Study of Records Lifecycle RRS introduction

Study of Records Lifecycle RRS introduction

Higher Education Institutions: HEI Record Retention Schedule (RRS)

RRS  Introduction

What is a Records Retention Schedule?

A Records Retention Schedule is a control document that sets out the periods for which an organisation’s business records should be retained to meet its operational needs and to comply with legal and other requirements.


Why is a Records Retention Schedule necessary?

A Records Retention Schedule is an essential component of an efficient and effective records management system. Properly developed and consistently implemented, a Records Retention Schedule protects the interests of the organisation and its stakeholders by ensuring that business records are kept for as long as they are needed to meet operational needs and to comply with legal requirements, and are then disposed of securely.


What does the HEI Records Retention Schedule cover?

The HEI Records Retention Schedule provides generic guidance on retention of records which higher education institutions (HEIs) commonly generate in the course of:

  • Their core academic work
  • Developing their relationships with their stakeholders
  • Managing the institutions themselves as corporate bodies

It covers key groups of records generated by the common business functions and business activities of HEIs which are defined in the HEI Business Function & Activity Model and it is structured in the same way as the Model.

The Schedule is based on extensive research and consultation with a wide range of institutions. However, it is not intended to be either prescriptive or exhaustive.


What does it contain?

Description of records
For each business activity, the Schedule lists common groups of records which relate to individual sub-activities or processes.

Retention period
Statutory retention periods are indicated by asterisks after both the retention period and the citation. These should be regarded as minimum retention periods.  For business reasons, it may be advisable to retain some records for longer than these statutory retention periods.

All other retention periods are recommended minimum periods, based on assessments of common HEI business needs and potential legal liabilities.

Citation
Citations are given for key Acts of Parliament, Statutory Instruments and regulations which are relevant to determining retention periods for the groups of records concerned. Those cited should not be regarded as the only ones that may be relevant. Institutions must obtain professional legal advice on other provisions which may apply to particular activities or within specific jurisdictions.

Note: Research on legislative provisions was limited to English law.  Institutions in Scotland must assess their potential liabilities under Scottish law.  Institutions in Scotland, Wales and Northern Ireland must assess their potential liabilities under legislation on devolved matters passed by the Scottish Parliament, the National Assembly for Wales or the Northern Ireland Assembly.

Notes

Where a group of records is likely to contain some records that should be preserved as institutional archives, ‘Review for archival value’ is recommended.  It is, of course, possible that, within individual institutions, other groups of records may contain material of archival value. Institutions should obtain advice from professional archivists on the archival value of specific groups of records in the context of their own activities.

Assessments of archival value should be carried out by professional archivists. If an institution does not employ suitably qualified staff, it may be able to obtain advice from its nearest local authority Record Office or from archivists in other institutions. If not, it should consult an independent archive professional.


How should it be used?

Institutions should use the HEI Records Retention Schedule as a starting point for developing their own Records Retention Schedules.

Assuming that an institution has already developed a Business Function & Activity Model, this will involve:

1. Identifying the records it generates in relation to each business activity.

2. For records which can be mapped onto record groups listed in this Schedule,  using the statutory or recommended minimum retention periods as a starting point for more detailed research and internal consultation leading to formal agreement of institutional retention periods.

3. For records which are not covered by this Schedule, undertaking research to determine initial retention periods as a basis for internal consultation leading to formal agreement of institutional retention periods.

Institutions should obtain professional advice on planning, developing and implementing their Records Retention Schedules. If an institution does not employ a professional records manager, it may be able to obtain advice from records managers in other HEIs. If not, it should consult an independent records management professional.

In using the HEI Records Retention Schedule, institutions should bear in mind the following key points:

  • The Schedule applies to all types of records in all media (e.g. paper and electronic documents, databases, audio-visual materials, scientific materials, artefacts).
  • Determining retention periods for records is ultimately a matter of risk management.  Institutions must make their own assessment of the risks associated with the retention and disposal of their records, bearing in mind that:
    • Where records are initially retained to meet statutory requirements, it may be advisable, for business reasons, to retain some of them for longer
    • Records which are retained may need to be disclosed in response to a request for information under the Freedom of Information Act 2000
    • Decisions to retain records containing personal information on individuals must take account of the provisions of the Data Protection Act 1998, and those which are retained may need to be disclosed in response to a request for data subject access under that Act
    • All decisions to retain or destroy records should be informed by professional legal advice within the relevant jurisdictions, and should be formally authorised by appropriate senior officers who can commit institutions to the potential consequences of those decisions.
  • The retention periods in the Schedule apply only to designated official copies of the records concerned. Duplicates can usually be retained for a shorter period.  Institutions should designate the official copies of records on a case-by-case basis and ensure that they are preserved and retained appropriately. They should also establish rules for the management of duplicates, to ensure that they are retained for only as long as they are needed to conduct business, and certainly for no longer than the official copies. It is vital to ensure that all duplicates are destroyed before (or at the same time as) the official copies, to ensure compliance with the requirements of the Data Protection Act 1998, the Freedom of Information Act 2000 and to protect the institution’s interests generally.
  • The retention periods given in the Schedule apply only to substantive records in each group. Almost all groups include working papers and other supporting materials which can usually be retained for a shorter period. To avoid over-retention, institutions should determine which are the substantive records in each group and establish specific retention periods for working papers and other supporting material.
  • Some records have no significant operational, informational or evidential value and can be destroyed as soon as they have served their primary purpose.  Institutions should develop guidance for staff on handling these records to ensure that they are disposed of promptly in the normal course of business. Some guidance is given in Appendix A.
  • A functional approach to managing records can result in some legitimate duplication. For example:
    • Staff directly involved in liaising with a students’ union on the development of its constitution usually hold a copy of the final Students’ Union Constitution document.  Using the HEI Business Function & Activity Model, this document will be classified under the Function of Students’ Union Relations Management and the Activity of Students’ Union Constitution Review & Approval and retained for the period set out in the corresponding section of the HEI Records Retention Schedule.
    • An institution’s governing body is required to formally review and approve the constitution of its students’ union.  A copy of the final Students’ Union Constitution document will be kept in the official records of the governing body. Using the HEI Business Function & Activity Model, the records of the governing body will be classified under the Function of Governance and the Activity of Governing Body Management and retained for the period set out in the corresponding section of the HEI Records Retention Schedule.
    • There will therefore be two separate official copies of the Students’ Union Constitution document, classified in different categories, retained for different periods and probably kept in different physical locations.
    • From a functional perspective, this duplication is not only legitimate but also necessary to preserve the functional context and provenance of the records. The two copies of the document result from two different business activities. Attempting to eliminate this duplication (e.g. to extend the above example, by designating the governing body copy as the ‘official copy’) would destroy this essential relationship between businesses activities and the records they generate.
    • In total, such duplication will represent a very small proportion of the records held by individual institutions.

  • Records which are to be retained as institutional archives will need special attention to ensure their physical survival.  Institutions should obtain professional advice on preservation of archives from archivists, curators and conservators.
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