment, security and physical organisation of the files.
Most organisations’ records, even administrative ones, contain sensitive or confidential information.
It is therefore vital that confidentiality is safeguarded at every stage of the lifecycle of the record, including destruction, and that the method used to destroy such records is fully effective and ensures their complete illegibility.
Care must be taken when destroying records.
The basic procedures for destruction are:
|Record Type||Disposal method|
Information in public domain
|Non sensitive files/records
Files/records not available to the public
|Torn into small pieces, bagged for collection by approved disposal firm|
|Sensitive records restricted||Strip shredded, bagged for collection by approved disposal firm|
|Sensitive records confidential||Strip shredded, bagged for collection by approved disposal firm|
|Secret and Top Secret||Cross-cut shredded bagged for collection by approved disposal firm|
|Optical/Magnetic Media||The HSC and DHSSPS ICT/IT Security Policy should be consulted and followed in relation to the disposal of such media|
Records (including copies) not selected for archival preservation and which have reached the end of their administrative life should be destroyed in as secure a manner as is appropriate to the level of confidentiality or protective markings they bear.
This can be undertaken on site or via an approved contractor.
It is the responsibility of the organisation to ensure that the methods used throughout the destruction process provide adequate safeguards against the accidental loss or disclosure of the contents of the records.
Contractors, if used, should be required to sign confidentiality undertakings and to produce written certification as proof of destruction.
Destruction should follow the British Standard BS EN 15713:2009 Secure destruction of confidential material Code of practice.
A record of the destruction of records, showing their reference, description and date of destruction should be maintained and preserved by the Records Manager, so that the organisation is aware of those records that have been destroyed and are therefore no longer available. Disposal schedules would constitute the basis of such a record.
If a record due for destruction is known to be the subject of a request for information, or potential legal action, destruction should be delayed until disclosure has taken place, or if the authority has decided not to disclose the information, until the complaint and appeal provisions of the Freedom of Information Act have been exhausted or the legal process completed.
Each organisation should have a retention/disposal policy that is based on GMGR.