The Records Management Policy provides a framework for managing St George’s, University London (SGUL) records and information. The policy provides a primary framework for all other records management policies.
Records belong to SGUL rather than an individual or group and are both an asset and an important source of legal, evidential, research, student, and historical information. Records are vital in understanding the University’s history and current activities.
A record is information created, received, and maintained as evidence and information by an organisation or person, in pursuance of legal obligations or in the transaction of business.1 At SGUL this includes records generated by the Principal’s Office, Professional & Academic Services, Academic Institutes, and Joint Faculty of Health Social Care and Education.
1 Definition of “records” from BS ISO 15489-1:2001 Information and documentation – Records management – Part 1: General
This policy applies to all records created and received during the conduct of the University’s activities. Records are held in different formats included, but are not limited to:
- Medical equipment and specimens
The Records Management Policy’s purpose is to ensure SGUL records are effectively managed according to regulatory and organisational requirements by all staff whether permanent, contracted, or temporary to ensure:
- All records are held in the appropriate repository and have adequate metadata applied to them in order to manage them throughout the lifecycle.
- All records are either disposed of or deposited into the Archive once the retention period has been met.
- The University can demonstrate it is complying with its legal and regulatory obligations.
- The contents of records can be trusted as being a full and accurate representation. The record will be complete and unaltered, with clear and traceable indications of authorised annotations or additions.
- Records are usable. All records can be found, retrieved, reproduced if required, and interpreted.
Furthermore effective records management:
- Allows the University to identify records of historical significance and ensure they are placed in the Archive.
- Ensures records are classified according to the University’s classification scheme and handled in accordance with the scheme.
- Promotes a culture that supports the value of effective records management and supports a records management program.
- Reduces the amount of hardcopy items held in departments and the amount of data stored in IT systems that is then backed-up.
- Supports the work undertaken by the Freedom of Information Officer and the Data Protection Officer.
The Records Management policy must be followed by all SGUL employees and contractors who create and handle records as part of their day to day activities at the University.
3.1 Roles & Responsibilities
1. The Information Strategy Committee ratifies the Records Management Policy
2. All Heads of Department are responsible for:
a. Agreeing with the Records Manager retention periods for records owned by their departments.
b. Ensuring approved records management procedures are implemented and adhered to in their departments.
c. Considering the information management lifecycle and information management implications when planning new systems or procedural changes.
d. Identifying a member of their department who can act as a records management champion and take on roles including:
i. Acting as the records management subject matter experts for their department.
1. Champion records management processes and policies within their departments.
2. Supporting their teams in records management matters.
3. Advise on destructions.
4. Create and maintain destruction certificates for departmental disposals.
5. Alert the Archivist to records for transfer to the Archive.
3. The Director of Information Services is responsible for:
a. Maintaining systems of records ensuring confidentiality, integrity, and availability (CIA) of the records is maintained.
b. Ensuring the system conforms to records management policy.
c. Ensuring that authorised destructions or deletions are actioned.
d. The Director of Information Services is the Senior Information Risk Owner (SIRO) taking overall ownership of SGULs Information Risk Policy.
4. The Records Manager is responsible for:
a. Developing and supporting records management activities at the University, monitoring compliance, and providing advice and support for all records produced across the University.
b. Training department champions in what has to be done at the University to achieve compliance with records management policies and practices.
5. The Data Protection, Freedom of Information, and the Information Risk and Security Officers are responsible for:
a. Advocating the management of records in accordance with the relevant information security and records management policies.
6. All staff, whether permanent, contracted, or temporary are responsible for ensuring:
a. Records are stored in the appropriate repository.
b. Records have a retention schedule and secure classification is applied to records.
c. When a member of the team moves on from their current role or leaves the University any records in their care are passed to their manager or a colleague for safekeeping.
SGUL records must be managed throughout the lifecycle:
Create == Classify == Use == Store == Review for destruction or transfer to Archive
All staff whether permanent, contracted, or temporary are responsible for creating and maintaining accurate records of their work undertaken for the University.
It is essential that our records are distinguishable, accessible, and retrievable throughout the lifecycle. Therefore meaningful metadata should be assigned to our records.
University records should be stored in the correct location. If they are borrowed or moved this should be recorded.
All records must be stored in the appropriate location or system.
Review for Destruction or Transfer to the Archive
Destruction reviews are the final stage in a records lifecycle. Destruction reviews do not always lead to the destruction of record. The outcome of the review might be a
hold placed on the record as it is still required to support the work of the University or the record could be transferred to the Archive.
However a record should never be kept for longer than necessary and should be disposed of when the retention period expires. Retaining records longer than necessary without a reason exposes the University to legal and regulatory risk.
5. Retention Schedules
SGUL has legal obligations to retain certain records for a defined period of time; the University may also set the retention period for some records at its own discretion.
Retention schedules benefit the University by standardising our approach to retention and disposal and by following the schedules we can all ensure compliance with legislation, regulations, and University best practice.
Retention schedules apply a set period to retain a record for before it is reviewed for disposal or transfer. However this only applies to the controlled record; duplicates made for working purposes should be kept for only as long as required and then destroyed; and duplication should be avoided wherever possible.
Records should never be retained past their retention period “just in case” and few records have a rationale to be retained indefinitely.
6. Preservation Holds
A preservation hold which can also be known as a preservation order, hold order, document hold, or litigation hold is a legal instruction directing an organisation to refrain from destroying or modifying records or information no matter what format they are held in that could be have bearing on a pending or anticipated investigation or lawsuit.
Upon termination of the hold records that were impacted by the hold will revert to the normal and the appropriate retention schedule applied once again.
7. Notable Records
The Archives is home to records that document the history, functions, and development of the University. When carrying out destruction reviews you may find records that you believe should be transferred to the Archives as they are of historical significance to the University. Examples include but are not limited to:
- Medical school records e.g. minute books
If you would like an item to be considered for transfer to the Archives, the Archivist should be consulted. The Archivist will evaluate the records to determine if they should be added to the Archive. The Archivist’s decision is final and cannot be overridden by the record owner.
Additionally there may be records of note such as committee papers or public enquiry submissions that the University wish to keep and this will be recorded in the retention schedules.
Any department wishing to assess their compliance with this policy should contact the Records Manager for assistance.
Data Protection Policy
Freedom of Information Policy
BS ISO 15489-1:2001 Information and documentation – Records Management – Part 1: General
BS 10008 Evidential Weight and Legal Admissibility of Electronic Information 2014
Retention & Disposal Policy
The SGUL Retention Schedules
Archive Collections Development Policy
Information Security Policy