Guidance

DLUHC: records and information management policy

Published 5 August 2022

1. Introduction

This document sets out the Department for Levelling Up, Housing and Communities (DLUHC, ‘the department’) policy on the storage, access, retention and disposal of information and records.

It applies to all information and records, regardless of format, held by the department, or transferred to the department, for example following the closure of Arm’s Length Bodies (ALBs), machinery of government (MOG) changes or the course of current business.

This policy defines where information should be stored, how access to it should be managed, and how long information and records should be retained before they are either destroyed or transferred to The National Archives (TNA) for permanent preservation.

It sets out the responsibilities of the Knowledge and Information Management (KIM) team and the Departmental Records Officer, and the expectations on staff in fulfilling their duty to manage records under the Civil Service Code.

1.1. Definitions

The following terms are used in this policy:

• “Records” are defined following ISO standard ISO 15489 – 1 as 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
• “Information” is defined as all records, plus ephemeral content, that is created, received, or held as part of the department’s work, regardless of whether it is designated a record
• “Physical” information and records are anything that is in a tangible physical format, including for example (but not limited to) paper, magnetic tapes, microfiche, and DVDs
• “Digital” information and records are anything that exists in a digital or electronic media, e.g., computer files, emails, database contents. It includes both ‘born digital’, which were created in digital formats, and digital versions of physical documents (e.g., scans)
• “Retention” usually means the length of time for which records are to be kept. It normally represents and will be expressed as a disposal period
• “Disposal” includes any action taken or yet to be taken to determine the fate of records including destruction and transfer to a permanent archive
• “Review” indicates that a record which has not yet been assigned a disposal action will be considered at a specific point in the future to determine its final disposal
• “Site” refers to an MS SharePoint or MS Teams site set up for the storage and sharing of digital data and collaborative working.

1.2. Related policies

Knowledge and information management policies are stored in the Information Management SharePoint site, and where appropriate published internally. These include:

• Records retention schedules: how long different types of information should be held
• Deletion and secure destruction policy: the processes for destruction and deletion of information, and when deleted information is considered to be held for statutory purposes
• Private office information management policy: specific requirements and handling of private office information
• Information security policy: information assurance roles and responsibilities, and breach processes
• Search policy: when and how searching of departmental information will take place
• IAR governance policy: structure, contents, and management of the Information Asset Register

1.3. Relevant legislation and standards

The department will comply with legal and regulatory requirements, including the following:

• Public Records Act 1958 and Public Records Act 1967
• Constitutional Reform and Governance Act 2010, including the Civil Service Code
• Freedom of Information Act 2000
• Freedom of Information Act section 46 code of practice: records management
• Data Protection Act 2018, including the UK General Data Protection Regulations
• Inquiries Act 2005

DLUHC also follows the records management guidance outlined in ISO 15489 Part 1^{[footnote 1]} and ISO 15489 Part 2^{[footnote 2]}, and the guidance and standards published by The National Archives.

2. Roles and responsibilities

All permanent and temporary employees, contractors, consultants and secondees who have access to DLUHC’s records, working on behalf of DLUHC on departmental business are responsible for managing DLUHC records, wherever these records are and whatever form they are in.

DLUHC owns all records created by employees carrying out DLUHC business related activities. Unless the originator asserts ownership, records received by DLUHC staff are also owned by DLUHC. Individual employees do not own records; however, they are responsible for managing them.

2.1. Executive Board

Members of DLUHC’s Board Executive have overall responsibility for our records and information management policy and standards, and for supporting their application throughout the organisation.

Significant changes to records and information management policy and standards, requiring corporate sign-off, will be presented to the Audit and Risk Committee, chaired by the departmental Senior Information Risk Owner (SIRO), for approval.

2.2. Departmental Records Officer

The Departmental Records Officer (DRO) is responsible on behalf of the Permanent Secretary for:

• developing and managing an organisation-wide records and information management programme that meets the requirements of the Public Records Acts and cross-government best practice
• providing advice on information management issues and promoting best records and information management practice
• ensuring the records and information management policy complies with the government’s Security Policy Framework
• regulating who has access to DLUHC’s records

2.3. Knowledge and Information Management

The Knowledge and Information Management team, part of Digital Directorate, are responsible for:

• making sure departmental records and information are stored securely
• making sure information is managed appropriately throughout its lifecycle
• making sure records and information management policies are kept up to date and relevant to the needs and obligations of the Department, consulting and working with DLUHC staff and the appropriate external regulatory and customer bodies
• informing staff about records and information management policy, and ensuring that all staff are aware of their responsibilities for managing records and information
• providing information management advice and guidance to all staff as required taking over management of DLUHC records and information for which there is no clear responsible business area
• advising DLUHC’s Arm’s Length Bodies and Agencies where appropriate on their records and information management
• deleting information which is no longer required to be kept for the record, for business purposes, or under any relevant legislation
• providing advice and guidance on knowledge management best practice

2.4. Line managers

Managers at all levels are responsible for:

• working with Knowledge and Information Management to develop suitable information management procedures, covering both digital and hard copy records, that:
  • are efficient and fit for purpose
  • comply with our information management policy and standards
• operating information management procedures
• ensuring that appropriate resources exist within their business unit to fulfil the responsibilities for managing records
• communicating local information management procedures
• ensuring that local records and information management processes and procedures are in line with central policies
• ensuring that staff follow procedures for the offsite storage of hard copy records
• ensuring that staff follow procedures for the management and storage of digital records, including when they leave the department
• creation and maintenance of retention schedules

2.5. Project managers

Project records are the responsibility of the project manager, who is responsible for:

• identifying project related records and liaising with relevant local contacts
• ensuring that the records are managed efficiently and comply with our records and information management policy and standards
• ensuring that there are appropriate resources within the project for fulfilling the responsibilities for managing records
• quality assurance of records and information management processes and procedures within the project
• ensuring the appropriate disposition of project records

2.6. Site owners

Site owners are administrators of specific Teams and SharePoint sites. They are responsible for:

• managing members of team sites, adding, and removing members when needed and ensuring there are always at least two individual owners of a site
• approving requests from non-members of a site to access information, considering the need and appropriateness of the sharing
• arranging for sites to be archived in line with Knowledge and Information Management processes

2.7. Individuals

In accordance with the Civil Service code, all staff are required to ‘keep accurate official records’. Therefore, staff that receive, create, maintain, or delete records are responsible for making sure that they do so in accordance with DLUHC’s records and information management procedures.

2.8. Working with external partners

When working with external partners, consideration must be given to who is keeping the official record. In general, the department should keep a copy of all records if working with:

• non-government bodies
• local authorities
• organisations not subject to the Public Records Act

When working with another government department or public records body, agreement must be reached about which department will keep the official record of the work. For other government departments, this will often be the department with the responsible minister. Copies of records held be another department may be kept internally, but they must be clearly marked as copies. Copies held within DLUHC will be subject to all information legislation, as appropriate.

3. Storage

3.1. Approved corporate storage

DLUHC operates a digital storage policy. Information is digital by default, with physical records only being created when there is a specific, legitimate need. All departmental records must be stored on departmental devices in approved corporate storage locations. This means:

• DLUHC SharePoint/Teams sites
• Centrally owned archive storage
• Registered paper files, where there is a legitimate business need for physical registration; these are covered by section 6

Information that does not form part of the record, has no legislative requirement to be kept, and is not of ongoing business value, should be deleted as soon as it is no longer required.

3.2. SharePoint and Teams sites

Private channels may not be created in Teams sites, as this creates a separate, hidden SharePoint library that administrator accounts are not members of.

3.3. Account-specific storage (OneDrives and mailboxes)

Departmental information should not be stored in account-specific storage, i.e., individual Outlook accounts and OneDrives.

All data in account specific storage remains searchable by and accessible to the Departmental Records Officer. The process for searches is set out in the department’s search policy.

3.4. OneDrives

OneDrives are account-specific storage provided as part of Microsoft 365. Although each OneDrive is linked to a named user, they remain held by the department, and the contents are subject to the same statutory requirements as other parts of the department’s information, including Freedom of Information and data protection legislation.

All information stored in One Drives is potentially accessible to the Departmental Records Officer, Data Protection Officer and Departmental Security Officer, where there is a legitimate need to access it. The process for searching these is set out in the department’s search policy.

OneDrives should be used for storing business-related personal documents, e.g., HR and performance related documents. Documents of business value (including drafts) must be saved to a corporate storage location, to ensure that business continuity can be maintained.

One Drives should not be used for storing data which may need to be accessed by an individual’s team, including draft documents. These should be saved to the appropriate site so that others in the team can access them and continue work if necessary, and the One Drive copy deleted to prevent duplication of information.

Line managers must comply with the department’s privacy notice for staff. It is the account owner’s responsibility to manage their own personal data, including deleting copies from their One Drive prior to leaving the department.

3.5. Microsoft apps

If OneNote, Planner, or any other Microsoft apps are used to record notes or information required for business purposes or that needs to form part of the corporate record, these must be transferred to SharePoint for storage.

3.6. Device storage

Devices issued to users (laptops, tablets, and phones) come with a small amount of local storage. This should only be used for temporary storage of information when no other storage location is available. Where it is necessary to save to the device, for example in the case of some downloaded data, it must be transferred to corporate storage as soon as possible and the copy on the device deleted.

Any apps installed on the device which store information outside of the main network (e.g., Messages, WhatsApp) should not be used for storage of departmental information. Device storage is unmanaged, is not backed up, and is inaccessible for business continuity purposes, but remains potentially disclosable under Freedom of Information and Data Protection legislation. Individuals may be required to search data stored on their devices, as set out in the search policy.

Personal devices should not be used to store departmental information. However, as with devices issued by the department, any work information that is stored in these locations remains potentially disclosable under Freedom of Information and Data Protection legislation, regardless of the ownership of the device.

3.7. Individual mailboxes in Outlook

Individual mailboxes on Outlook are not currently recognised as part of the official departmental record keeping system. It is the responsibility of staff to ensure that any emails relating to business activity are saved in approved corporate storage locations, and then deleted from the mailbox.

It is the responsibility of the individual holding the account, or in their absence their line manager, to ensure that all business-related emails within the mailbox are transferred to an appropriate site before the individual leaves the department.

Auto-forward should not be used to automatically send emails from a departmental account to an external account. Where there is a business need for auto-forward to an external account, approval should be sought from the Departmental Records Officer and Cyber Security lead, and a date agreed for a review of the auto-forward.

Outlook should be used for short-term storage of communications and ephemeral information. Records of business decisions stored in emails should be transferred to a corporate storage location.

3.8. Shared mailboxes in Outlook

Shared mailboxes, including group mailboxes linked to Teams sites, may be used for the storage of business information; however, if this is the case, the owning team should appoint an information manager responsible for ensuring that the information stored in the account is appropriately managed in order to be retrievable if needed, and that retention and disposal is suitably applied. The KIM Team should be contacted for advice on the management or disposal of this information.

3.9. Personal digital files

Purely personal files should not be stored anywhere on DLUHC IT. This includes (but is not limited to) personal photos and other media files, personal documents unrelated to work and documents relating to any external business commitments individuals may have.

Any documents stored temporarily on DLUHC IT must be reviewed regularly by the owner and deleted. Work-related personal documents (e.g., PMRs) should be saved to account-specific storage (OneDrives).

Any purely personal files identified on the network may be deleted on sight. Whilst stored on the network they may be identified as part of routine searches for Freedom of Information requests, inquiries, and other search activity.

3.10. Instant messaging

Instant messages fall into two types, both of which are covered by the Freedom of Information Act and may be considered for disclosure:

• Chat messages are private messages between two or more individuals. They are retained for 30 days. Any chat messages that need to be retained as part of the official record must be copied into another format or taken as a screenshot and saved (e.g., as a Word file saved to the site).
• Posts are messages that can be seen within a Teams site by any members of that site. Posts are currently kept for the same length of time as the rest of the site. Posts will be treated as part of the entire team record.

3.11. Use of informal communication styles

Departmental records must not include use of informal communication styles such as emojis or GIFs. Any use of these to indicate a decision must be accompanied by appropriate words setting out the meaning.

3.12. Social media and external platforms – approved platforms

An approved platform is a social media or other web-based platform that has been either been designed for the department or has been through the IT and cyber approvals process, with reference to the KIM and data protection teams as appropriate. It includes both systems with a software download component and services entirely on the web through corporate account usage.

The KIM team should be notified of any platforms being used in this way. A system owner should be appointed, who will have responsibility for ensuring the information is appropriately managed, access controls are in place, and for ensuring searches are conducted as necessary for Freedom of Information and other requests. The system or parts of its contents may need to be recorded on the information asset register.

WhatsApp is currently approved for use on Departmental phones. Users must be mindful of their responsibilities to keep accurate records and ensure any decisions or important business conversations made over WhatsApp are subsequently recorded in a format that can be saved to departmental systems. Personal phones and WhatsApp should not be used for making business decisions.

3.13. Social media and external platforms – unapproved platforms

The department does not recognise social media (e.g. Twitter) or external web-based platforms (e.g. Trello, Google Docs, DropBox, Slack) as record-keeping systems. Personal accounts with social media and web-based platforms must never be used for departmental business.

As far as possible, the features of Microsoft 365 should be used to replace these services, particularly for internal business activities. Work conducted on external applications is covered by the Freedom of Information and Data Protection Acts and may be subject to disclosure.

Where there is a business need to conduct business on an external platform, the staff using it are responsible for ensuring that personal and sensitive data are adequately protected and handled in line with any relevant legislation.

Staff must ensure that a copy or screenshot of any information that needs to be kept as a record is saved to DLUHC IT, either ongoing or at the end of a project. Staff are also responsible for ensuring that information is deleted regularly from these platforms where possible. Where automated retention is in place, particularly where the retention period if not based solely on date (e.g., items are deleted once the maximum data allowance is reached) staff are required to regularly extract anything that needs to be kept as a record to ensure it is not deleted.

3.14. Digital SECRET and TOP SECRET information

Digital SECRET and TOP SECRET information must not be stored on DLUHC IT. Information at these classifications must only be stored digitally on approved systems. Staff with a requirement to handle digital information at these security classifications should contact Knowledge and Information Management.

4. Retention and disposal

4.1. Retention of material relevant to inquiries, criminal investigations, and information rights requests

In certain circumstances, the department is required to retain information. In the cases listed below, the requirement to keep information will override all retention policies set out in departmental policies.

• a current or future inquiry
• criminal investigation
• a Freedom of Information, Environmental Information, or subject access request

Where any of these applies, a non-deletion policy will be in force for any affected information. Depending on the scale and nature of the information affected, this may be managed through a non-deletion policy, through settings applied to Microsoft 365 to prevent the final deletion of information, or a combination of the two.

Moratoria or retention controls currently apply for the Grenfell, IICSA and Covid Inquiries. Where appropriate, these override all retention policies set out in this document.

4.2. Departmental retention and disposal schedule

The department does not keep most information indefinitely. Records will be kept for as long as there is a business or legislative need to do so. This will vary according to the type of information up to a maximum of 20 years for most records. In a limited number of circumstances, records may need to be held for longer, including the lifetime of an asset. Legal authority is required for the department to hold records for longer than 20 years. In these cases, the department will apply for a retention instrument from the appropriate authority, providing justification of the need to retain the information.

The table in the Departmental record retention schedule shows the general retention periods used by the department based on detailed TNA guidance on the subject.

Each business area is responsible for agreeing, in consultation with Knowledge and Information Management, the retention period of all its records.

In circumstances where either individual business areas are unsure of the retention period of a record, or where there is no clear owner to advise, the default will be taken to be 8 years.

Additional policy on the retention of particular subsets of digital records or information is set out below.

4.3. Records received following ALB closures

Where records in any format are received from Arm’s Length Body (ALB) closures their retention period will, where possible, be agreed with the ALB. Where it is not possible to do this, a default retention of 8 years starting from the date they are formally transferred to the department will be applied. In exceptional cases where the records need to be kept longer, a maximum 20-year retention period will be used.

HR and pension records will have standard DLUHC retention periods applied.

All remaining ALB records will remain the responsibility of the DLUHC sponsoring business area, except where a separate agreement is made with the Departmental Records Officer by the ALB’s equivalent officer or the sponsoring business area. If legacy responsibility for an ALB transfers to a new business area, the new business area must inform Knowledge and Information Management of the change.

The business area that has responsibility for the files will also have responsibility to action any requests to access the information.

4.4. Records received or transferred following MOG changes

Where records, either in paper or digital format, are formally transferred to the department following any machinery of government (MOG) changes, a transfer agreement should be drawn up with the relevant business area, setting out ownership, retention periods and related considerations (e.g., data protection). This should be agreed and signed by the transferring and the receiving parties and the Departmental Records Officer.

Where digital records are transferred to another government department, the data will be deleted once the transfer has been confirmed as completed. Backup data may be retained for its full lifecycle.

4.5. Records of significant interest

All records created or identified (digital and/or physical) that relate to any significant sensitive matter or to ongoing investigations must be notified as soon as possible to the Departmental Records Officer. The Departmental Records Officer will then assess the most appropriate retention that should apply to these records.

The decision regarding what is of significant interest rests with the Departmental Records Officer. Subjects are set out at a broad level and include all variations on spelling and specific references within the general area.

Subjects currently flagged as significant are:

• material related to current inquiries
• evidence of criminality
• child abuse, child pornography, paedophilia (following a recommendation from the Wanless-Whittam independent review that all records relating to child abuse are marked as significant and the Home Office informed)

4.6. Record destruction

The processes for the destruction of paper and digital records are set out in the Deletion and secure destruction policy.

4.7. Deletion of digital records

Where held digitally, records are to be deleted by the KIM team in accordance with disposal agreements agreed with business areas. Where no agreement exists, digital records will be considered for deletion once they reach 7 years of age.

The KIM team will regularly identify any digital ‘review’ records that have reached the end of their retention period. These records will be first reviewed by the KIM team to see if they are of historical value. Any that are selected for retention will be transferred to TNA or other place of deposit; all that are not will be permanently deleted.

4.8. Retention and deletion of legacy data held outside Microsoft 365

Legacy information stored in systems or other platforms than the main departmental network will be assessed to evaluate which information needs to be retained and will have their lifecycle managed by the KIM team according to this policy and the technical constraints of the systems they are stored on.

4.9. Enterprise Vault data

The department previously used an email archive, Enterprise Vault, to store older emails. Email ‘stubs’ containing links to items in the archive were retained in the original mailbox. As part of the 2019 IT migration project, emails were restored to accounts at the point where the Enterprise Vault ‘stub’ resided.

Some ‘stubs’ were no longer in the original email account. Some have been transferred to shared drives or Team sites as part of the department’s corporate memory, however many were deleted by users as part of day-to-day mailbox management, with the assumption that this action would also delete the corresponding email from the Enterprise Vault, which was not the case.

All emails without corresponding ‘stubs’ in the original mailbox have been restored to a residual storage facility which can be accessed by the Knowledge and Information Management team. Due to the unstructured nature of this residual storage, there is no easy or cost-effective way to distinguish between those emails that should be retained and those intended for deletion. A project will be implemented to review this information; once this process is complete, the remaining information will be deleted in line with the department’s destruction policy.

4.10. Ministerial and Permanent Secretary mailboxes

Private office records, including special advisor records, must be managed in line with the Private Office Information Management policy.

4.11. PST files

Personal Storage table (pst) files (archived emails – a feature in MS Outlook) are not an approved form of information management and must not be created or used. They are not supported by the department, and any pst files discovered on DLUHC IT may be subject to deletion.

5. Access and sharing

5.1. Internal sharing and access controls in SharePoint/Teams sites

Sites set up in SharePoint and MS Teams enable staff to share information and conversations within a set group of people. Each Teams group includes a shared email address and mailbox which can be accessed by all members of the team.

Staff should save all their work, including drafts, to shared areas, where colleagues can access it if there is a need to do so.

Access restrictions should be managed using the permissions features built into Microsoft 365. Where there is a need to restrict access to a set of data to a limited group of people, a new site may be set up, giving only those individuals access. This simplifies the management of individual permissions within sites.

Passwords must not be used to protect documents, as these are unique to the creator and do not allow for business continuity or for the department to meet statutory requirements such as FOI and the Public Records Act.

Staff can share sites, folders, and individual documents with other members of the department. It is the responsibility of the site owner to manage and, where appropriate, remove access permissions.

Staff are responsible for regularly reviewing which documents have been shared and removing permissions where there is no longer a requirement for their access to continue. This includes, but is not limited to, when a project closes or when staff move post.

5.2. Internal sharing and access controls in OneDrives and Outlook

Access to OneDrives and Outlook must normally be approved by the individual owning the account, or if they have left, by the KIM team, who will seek approval from the Departmental Records Officer or Data Protection Officer as necessary.

Where the individual is unable to give permission, for example due to absence or if they have left the department, access will need to be approved by the KIM team via the KIM Approvals mailbox. Requests by staff under Grade 7 may additionally require line management approval.

Where possible, direct access by staff to OneDrives will be minimised. Requests for documents stored in OneDrives will normally be processed by the KIM team rather than individuals being granted access to the relevant account. Individual files may be transferred via email; otherwise, a suitable SharePoint/Teams location will need to be provided for the files to be copied to.

Where access is approved to a OneDrive or calendar, this will be for a time-limited period; typically, this will be 24 hours, unless there is a business need for access to be permitted for longer.

5.3. External sharing via SharePoint/Teams

Information should only be shared externally where there is a clear business need to do so, and where the contents and security classification of the information make it appropriate to be shared. Consideration should always be given to privacy and security, and sharing must consider the implications of the information being made available outside of the department.

Where information needs to be shared outside the department, it should be placed on a dedicated private site, accessible only to named users, and the external parties should be given access to that site as guest users. Additional precautions may need to be taken for external users with web-based email accounts, including the use of two factor authentication if appropriate, in line with current guidance available on the intranet and on the Discover Information site. The owner of the site is responsible for ensuring that all members of the site are aware of who can access the content and making sure that they do not add content that is not appropriate for external sharing. External parties must never be invited to view sites that are accessible to the entire department.

Granting external access to private sites ensures that the data remains within the managed environment of the department, and that access is only available to those with guest accounts.

External parties must not be given access to information stored in One Drives.

The option to share files so that they allow access to anyone with a link has been disabled. This option enables access by unknown users, without a guest account, and exposes the department to the risk of information being shared inadvertently, e.g., through forwarded emails. Links can be shared with users with guest access to a site.

Staff are responsible for regularly reviewing which documents have been shared and removing permissions where there is no longer a requirement for their access to continue. This includes, but is not limited to, when a project closes, when external users no longer require access to information, or when staff move post. IT may conduct reviews of external guests and contact site owners for confirmation that the access is still required. Owners must act on these reviews as requested, otherwise guest access to sites may be revoked.

Information should only be shared externally where it is appropriate to do so, and through permitted means. Photos of departmental information must not be shared externally except with the approval of the Departmental Records Officer or Cyber Security Lead.

5.4. External sharing via email

Email should not be used for sharing significant amounts of data outside of the department, where it is possible to use a site. Where smaller quantities of information are being shared, or where it is not possible to use a SharePoint/Teams site, it should be considered whether the ‘Encrypt’ and ‘Do not forward’ settings are appropriate to use to protect the contents.

Outlook calendars may be opened externally to allow people outside the department to see when an individual is free or busy, but not the contents of that appointment. This feature must be used appropriately, and permissions must be removed when the access is no longer needed by the external person.

5.5. Joiners, movers, and leavers

When a member of staff joins a team or leaves it either to move within the department or to leave the department, it is the site owner’s responsibility to ensure that all permissions are updated. When a member of staff leaves temporarily and does not require access in the interim, their permissions will be revoked and reinstated on their return. 

When a member of staff leaves the department, their Microsoft 365 licence will be revoked immediately, and they will no longer have access to their OneDrive, Outlook or to any other information based within Microsoft 365. The account will then be closed, and retention policies will be applied. Access to the account whilst it is still held will be handled in line with section 5.2.

If the member of staff has any corporate information saved on their One Drive or in their email account, they must transfer this to corporate storage before they leave. If they wish to retain any personal information held in the account, it is their responsibility to ensure it is extracted prior to departure. The retention of any data left in the account is not guaranteed, and any requests for personal data to be extracted from the account of a former member of staff will need to be submitted to the department as a Subject Access Request (SAR).

5.6. Sharing agreements

When information is being shared on a regular basis, a sharing agreement is required that sets out key information about the sharing. This is particularly important for external sharing but may also be required for internal sharing of sensitive data.

If the data being shared is personal data, the agreement should be made on the data sharing template available from the data protection guidance.

If the data does not include personal data, a sharing agreement is still required.

6. Physical information and records

6.1. Physical storage

All registered paper files should be stored by Knowledge and Information Management, either on a DLUHC site or with Knowledge and Information Management’s off-site storage contractor. Appropriate measures will be taken to protect files according to their sensitivity. Only registered paper files or registered boxes containing paper material will be accepted for storage without separate agreement from the Departmental Records Officer or Deputy Departmental Records Officer. If business areas have requirements for storing information on other physical media (e.g., magnetic tapes), they should first speak to the KIM team.

Registered files held temporarily by staff must be stored in a suitably secure location, according to the security classification of the information and be returned to Knowledge and Information Management when not required for immediate business use.

6.2. Paper files

The KIM team are responsible for maintaining the departmental records catalogue of registered paper files.  All paper records are either identified for destruction or for review for potential historical value according to their retention period, as set out in the Departmental record retention schedule.
Paper records that become due for destruction (which depends on their retention category) are destroyed either:

• by the department’s offsite file storage provider on receipt of a destruction request from the KIM team, or
• by the KIM team on site

Paper records identified as being of potential historical value are reviewed by the KIM team in order to decide if they are of historical value. If they are of historical value, they are transferred to The National Archives, or another place of deposit; if not, they are destroyed.

Records are generally not kept for longer than 20 years.  If there is a requirement to do so, then an application for a Retention Instrument is made by the KIM team.
Personnel records are kept until a member of staff reaches 100 years of age in accordance with TNA guidance on the retention of employee records. The KIM team check biannually which personnel records can be destroyed based on staff age. Different retention periods may apply to temporary staff.

6.3. Hard copy papers

The department’s policy is to retain digital, rather than paper copies of documents. Unless there is a legal requirement to keep paper copies, therefore, paper documents should be scanned and saved to SharePoint as a digital file. Scans should be saved with a meaningful name, and where possible, should include OCR of any text.

There is no requirement to keep printouts of papers printed for departmental business where these are identical to the digital copies. However, if any additional manuscript notes or markings have been added to the paper that are required for the corporate record or for business purposes, these should be scanned and saved to SharePoint alongside the original document. Scans should be saved with a meaningful name, and where possible, should include OCR of any text.

6.4. Notebooks

Notebooks kept in the course of business should normally be handled as personal papers if they are solely used for personal notes and do not contain business information not recorded elsewhere, with the following exceptions:

• the contents of the notebook relate to a current or expected inquiry, criminal investigation, or information access request

Ministerial notebooks should be managed as set out in the Private Office Information Management policy.

6.5. Personal papers

Individuals are responsible for managing their own personal work papers and ensuring that they are held in storage with appropriate security and destroyed when no longer needed. Any personal storage allocated, for example departmental lockers, should not be used for the storage of registered files.

Ministerial papers should be managed as set out in the Private Office Information Management policy.

6.6. Non-paper items and digital continuity

Physical items other than paper should not be put into off-site storage without first consulting with the Deputy Departmental Records Officer. Knowledge and Information Management have a contract which allows us to store certain materials (e.g., tapes) in appropriate climate-controlled storage and will be able to advise on the best way to store these materials.

Physical media for storing digital data (e.g. CDs, DVDs) changes over time, and can become obsolete and inaccessible. These media will not be accepted as part of a registered file, as Knowledge and Information Management are unable to guarantee continued access to the data. Where it is necessary to include physical media with a deposited document (see section 6.7), the business unit will be required to sign to accept responsibility for ensuring that the media can continue to be read as storage formats change and become outdated.

Retention periods for non-paper physical items will be agreed with business units in the same way as paper files.

6.7. Deposited documents

Deposited documents are legal documents. Examples of deposited documents are:

• Compulsory Purchase Orders
• Deeds
• Leases
• Transfer Schemes
• Statutory Appointments and Instruments (except those subject to Parliamentary process and temporary)
• By-laws
• Sealed Planning Orders
• Official Seals of any of our Arm’s Length Bodies that have been closed

Owing to the content of deposited documents, the department keeps them in perpetuity, and they must be sent to Knowledge and Information Management for storage.

Physical documents are stored in offsite storage and digital documents in the Departmental Records Catalogue. It is appropriate if needed for owners to place copies onto registered files or to be saved to Team Sites for continued business use.

6.8. Personnel and pension files

Permanent personnel and pension files are held until staff reach 100 years of age. This is reviewed annually in line with ONS statistics on average life expectancy.

Temporary personnel and pension files are retained for 7 years. These are checked annually to confirm whether they need to be converted to permanent files.

6.9. Physical SECRET and TOP SECRET information

SECRET and TOP SECRET files must be kept in appropriate secure cabinets and never in personal lockers or ordinary cabinets. The Departmental Security Officer should be aware of all SECRET and TOP SECRET files and the approved storage for them around the building. Checks will be regularly undertaken to ensure that these files are being stored appropriately.

Destruction of SECRET and TOP SECRET material will be in accordance with the Deletion and secure destruction policy.

Transportation will comply with Centre for the Protection of National Infrastructure guidance on the secure transportation of sensitive items.

7. System audit

The Departmental Records Officer is accountable for the management of information in the department. They may, therefore, require audit reports to be run and retained showing activity on the network.

7.1. Creation of SharePoint/Teams sites

A log is kept of all sites created on DLUHC.

1. International Standard ISO 15489 – 1. 2001. Information and documentation – Records Management – Part 1. International Organisation for Standardisation. First edition 2001. Ref ISO15489-1:2001(E). ↩

2. International Standard ISO 15489 Information and documentation – Records Management – Part 2: Guidelines International Organisation for Standardisation. First edition 2001. Ref ISO15489-2:2001(E). ↩