Records Management and Data Quality Protocol

Contents

INTRODUCTION.
QUICK REFERENCE POINTS
KEY DEFINITIONS
SCOPE
KEY LEGISLATION / FRAMEWORK
MANAGING RECORDS
THE RECORDS LIFECYCLE
WHAT IS A RECORD?
RECORD CREATION
LOGS
USE / STORAGE
RETENTION
DESTRUCTION
DATA QUALITY
INTERNAL COMMUNICATIONS
APPLICATION AND AUDIT
APPENDIX A: CREATING A SUMMARY HR RECORD
APPENDIX b: KEY RECORDS RETENTION SCHEDULE
APPENDIX C: PRAGMATIC ANNUAL RECORDS REVIEW

INTRODUCTION

QUICK REFERENCE POINTS

• Keeping accurate, quality records provide evidence of the how Hopscotch Nurseries and Holiday Clubs operates
• It allows Hopscotch Nurseries and Holiday Clubs to be effective and accountable
• Keeping personal data for longer than its intended purpose (without suitable rationale) is unlawful
• Staff must be aware of how they are required to create records – in the shared space or approved software
• Staff must use and access records as defined by company policy including managing paper and digital records according to proper standards
• Staff must use good naming conventions and version control to maintain effective record keeping
• Offsite storage must be properly approved and tracked 

KEY DEFINITIONS

Personal Confidential Information            

SCOPE

KEY LEGISLATION / FRAMEWORK

• UK GDPR / Data Protection Act 2018
• Human Rights Act 1998

MANAGING RECORDS

• Information is a corporate asset and as such, is an important source of administrative, financial, legal, evidential and historical information.
• It is vital to Hopscotch Nurseries’ and Holiday Clubs future operations, for the purposes of accountability and for an awareness and understanding of its history; information is the corporate memory of Hopscotch Nurseries and Holiday Clubs.
• Information may be held on paper, USB sticks, computer file or printout, laptops, tablets, mobile phones or even heard by word of mouth or telephone.
• This protocol provides general guidance about records management and data quality.
• Without high standards of information quality, supported by systematic processes and practice, we cannot support the delivery of high-quality services and continue to improve.

THE RECORDS LIFECYCLE

• The diagram below identifies the records management lifecycle, and each part of the lifecycle needs to be consistently managed to encourage high standards.



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WHAT IS A RECORD?

• A record is information that memorialises and provides evidence of activities performed, events occurred, results achieved, or statements made. Records are created/received by an organisation routinely in the process of its business or in pursuance of its legal obligations.
• Records include accounts, agreements, books, drawings, letters, magnetic/optical disks, memos, micrographics, etc. Generally speaking, ‘records’ function as evidence of activities, whereas ‘documents’ function as evidence of intentions.
• Some activity will be predefined as a record that needs to be kept, such as financial or employment records. Other records are kept because they are a unique instance of an event such as a business document or email.

RECORD CREATION

• Records must be created within company systems or stored in the shared network
• Records must not be stored in personal drives or mobile devices such as mobiles or memory sticks
• The filing and naming of records should follow the Function-Activity-Transaction approach.
• This means that the top-level folder would be named in line with the function, the second level named in line with the activity and the then in line with the transaction.



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LOGS

• Hopscotch Nurseries and Holiday Clubs will maintain a list of all systems (digital and electronic) that hold records including the type of records they hold (staff, service users etc).
• The list will identify whether the records within the system are classified as containing personal or special category data.
• Access to record keeping systems will be limited to staff with a legitimate reason to access those records.
• Hopscotch Nurseries and Holiday Clubs will undertake regular checks to ensure that records containing personal data are accurate, adequate and not excessive.

USE / STORAGE

Paper Records

• In order to establish the authenticity of paper records, the records must be held in a way that allows Hopscotch Nurseries and Holiday Clubs to audit who has accessed it.
• Paper records must be kept in a safe, dry and secure location
• If paper records are being kept in off-site storage, they must be fully tracked so that Hopscotch Nurseries and Holiday Clubs are fully aware of the location of records at all times
• Offsite storage providers must be approved by the DPO

Digital Records

• Digital information must be stored in such a way that throughout the lifecycle it can be recovered in an accessible format
• Systems for storing digital records must provide information about those who have accessed the record.
• When using a digital record being within the shared network such as a Word or Excel document, care must be given to providing ‘metadata’
• This will include identifying the author, version, changes made, owner of the document
• All information relating to a specific record must be stored together. For example, email messages related to a specific recruitment campaign must be stored in the network Recruitment folder alongside the Application Form and Interview Sheet.
• Hyperlinks or embedded documents must still work when the document is transferred to different media or later versions
• Occupational Health records should not be held with the main employee record

RETENTION

• Once a record is no longer being used for its primary purpose, it should be appraised to consider whether and if so, how long, it should be retained by Hopscotch Nurseries and Holiday Clubs.
• Retaining records for longer than the intended purpose in identifiable form and without an alternative lawful basis is a breach of Data Protection legislation
• Hopscotch Nurseries and Holiday Clubs uses the National Archives guidance to assign retention periods. Some key records and their retention periods have been identified at Appendix C.
• Staff should have access to a list of key records and their retention periods for that particular department. If you do not have this, please contact the DPO
• Where the record is being retained, there should be a documented consideration of whether the information could be de-identified (direct or indirect identifiers removed) to reduce the risk of an information breach
• Each year, a records management review should be performed to ensure that records are not being kept on personal drives and are not being kept for too long. A guidance document has been provided at Appendix D.

DESTRUCTION

Paper Records

• Paper records can be incinerated, pulped or shredded (using a crosscut shredder) under confidential conditions.
• National guidelines provide that confidential records must be shredded to no larger than 4mm x 15mm micro cross-cut to destroy sensitive data
• Do not use the domestic waste or put them on a rubbish tip, because they remain accessible to anyone who finds them.
• Destruction implies a permanent action so records cannot be retrieved.
• Staff must keep accurate records of destruction and appraisal decisions.

Electronic Records

• Destruction of hard assets, like computers and hard drives and backup tapes, must be auditable in respect of the information they hold.
• An electronic records management system will retain a metadata stub which will show what has been destroyed.
• The Information Commissioners Office has indicated that if information is deleted from a live environment (but remains in back up) and cannot be readily accessed then this will suffice to remove information for the purposes of the Data Protection Legislation.

DATA QUALITY

• It is understood that errors and inaccuracies will occur in Information.
• Systems, process and analysis during the lifecycle of the information need to identify the causes of any errors, the relevant margin of error introduced into any subsequent use of the Information and the appropriate action taken.
• This includes understanding the context of any Information or data set, to ensure that “outliers”, results that fall outside expected ranges, are investigated to determine if there are any resulting Information Quality concerns.
• It is important to determine and maintain a view of expected ranges of information to support the principles of Information Quality.
• A Data Protection Impact Assessment should be completed for new processing activities to determine how data quality will be maintained
• Information Asset Owners should determine and document the specific data quality measures in place for the Information Asset
• Information coming into Hopscotch Nurseries must be checked for accuracy and completeness
• Where incomplete, records should be returned to the sending organisation and the issues flagged with the appropriate lead
• Manual quality checks should be completed on correspondence containing Personal Confidential Information
• Systems should have the capacity to run data quality reports to identify duplications or incomplete records
• Procurement of systems should include built in measures to maintain data quality such as reduction of free text boxes and the use of drop-down lists
• Integration with other systems should consider data validation and the potential for errors requiring manual intervention
• Data Quality audits must be completed regularly and the results reporting into the Data Protection Lead
• Where errors are identified, appropriate mitigation is required. This includes correction, where relevant, analysis of process and appropriate action, and ongoing monitoring.
• Understanding the cause of error and its likely consequence are a key component of improving Information Quality or managing issues that cannot be addressed through appropriate controls.

INTERNAL COMMUNICATIONS

• All written internal communications, including emails, instant messages (e.g. Microsoft Teams, and in some cases WhatsApp), and collaborative notes may be disclosable in the event of a Subject Access Request (SAR). This applies even where the content is informal or written in a private or personal tone.
• The organisation recognises that not all communications form part of our corporate memory and need to be retained. Routine deletion of non-essential messages is both permissible and encouraged, provided this occurs in accordance with our retention schedule and not in response to a specific request for information.
• Once a SAR has been received, it is a criminal offence under section 173 of the Data Protection Act 2018 to delete, conceal, or alter personal data with the intent of preventing disclosure. All relevant records, including those stored in email or chat platforms, must be preserved from that point forward.
• Staff should avoid using communication channels to share views or commentary about colleagues, performance issues, or sensitive matters. Even private messages may be within scope of a SAR and could lead to reputational, legal, or interpersonal difficulties if disclosed.
• The organisation reserves the right to audit compliance with retention and deletion practices. Where necessary, staff may be asked to review and reduce non-essential digital communications in accordance with data minimisation principles.

APPLICATION AND AUDIT

• Staff must confirm that they have read and understood this protocol
• This protocol will be reviewed annually or sooner in the event of significant learning or change
• This protocol should be read in conjunction with the other protocols in the Data Protection and Security policy suite

APPENDIX A: CREATING A SUMMARY HR RECORD

Delete / Destroy the data (this is because it has either hit or exceeded its retention period. There are some documents which might have a shorter retention period however, it is disproportionate to expect personnel files to be reviewed each year to identify specific documents for destruction. Instead, the 6-year review allows for a group of documents to be deleted together as a proportionate response, reducing risks to the rights and freedoms of employees.)
Retain the document as a record itself (this is mostly for records that are required to be retained until the person is either 75 or 100 years old. Some files will be reviewed again when the person is 75 and a final deletion will be made when the person is 100)
Make summary notes and delete/ destroy the original. It is recommended that a summary sheet is added to the front of the summary record for notes made relating to these records.

APPENDIX b: KEY RECORDS RETENTION SCHEDULE

APPENDIX C: PRAGMATIC ANNUAL RECORDS REVIEW

Staff email requesting written confirmation regarding their personal accountability.

• Please confirm that any records are stored within the shared drive or on the software system and not in your individual or laptop drives (good practice to obtain email confirmation from each staff member)
• Please confirm that you have moved personal data related to families from your email folders into the shared drive to form part of the corporate memory

Undertake a review of the contents of the shared drive and filing cabinets.

• Any records related to incidents that are older than 10 years
• Any records related to serious incidents that are older than 20 years
• Any records related to complaints that are older than 10 years
• Any application forms or CVs that are older than 7 months (including in inboxes) – for unsuccessful candidates
• Any records related to payroll activity that are older than 7 years (only where employee has left
• There are no full personnel files that are older than 6 years (once person has left) providing a review and summary has been made
• There are no Disclosure and Barring Certificates retained (only the reference number should be retained)