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Public Record Office of Northern Ireland

© Crown copyright 2003

‘The influx of paper will not end any time soon.’1

______1 ‘Ready Access to Essential Evidence: The Strategic Plan of the National Archives and Records Administration 1997-2007’, Washington D.C., revised 2000, page 1.

Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

C O N T E N T S

Page

Foreword 3

Abbrieviations 6

1. Records Management Structure 7

1.1 Introduction 7

1.2 Information/Records Managers 7

1.3 Local Information Managers 8

2. Information Audits 10

2.1 Why carry out an information audit or records survey? 10

2.2 What is an information audit/records survey? 10

2.3 How should the information audit be carried out? 10

2.4 What information should be sought? 11

Information Audit Questionnaire: Sample Questionnaire and 13 Responses (1)

Staff/Equipment Questionnaire: Sample Questionnaire and 18 Responses (2)

2.5 Evaluating feedback from the information audit 19 questionnaire

2.6 The Information Audit Report 21

3. Disposal Schedules 23

3.1 Regular and Special Disposal Schedules 23

3.2 What does ‘disposal’ mean? 23

1 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

Page

3.3 Why have a disposal schedule(s)? 23

3.4 How many disposal schedules are required? 23

3.5 What is the role of the Information/Records Manager 24 in relation to disposal schedules?

3.6 What steps should the Information/Records Manager 24 take to ensure the smooth running of the disposal scheduling process?

3.7 Apart from LIMs, whom else should the 24 Information/Records Manager consult during the disposal scheduling process?

3.8 What is the role of PRONI in relation to disposal schedules? 25

3.9 What format should a disposal schedule follow? 26

Disposal Categories 29 Schedule of Records Layout: Sample 1 31 Schedule of Records Layout: Sample 2 32

3.10 What happens after the disposal schedule is signed? 34

3.11 How long do you keep files/records about information audits 35 and disposal schedules?

3.12 How should the physical destruction of files/records be 36 carried out?

4. The Backlog: Special Disposal Scheduling 38

5. Bibliography 40

6. Note on Author 42

2 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

FOREWORD

Because of the demands of recent legislation, in particular the Data Protection Act 1998, the Freedom of Information (FOI) Act 2000, and Environmental Information Regulations (dating from 1992), and also because of legislation that has been on the statute book for many decades, such as the Public Records Act (N.I.), 1923, the records management function in public authorities needs a substantial investment of time, energy and resources to recover its position as a key business activity.

Both Government Ministers and Senior Civil Servants have acknowledged that records management has been given a very low priority over the last number of years if, indeed, it has been given any priority at all. One Minister asserted recently (2002) that:

In looking at what we have to do to meet our obligations under the [FOI] Act, our ability to access the information held within our Departments has become a recurring theme. Records Management, it would now appear, has been for too long neglected. Certainly this is true I believe within the Civil Service.

And, he added that:

The proper move to more electronic records has added a new dimension to this problem.2

A culture change is expected in the area of records management, and there will be no hiding place for organisations failing to tackle the challenges ahead. While recognising that records management activities have been starved of resources, the Information Commissioner (established by the FOI Act) will expect improvements. The Financial Times legal correspondent reported (22 May 2002) that the Information Commissioner had warned:

Many government departments will struggle to cope under new public rights of access to information, unless they modernise their neglected record-keeping systems.

It was further reported that ‘Departments will ‘‘pay the price’’ for neglecting the ‘‘Cinderella’’ area of records in cost-cutting during the late 1980s and early 1990s’, and that, ‘If they don’t put some resources into sorting it out [and establish] some clear rules for the game, then there will be embarrassment’.

Recognising the need to raise the profile of records management, the Public Record Office of Northern Ireland (PRONI) published advice on its website in May 2002: http://www.proni.gov.uk/NIRMS/NIRMS1/pdf. The Northern Ireland Records Management Standard (NIRMS) was devised in consultation with all the Northern Ireland Departments, and contains practical advice on the several important areas of records management: filing systems, filing practices, disposal scheduling, reviewing procedures, special category records, legislation (ie, the full text of the Public Records Act (NI) 1923 and the Disposal of Documents Order 1925) and electronic records management.

______2 Mr Denis Haughey, a junior Minister in the Office of the First Minister and Deputy First Minister (OFMDFM), made the comments at a Chief Executives’ Forum event held in Belfast Castle in January 2002.

3 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

However, with the publication of the Code of Practice on the Management of Records under Section 46 of the FOI Act (in November 2002), it soon became clear that further, and more detailed, advice was going to be required by public authorities. The Code supports the provisions of the FOI Act and provides guidance to all public authorities on how to comply with their legislative obligations. It focuses on the need to have in place a sound records management system, and to carry out specific records management practices.

The Code points out that:

Any freedom of information legislation is only as good as the quality of the records to which it provides access.

And that:

Such rights are of little use if reliable records are not created in the first place, if they cannot be found when needed or if the arrangements for their eventual archiving or destruction are inadequate.

Without doubt, good records management is the ‘key to success’.

As regards ‘Record Keeping’, the Code of Practice comments that ‘Installing and maintaining an effective records management programme depends on knowledge of what records are held, in what form they are made accessible, and their relationship to organisational functions’. The Code then states that:

An information survey or record audit will meet this requirement …’ 3

Furthermore, the Code of Practice spells out clearly what is required in terms of ‘Disposal Arrangements’:

‘It is particularly important under FOI that the disposal of records – which is here defined as the point in their lifecycle when they are either transferred to an archives [ie, PRONI] or destroyed – is undertaken in accordance with clearly established policies which have been formally adopted by authorities [ie, a disposal schedule(s) agreed between PRONI and the respective public authority and carrying appropriate signatures] and which are enforced by properly authorised staff’. 4

Therefore, in response to the needs of public authorities, PRONI has produced this guidance document on information audits and disposal schedules – it builds on the advice offered by the Northern Ireland Records Management Standard. The guidance will act as a reference tool, and will complement the necessary case work that is being undertaken with the 11 Northern Ireland Departments, 26 District Councils, well over 100 Non-Departmental Public Bodies and the Northern Ireland Court Service. As Government is still primarily a paper- based operation, the scope of the guidance covers the surveying and disposal scheduling of

______3 Lord Chancellor’s Code of Practice on the Management of Records under Section 46 of the FOI Act, para. 8.4. 4 Code of Practice, para. 9.1.

4 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

paper-based information/records and not electronic information/records. However, it is important to note that the medium on which information is held is less important than the information itself, and that good records management principles apply to both paper and electronic documents.

PRONI will continue to seek new ways of providing a records management service to public authorities, especially through training. And, as a lead implementer in the Northern Ireland Civil Service’s Electronic Document and Records Management Systems Infrastructure Project, PRONI will be able to pass on practical advice and guidance on the management of electronic records in the near future.

GERRY SLATER Chief Executive/Deputy Keeper of the Records

May 2003

5 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

ABBRIEVIATIONS

DCAL Department of Culture, Arts and Leisure

DIM Departmental Information Manager

DP Data Protection

DRO Departmental Record Officer

FOI Freedom of Information

EIR Environmental Information Regulations

EDRM Electronic Document and Records Management

LIM Local Information Manager

NA National Archives, London (formerly Public Record Office)

NDBP Non-Departmental Public Body

NIO Northern Ireland Office

OFMDFM Office of the First Minister and Deputy First Minister

PRONI Public Record Office of Northern Ireland

6 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

1. Records Management Structure

1.1. Introduction

Public authorities are expected to use existing resources to remedy any records management deficiencies, and it is clear that they need someone to ‘champion’ the cause of records management. The Disposal of Documents Order (NI) 1925 laid down that an officer ‘specially conversant’ with the records should be appointed to lead and advise on records management matters. In recent decades the practice has been to appoint an officer from the ranks of middle management (eg, typically a Staff Officer or Deputy Principal in the Northern Ireland Departments), who was already responsible for functions such as premises or personnel management or office accommodation. These officers were called ‘Departmental Record Officers’ (DROs) in the Northern Ireland Departments and the Northern Ireland Court Service, and ‘Record Liaison Officers’ (RLOs) in Non-Departmental Public Bodies. In some cases, the role was never recognised or filled at all! Basically, records management was seen as a nuisance, and responsibilities in this area were simply tacked on to the officer’s main duties and accounted for only a very small percentage (c.2-5%) of his/her overall time.

1.2. Information Managers

In response to the demands of Data Protection, Environmental Information Regulations and Freedom of Information legislation, public authorities have been appointing Information/Records Managers. Departmental Information Managers (DIMs) have been appointed in nearly all of the Northern Ireland Departments (some Departments have elected to stick with the traditional Departmental Record Officer (DRO) title). Non-Departmental Public Bodies and Local Authorities have begun to appoint Information or Record Managers, but many positions still remain unfilled.

The title of these officers is less important (indeed ‘DIM’ is a particularly unfortunate acronym!) than the time they are given to carry out essential records management tasks: information audits or records surveys, development of file plans or filing systems, and drafting disposal schedules. PRONI recommends that Information Managers are: ♦ Formally appointed (using a pro forma supplied by PRONI) by the most senior public servant in the particular public authority, eg, the Permanent Secretary would make the appointment in a Northern Ireland Department and the Chief Executive would sign in the case of most of the NDPBs5 ♦ Full-time officers, ie, full-time on records management activities/functions ♦ Dedicated – in every sense of the word – to records management matters, and to servicing the needs of Data Protection, Environmental Information Regulations, Freedom of Information and, indeed, any business concerning access to information, including the Annual Sensitivity Review exercise6

______5 In fact, this is a legal requirement - as opposed to a recommendation - under the Public Records Act (NI) 1923. 6 This exercise involves PRONI issuing records that are eligible for release under the ‘30-year rule’ to the functionally-responsible public authorities, who will decide whether the records should be made available or closed for an extended period of time using the existing Open Government criteria. FOI criteria will apply after January 2005, when the Act is fully implemented.

7 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

♦ Professionally trained (this is PRONI’s preference, but it is accepted that training at a level just short of that required for a professional qualification would be sufficient) ♦ Possessed of sufficient rank or clout within the public authority (eg, at least Deputy Principal rank in the Northern Ireland Departments)7

The range of duties that the Information Manager would be expected to carry out include:

♦ Drafting a corporate records management policy and procedures document (a document which must be made available to all staff once the final draft is agreed) ♦ Seeking appropriate funding (eg, devising a Business Case for appropriate funding/staffing) ♦ Organising appropriate staff training ♦ Carrying out an information audit or records survey ♦ Devising a file plan or filing system ♦ Drafting a disposal schedule ♦ Refining the FOI Publication Scheme ♦ Acting as editorial controller of the public authority’s Internet/Intranet website(s) ♦ Liaising with associated organisations, eg, a Department should liaise with executive agencies and Non-Departmental Public Bodies under its parental wing ♦ Liaising with the Northern Ireland Information Manager (based in OFMDFM)8 ♦ Liaising with the Public Record Office of Northern Ireland ♦ Attending meetings of the Information Managers’ Forum convened quarterly by PRONI.

1.3. Local Information Managers

It is vital that the Information Manager – the records management ‘champion’ – has ‘supporters’. Traditionally, records management support staff have been registry staff but, as has been said (see Foreword), public authorities have been

______7 In Northern Ireland there is a myriad of public authorities, some with around a dozen staff and others with thousands. Therefore, public authorities must consider and decide (taking into account size and public interest in their respective functions), which grade is appropriate to the various records management tasks in hand. 8 The newly-created post - within the Office of the First Minister and Deputy First Minister - of Information Manager for the Northern Ireland Civil Service was filled by Mary Cunningham in November 2002. Its purpose is to develop policies on document and records management and to gain corporate agreement to such policies across the Northern Ireland Civil Service. The development of the necessary infrastructure for an Electronic Document and Records Management system to enable Departmental (ie, the 11 Northern Ireland Departments) implementation is also a key element of the post.

8 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

neglecting the registry function or ignoring it altogether. This appears to have been a problem for some time.

Notes for the use of Registry Branches - published by the British Treasury in 1919 and issued to the Belfast Branch of the Irish Chief Secretary’s Office – state that:

Heads of Departments should take effective steps to combat the tendency of administrative officers to protest their ignorance of the methods of the Registry and to consider that their duty in this respect is done if they see that the paper before them has a number on it. This attitude has been responsible for much inefficiency in the working of the machinery of Government Departments in the past.

The situation had obviously not improved that much by the end of World War Two. When considering the case for adequate records management staffing, senior staff should perhaps bear in mind the now politically incorrect comments of a report on Departmental Registries in Northern Ireland, published in 1946:

There is undoubtedly a widespread impression that Registry work is of a purely routine character and can be discharged by officials who have proved to be misfits or failures in other Branches. The Registry is in fact a key point in a Department and … a proportion of the work requires intelligence, judgement and experience as well as memory. The provision of suitable staff is, therefore, essential for the efficient working of the Registry and, consequently, of the Department.

In the same way that the human body requires limbs in order to operate efficiently, Information Managers need LIMs (Local Information Managers), so that they can carry out a wide range of records management duties effectively. LIMs should be officers that are usually a grade (or two) lower than that of the Information Manager, and possess a proficient knowledge of the business area within which they are working.

It is in the best interests of the Information Manager that he/she meets regularly with the LIMs, in order to share information, issue instructions and monitor progress as regards the carrying out of information audits or records surveys, the development of file plans or filing systems, and the drafting of disposal schedules.

While LIMs will not usually need the same professional or high level of training that the Information Manager requires, they should receive specific instruction on records management policies and procedures.

And, last, but by no means least, new recruits to any public authority should receive mandatory training on records management principles and practices. This is the only way to ensure that the necessary records management cultural change takes effect and becomes sustainable.

9 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

2. Information Audits

2.1. Why carry out an information audit or records survey?

Public authorities in Northern Ireland should be engaged in renovating their respective records management structures and systems, with a view to servicing the needs of Data Protection, Environmental Information Regulations, and Freedom of Information legislation, and also to prepare the way for the introduction of an Electronic Document and Records Management system. In this regard, it is important to develop file plans or filing systems, and to prepare disposal schedules that point to the future. Such file plans and disposal schedules will be informed by feedback from information audits. As well as helping to prepare for the future, information audits will also identify records that will no longer play a part in new records management systems. It is important that these records are dealt with sooner rather than later, but the first priority must be to prepare for the future (see para. 3.1).

2.2. What is an information audit/records survey?

The National Archives (London) defines an information survey as ‘a comprehensive gathering of information about records created or processed by an organisation’. In its guidance document on ‘Records and Information Surveys’, the National Archives also states that:

An information survey is a prerequisite for the work of the records manager. Records are the reflection of an organisation’s activities. The survey provides access to these activities and the records that arise from them. It profiles each record series and system, and helps to identify any problems, establishes a records management programme, and quickly to design a filing system or produce a disposal schedule. It also helps to determine what is required to install and maintain the records management programme (space, equipment, personnel, etc) as well as how to evaluate the efficacy and economy of records management systems.9

And, while the National Archives (London) points out that an information survey ‘is the first and most important step to the proper control of records’, it also advises public authorities that ‘the collection and analysis of data from an information survey is time-consuming and labour intensive’.

2.3. How should the information audit be carried out?

2.3.1. It is important that senior management (eg, the Chief Executive and Senior Management team) within the public authority supports the carrying out of an information audit, and indicates this in writing, eg, in a memo to staff.

2.3.2. Before the information audit is undertaken, the Information Manager must establish its aims and objectives. Of immediate concern will be the ______9 See, ‘Records and Information Surveys’, National Archives (London) website: http://www.pro.gov.uk/recordsmanagement/standards/surveys.pdf

10 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

development of a file plan or filing system, and the compilation of a disposal schedule. Other goals could include the establishment of a centralised registry, and the construction of a records management training strategy.

2.3.3. A questionnaire should be devised by the Information Manager, and issued to each of the LIMs. A strict timetable for the return of the questionnaires should be agreed - no returns or nil returns are unacceptable. Communication is always important, and Information Managers should meet with LIMs during the course of the information audit to discuss any urgent issues that have arisen. Feedback from the questionnaires should be analysed by the Information Manager and a comprehensive report should be produced, again, according to a strict timetable.

2.3.4. If the staff and/or functions of the public authority are split between a number of sites, then it may be necessary for the Information Manager to visit them for the purposes of a physical inspection. Such visits will add another dimension to the information gathered from the questionnaires.

2.4. What information should be sought?

2.4.1. The information audit questionnaire should request a statement outlining the nature and scope of the function(s) carried out by the particular Branch or business unit represented by the LIM. This statement can be used again in any disposal schedule(s) compiled at a later date.

2.4.2. The questionnaire should seek to test the level of staff awareness of records management principles and practices. Ask staff to indicate how much experience they have in dealing with file management issues (eg, have they ever drawn up a file plan for their area of work). And, ask them to note any records management training they have received recently (ie, within the last 3 years).

2.4.3. It is particularly important that the questionnaire should request information on what records are held and on the activities to which they relate. The following are examples of questions that could be posed:

How many files/records are held? or What is the volume of files/records held?

What is the date range of the files/records held?

2.4.4. Information about file/record series (eg, policy files, case files) or, if the files/records in question are not associated with a particular series, then information about the function(s) to which they relate, should be recorded. This information will provide the basis for the disposal schedule(s).

2.4.5. All records should be included in the questionnaire, whatever their form, eg, paper, microform, tape, etc. It is probably best that electronic records

11 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

are covered by an audit which is separate and distinct, but if there are linkages to paper-based records or others on a different medium, then such linkages should be noted.

2.4.6. Although information audits are concerned primarily with the examination of current files/records, it is important in the circumstances (see, para. 2.1) that semi-current files/records are included. Even if semi- current or inactive files are held in commercial storage, they are part of the picture and must feature in the audit.

2.4.7. Copies of files/records should be included in the audit, ie, those held by the Branch or business unit or by individual members of staff. Such files (and their fate) will feature in the disposal schedule(s).

2.4.8. Unfortunately, many staff in public authorities, have assembled something like a ‘private registry’ over the years for their own convenience. This bad practice must cease within the new records management environment that your organisation is establishing. Files/records in such ‘private registries’ and, indeed, unregistered files/records anywhere within the public authority, must be included in the information audit process.

2.4.9. Sensitive files/records should feature in the information audit questionnaire. Such material - eg, personnel files or medical case files - is a vital part of the public authority’s information assets. It is exactly the type of material that could be needed in the event of a Data Protection, Environmental Information Regulations or Freedom of Information request. Of course, appropriate safeguards should be taken by the Information Manager and others to ensure that access to sensitive information within the public authority is strictly controlled.

2.4.10. Information about the movement of files/records between staff in the public authority is required, and also about the frequency of consultation. Centralised or de-centralised tracking systems should be described briefly. If files have been misplaced or have gone missing, then such information should be recorded.

2.4.11. The information audit questionnaire should be used to compile an inventory of record containers (eg, filing cabinets, file racking/shelving). Storage problems, whether on-site or off-site, should be noted, eg, damp, files/records lying on the floor unprotected or lack of space. This information will help the Information Manager to determine whether or not additional storage space is required or whether new file storage systems are needed in order to ensure the fast retrieval of files/records.

12 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

3 INFORMATION AUDIT QUESTIONNAIRE

SAMPLE QUESTIONNAIRE AND RESPONSES (1)

Department: Culture, Arts and Leisure

Agency: Public Record Office of Northern Ireland (PRONI)

Local Information Manager: Cynthia Smart10, Head of Corporate Services Section, PRONI11

Date: June 2003

1. Describe the function(s) of the The Records Management Unit forms part Branch or business unit in a brief of the Records Management and statement Administration Section. It is responsible for providing records management advice and guidance to Northern Ireland public authorities by establishing standards, engaging in case work, answering specific enquiries, delivering presentations and training, running the Information Managers’ Forum, and organising conferences. The records administration function will be dealt with in a separate questionnaire.

2. Title/reference of record Records Management series/function File reference prefix: ‘RM’

Generally speaking one form should be used for each file series (see, footnote 11 below). However, it is acceptable to record a group of miscellaneous files on one form.

3. What information do the files Information about the policies, procedures contain? and operational activities of the Records Management Unit of the Records Management and Administration Section within PRONI. ______10 A fictitious name, but the post exists. 11 It is assumed that PRONI’s LIM has issued the information audit questionnaire to each of the Heads of Section within the organisation: Access, Corporate Services, Education, Learning and Outreach (ELO), Public Services, Information Systems, Records Management and Administration (RMA), and Funding and Project Management; and, that the Section Heads are submitting a completed questionnaire for each file series corresponding to a functional area within their responsibility. For example, the Head of Records Management and Administration Section would be expected to submit two completed questionnaires, one dealing with the records management function (which is the sample questionnaire shown), and the other dealing with the records administration function. Upon receipt of all the questionnaires, the LIM would put together a composite return on behalf of PRONI.

13 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

3 INFORMATION AUDIT QUESTIONNAIRE

SAMPLE QUESTIONNAIRE AND RESPONSES (1)

4. Describe the file plan structure Below is the proposed file plan. Records management files are presently referenced ACQ/ = Acquisition (the name of the Section dealing with records management matters until January 2003):

RM/ = Records Management

[the function within your public authority]

RM/1/ = Case work

[the type of work activity associated with the function]

RM/1/1/ = Health

[the functional area that your public authority is dealing with]

RM/1/1/1/ = Department of Health, Social Service and Public Safety, or

RM/1/1/2/ = Northern Health and Social Services Board

[the public authority carrying out Health functions]

RM/1/1/1/1/2003 = Information Audits, or

RM/1/1/1/2/2003 = File Plans

[type of work activity that your public authority is engaged in with another public authority, and the year the file was opened]

The importance of setting out clearly the existing file plan (or the proposed one) cannot be exaggerated. It is vital to the success of the audit.

14 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

3 INFORMATION AUDIT QUESTIONNAIRE

SAMPLE QUESTIONNAIRE AND RESPONSES (1)

5. File Referencing system Alpha-numeric, eg, RM/1/1/1/1/2003

6. Date range of the files 2003 onwards

Note the earliest and latest dates of the files concerned. 7. Format of the records Paper (standard files)

If the records are on more than one medium, then indicate what the combination is (eg, paper files and microfilm).

8. Physical state of the records Good.

Note if any of the files/records are in a poor physical condition (eg, files afflicted with damp or dirt, contain paper clips and pins).

9. Finding-aids File register available as a Word document on the PRONI computer network T-drive. Maintained by Corporate Services Section.

Include finding-aids that may be in the form of indexes, file lists, file manuals, computer databases, etc.

10. Who refers to the records and how Primarily Records Management Unit (RMU) often? staff, but also staff of the Records Management and Administration, Corporate Services, and Access Sections.

RMU staff consult the files almost daily.

Record the number of retrievals from the series per week or per month if possible.

11. Status Registered files (no copies are maintained). Indicate if any of the records are very important (eg, precedent files).

15 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

3 INFORMATION AUDIT QUESTIONNAIRE

SAMPLE QUESTIONNAIRE AND RESPONSES (1)

Note if copies of files or related papers are held and, if so, where they are held if outside the registry.

12. Are protective markings No. applicable? If yes, which marking is applied? (ie, restricted, confidential, Note where any sensitive files/records are secret or top secret). kept, and who has access to them.

13. Is there information in other Yes. Some key records management files/records, which duplicates documents will be copied to the Records information contained in this file Administration ‘RA’ file series. series?

14. Do the files provide evidence of No, but they provide information about the the origins, structure, policy and establishment of the Records Management functions of the public authority? and Administration Section on 6 January 2003, (formerly Acquisition Section).

15. Do the files have long-term Yes. Some of the files will document historical/research value? PRONI’s attempts to help Northern Ireland public authorities prepare for the introduction of the full provisions of the Freedom of Information Act 2000 in January 2005.

16. What is the volume of records 3 linear metres (current records) 1 linear metre (semi-current records)

17. Annual growth rate 1 linear metre (current records)

18. Location The File Registry in the Corporate Services room. However, individual files will continue to be marked out to staff as required and held in desk drawers, filing cabinets, etc.

Multiple locations should be noted on the same form.

19. Storage equipment used Lateral filing system located in the Corporate Services room.

16 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

3 INFORMATION AUDIT QUESTIONNAIRE

SAMPLE QUESTIONNAIRE AND RESPONSES (1)

20. After what period do the records Generally 5 years. become inactive or semi-current? Indicate whether or not any disposal schedule or other directive exists for the files/records.

21. Is the retention period affected by No. The files would normally be closed legislation? after 5 years and then receive a first review (See, the Northern Ireland Records Management Standard: http://www.proni.gov.uk/NIRMS/NIRMS1.pdf

Cite any relevant legislation.

22. Are the records required for audit Yes. Records management processes are purposes? reviewed periodically by Internal Audit and the Northern Ireland Audit Office.

Signature: David Lammey Date: June 2003

Section: Records Management and Administration Section

Key to information audit sample questionnaire:

Text in black – typical responses to the information audit questionnaire

Text in blue – response to question 3, it indicates what each level of the file plan relates to

Text in red – gives general advice on the type of information/response required

17 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

STAFF/EQUIPMENT QUESTIONNAIRE

SAMPLE QUESTIONNAIRE AND RESPONSES (2)

Department: Culture, Arts and Leisure

Agency: Public Record Office of Northern Ireland (PRONI)

Local Information Manager: Cynthia Smart12, Head of Corporate Services

Date: June 2003

1. How many staff spend 50% or more of 4 staff in the Records Management and their work time engaged in records Administration (RM&A) Section, management and/or registry duties? including the Section Head

2. What are the grades of the staff 1 x Curatorial D (RM&A Section Head) engaged in records management and/or 1 x Curatorial E registry duties? 1 x Curatorial F 1 x AO

Note: 1 x AA in Corporate Services spends c.5-10% of work time opening files, filing documents, etc.

3. How many records management and/or None of the staff have attended any registry staff have received training in formal course(s). Only ‘on-the-job’ records management principles and training has taken place. practices within the last 3 years?

4. What is the total number of staff served The Records Management Unit (RMU) by records management and/or registry staff are involved in records staff, and their location(s)? management outreach work with central and local government bodies, NDPBs, the Courts, etc.

RMU staff also provide advice to c.70 PRONI staff at headquarters (66 Balmoral Avenue, Belfast).

______12 See footnote 10.

18 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

STAFF/EQUIPMENT QUESTIONNAIRE

SAMPLE QUESTIONNAIRE AND RESPONSES (2)

5.What comments have been made by ‘You can’t move for filing cabinets.’ records management and/or registry staff about records management matters, eg, ‘Our records store is a mess.’ the state of file management in the Branch/Agency, their level of competence ‘Files are always being lost or and whether or not they need training? misplaced.’

‘I can never find anything without a lot of trouble.’

‘I’ve been here for 4 years and have never been given any formal records management training.’

6. Provide an inventory of equipment used 37 x 4-drawer filing cabinets to store records? 2 x lateral filing units (Corporate Services room)

Note: These figures are for PRONI as a whole.

7. What is the area occupied by file 20m2 storage equipment (in square metres)?

2.5. Evaluating feedback from the information audit questionnaire

2.5.1. Read and analyse the completed questionnaires promptly so that the information provided does not become out of date.

2.5.2. Remember why you carried out the audit in the first place (see para. 2.1). The aim is to improve records management systems in general and to develop file plans and prepare disposal schedules in particular.

2.5.3. Files/records that have no further administrative and/or legal value can be referred to the Public Record Office of Northern Ireland (PRONI) to see if they have any long-term historical/research interest.

2.5.4. Files/records identified as semi-current or inactive within a registry should be removed to a low cost out-store.

______

19 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

2.5.5. It is particularly important to identify unregistered files so that they can be brought into a formal file management system and feature in the file plan. If they have no future use they can be dealt with as recommended in para. 2.5.3.

2.5.6. Duplicate files should be destroyed as soon as possible. Remember, under the provisions of the Freedom of Information Act, if you hold certain information, then you may well be required to answer a related enquiry.

2.5.7. Sensitive files/records that are held in an open registry or are easily accessible must be removed to a secure storage area (eg, a strongroom accessible only by a key held by an authorised officer).13

2.5.8. Ineffective or faulty equipment should be replaced, and partially-filled filing cabinets or other file storage equipment should be identified so that consolidation of files/records can take place.

2.5.9. Consider seriously the comments made by staff during the course of the information audit.

2.5.10. Discuss consolidated feedback with appropriate staff, eg, Information/Records Managers should meet with their Local Information Managers.

!!! SOMETHING TO PONDER !!!

Recently (2002), an independent survey for Document Management magazine came up with these figures14:

♦ It costs £25 to file a document

♦ It costs £85 to look for an incorrectly filed document

♦ The average employee creates 22 documents per day

♦ A large organisation loses a document/file every 12 seconds

♦ 7.5% of documents filed incorrectly are never found

♦ It costs £16,000 to fill a 4-drawer filing cabinet

♦ It costs £1,200 per annum to manage a filing cabinet

The point here is that records management costs money, but bad records management costs even more money. ______13 See ‘Introduction of a new protective marking system’, a circular issued by the Department of Finance and Personnel referenced CSC 8/94. 14 The figures were drawn to my attention by Danny McConnell of Deloitte and Touche.

20 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

2.6. The Information Audit Report

2.6.1. The report should point to the need for the development of an up-to-date file plan, which reflects the functions of the public authority not its organisational structure, which is apt to change. A file plan based on the functions of the public authority will be more durable and require less maintenance.

2.6.2. The report should also conclude that the public authority requires a disposal schedule(s), which will give legal authority to the destruction or preservation of files/records. Moreover, the disposal schedule should mirror the file plan, so that files/records or file series identified by the information audit and which appear in the schedule have an appropriate action or fate noted against them. Examples are:

Types of Files/Records Action Flexi-sheets Destroy 3 months after the period to which they refer

Individual staff file(ie, copy Destroy 6 months after member held by line manager) of staff leaves the Branch/Agency

Enquiries ‘E’ files Review 5 years after file has been closed (ie, 1st review)

2.6.3. Make other recommendations influenced by feedback from the information audit questionnaire and discussions flowing from it.

2.6.4. If records management training is being proposed, indicate the nature and scope of the training, who should attend/enrol, etc., the expected costs and relevant timescales.

2.6.5. If additional records management staff are being proposed, set out the number and grade(s) of staff required, whether they should be transferred from other areas of the Branch/Agency or whether they should be recruited from outside the organisation.

2.6.6. A change in the culture of the public authority can be encouraged if procedures are tightened up. For example, the Information Manager should recommend that only authorised officers can open files, that the file tracking system must be used (and not abused), and that if a tracking system is absent then one should be established.15 It is in your interests to use the information audit to improve attitudes towards file management because Information Managers:

______15 See, ‘Records Management Standards: Tracking Records’, RMS 2.1, (National Archives (London), 2000). Web reference: http://www.pro.gov.uk/recordsmanagement/scoping/gsrmstra.pdf

21 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

… are responsible for ensuring the operation of an effective and efficient registered file system, for ensuring that it is used by all operational areas of their organisation, and that all relevant documentation is accurate and available to staff of the organisation when required.16

2.6.7. Where costs (eg, concerning equipment) can be measured with a good degree of accuracy, and cost savings can be identified, then such savings should be recorded in the report. This may help to keep senior managers in tune with the process!

______16 Quoted from, ‘Records Management Standards: File Creation’, RMS 1.1, (National Archives (London), 2000), p.4. Web reference: http://www.pro.gov.uk/recordsmanagement/scoping/gsrmscre.pdf

22 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

3. Disposal Schedules

3.1. Regular and Special Disposal Schedules

PRONI recommends that public authorities draw a ‘line in the sand’ as regards their existing holdings of files/records. On the one side should stand files/records that have a continuing administrative/legal value to the public authority, and that will feature in any new file plan or filing system and disposal schedule(s). On the other side, there should stand files/records that do not have a continuing administrative/legal value to the public authority. A special ‘one-off’ disposal schedule should be compiled for this material, which is redundant as far as the public authority is concerned (see the next section of the Guidelines, The Backlog: Special Disposal Scheduling).

Basically, the message is:

Clear out old files – do not integrate into a new file plan or filing system – a special ‘one-off’ disposal schedule should be compiled to deal with them.

3.2. What does ‘disposal’ mean?

Disposal does not just mean ‘destruction’. It also means the transfer of records selected for permanent preservation to PRONI. The term ‘disposal’ can also be used to note the movement of records from one medium to another (eg, paper to microfilm or electronic).

3.3. Why have a disposal schedule(s)?

Disposal schedules are required under the Public Records Act (NI), 1923. They encourage control over the records created by a public authority; they enable Information/Records Managers to dispose of records promptly when they cease to be of any continuing administrative/legal value; and they identify records that should be transferred to PRONI because of their long-term historical/research value.

3.4. How many disposal schedules are required?

Disposal schedules should be drawn up for each operational area of a public authority. Every Branch (eg, Personnel Branch), business unit (eg, Facilities Management Unit) or Executive Agency (eg, PRONI) within the eleven Northern Ireland Departments should possess its own schedule. Large Non-Departmental Public Bodies and District Councils should have a disposal schedule for each of their operational areas. One disposal schedule should be sufficient to cater for the smaller NDPBs and local authorities. PRONI will advise in any cases of doubt. Most importantly, disposal schedules must include all records created by the public authority.

23 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

3.5. What is the role of the Information/Records Manager in relation to disposal schedules?

3.5.1. The Information/Records Manager advised by his/her LIMs is responsible for drafting the disposal schedule(s). To do this, he/she must appraise the public authority’s records to determine the disposal actions to be taken, eg, a destruction date or a review date. Such action should be informed by the business needs of the public authority and by its legal obligations.

3.5.2. The Information/Records Manager is also responsible for ensuring that the disposal actions specified in the schedule(s) are carried out, and that the schedule(s) is updated regularly – NIRMS recommends an annual update, but if this proves to be unrealistic in terms of the resources available to carry out the task or because there has been little change in the types and range of records created, then an update every two years would be acceptable.

3.6. What steps should the Information/Records Manager take to ensure the smooth running of the disposal scheduling process?

3.6.1. The Information/Records Manager should establish a timetable to cover the disposal scheduling process: from the stage of assessing the contents of the Information Audit through to its signing (see para. 3.9.8) and implementation (see paras 3.10 and 3.11). Without a timetable, matters will drift and jeopardise the successful conclusion of the process. The timetable should be realistic, allowing appropriate staff sufficient time to carry out their respective tasks.

3.6.2. The Information/Records Manager should arrange regular monitoring meetings with Local Information Managers (LIMs) to ensure that agreed tasks are being completed according to the timetable targets. These ‘information forums’ should also be used to discuss, and seek to resolve, any difficulties that have arisen during the disposal scheduling process.

3.7. Apart from LIMs, whom else should the Information/Records Manager consult during the disposal scheduling process?

3.7.1. The public authority’s Internal Audit services (and possibly also the Northern Ireland Audit Office) should be consulted, so as to ensure that audit requirements are met before any documents/records are destroyed.

3.7.2. The public authority’s finance and/or accounting units/sections/branches should be consulted, with the aim of identifying locally-held copies of financial/accounting records that can be destroyed sooner rather than later. It may be that locally-held copies can be destroyed after 3 years, whereas the master (original) copies held by the ‘central’ finance and/or accounting unit/section/branch, etc., must be held for 7 years before they can be destroyed. If such locally-held copy records can be identified for early destruction, it is important that Internal Audit is content with the minimum retention periods of such records. Written confirmation should

24 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

be obtained from Internal Audit, and the file reference on which this confirmation is kept should be recorded on the relevant disposal schedule(s).

3.7.3. The public authority’s personnel unit/section/branch should be consulted similarly (see para. 3.7.2 above). Again, it is likely that locally-held copies of personnel documents/records can be destroyed earlier than the master (original) copies. Obtain written confirmation from the personnel unit/section/branch, and record the reference of the file on which this confirmation is kept on the relevant disposal schedule(s).

3.7.4. If records of a non-administrative or specialised nature are going to feature on the disposal schedule, it will be necessary to consult with the staff who are working with this material, eg, professional and technical officers, scientific officers, school inspectors.

3.7.5. The Information/Records Manager should consult with the Information/Records Managers of public authorities with which his/her public authority has close business relations. It is important to establish in writing, which body holds the master (original) set of records. For example, the Department of Enterprise, Trade and Investment (DETI) will possess a copy of the minutes produced by the Northern Ireland Tourist Board as parent Department. However, these copy minutes need only be kept for a short period of time for business purposes (eg, for a year after the minutes have been produced). The original minutes produced by the Tourist Board should be retained for a longer period for business/reference purposes, and then transferred to PRONI no later than 20 years after the file or volume containing the minutes has been closed.

3.7.6. It may be necessary for Northern Ireland Departments to consult with UK Departments on matters where responsibilities overlap. For example, the Assistant Chief Inspector (Criminal Justice Services), who is based in the Social Services Inspectorate (SSI) - a professional body within the Department of Health, Social Services and Public Safety (DHSS&PS) - is responsible for policy advice to the Criminal Justice Division of the Northern Ireland Office. Therefore, it is essential that there is consultation between the DHSS&PS Departmental Information Manager, the SSI and the Northern Ireland Office’s Departmental Record Officer, on the disposal instructions contained in the SSI’s disposal schedule.

3.8. What is the role of PRONI in relation to disposal schedules?

3.8.1. Once the disposal schedule(s) has been drafted by the Information/ Records Manager, PRONI should be invited to quality assure its contents. While PRONI staff will not have a full knowledge of the function(s) of the public authority, they will be able to give advice drawn from the experience gained through liaising with a wide range of public authorities in Northern Ireland for many years. Typically, PRONI staff will satisfy themselves that the schedule:

25 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

includes all the records created by the public authority; that disposal recommendations are appropriate (ie, that the records concerned are located in the correct disposal category: destruction, review or permanent preservation); and that the action dates are also fitting.

Once the Information/Records Manager and PRONI agree any changes to the draft, the disposal schedule can proceed to the signing (see paras 3.9.8 and 3.9.9).

3.8.2. PRONI staff will also wish to satisfy themselves that appropriate steps are being taken by the public authority to ensure that files/records are kept in good physical condition, and that good filing practices (as set out in the Northern Ireland Records Management Standard (NIRMS), para. 7) are followed.

3.9. What format should a disposal schedule follow?

The suggested format is described below.

3.9.1. The title page or front page should record:

the name of the public authority, eg, Department of Health, Social Services and Public Safety

the name of the operational area whose records are being covered by the schedule, eg, Social Services Inspectorate

the corporate logo(s)

the Implementation Date of the disposal schedule

the Review Date of the disposal schedule

the reference or version number of the disposal schedule

3.9.2. There should be a contents page for ease of reference.

3.9.3. There should be an Introduction that includes:

an explanation of the purpose of the disposal schedule, and its statutory basis (ie, the Public Records Act (NI) 1923) a brief administrative history of the public authority that records any significant events (with specific dates if possible)

a summary of the present-day functions of the public authority, noting its relationship with other public authorities

a list of the primary legislation under which the public authority carries out its functions, for example:

26 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

The Social Services Inspectorate of the Department of Health, Social Services and Public Safety carries out inspections under statutory powers contained in a range of primary legislation, including

Health & Personal Social Services (NI) Order 1972 (as amended in 1991 and 1994)

Adoption (NI) Order 1987

Probation Board (NI) Order 1982 (as amended by the Criminal Justice (NI) Order 1991

Registered Homes (NI) Order 1992

Children (NI) Order 1995

3.9.4. A list of Abbrieviations and/or Glossary of Terms should be included if it is thought that they would be helpful aids to understanding the text.

3.9.5. A series of short statements outlining the file management system and corporate records management policy, noting for example:

when to close files, folders, records, etc

what to do if records are to be retained by the public authority for administrative/legal purposes

when and how to carry out an appraisal or review of records

the roles and responsibilities of the Information/Records Manager, LIMs, and individual members of staff in the branch, business unit, etc

3.9.6. A statement declaring the public authority’s commitment to preserving files/records prior to their destruction or transfer to PRONI, and to good filing practices (as set out in NIRMS, para. 7). The following statement should be used:

The [name of the public authority] declares that it will take measures to ensure that the records it creates will be physically well maintained and cared for while they are in its custody, ie, until either destroyed or transferred to PRONI for permanent preservation. These measures will include:

Removing paper clips and pins from papers before filing with particular attention being given to those records, which, according to the Disposal Schedule, are to be preserved permanently

Removing any floppy disk from paper files, and converting its contents to hard copy

27 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

Using files with file covers as opposed to buff folders, which do not offer the same protection to the papers inside

Using continuation files if files get too bulky ( ie, more than 25mm thick)

Punching papers to be filed 25mm in and 25mm down from the edge to minimise the danger of detachment and resulting loss of information

Storing bulky or outsize items in a pocket or envelope inside the file cover on the left-hand side

Remember – the signed disposal schedule is the authority not just for destroying records, but also for preserving them. If records are not in good condition at the time of their transfer to PRONI, their long-term preservation will be jeopardised.

3.9.7. A series of short statements defining the work areas within the Branch, business unit, etc., and the types of records created.

Example 1

Work Area – Chief Executive’s Office

Description of Work Area function(s) – The Chief Executive’s Office services the administrative needs of the Chief Executive and the Senior Management Team by arranging meetings, preparing and issuing agendas and invitations, providing hospitality to VIPs, producing powerpoint presentations, etc. Description of records created – Minutes of Senior Management Team meetings, responses to Assembly Questions, correspondence files, invitations, publications, and presentations.

Example 2

Work Area – Information Systems and Information Technology Section

Description of Work Area function(s) – The Information Systems and Information Technology Section provides for the hardware and software needs of each business area within the organisation, and arranges appropriate IT training for staff.

Description of records created – Team Brief minutes, reports and submissions concerning the Information Systems Strategy, correspondence files, query logs, training files, and register of IT equipment.

28 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

Example 3

Work Area – Business Support Unit

Description of Work Area function(s) - The Business Support Unit ensures that a proper grading structure and loading of posts is in place throughout the Department.

Description of records created – Correspondence and papers concerning efficiency assignments, papers on bids for additional posts, and submissions on staffing matters.

3.9.8. The Schedule of Records is the core of the disposal schedule. It details the files concerned and the actions to be taken. See sample layouts 1 and 2 (pages 36-38 below). Either would be acceptable but sample 1 is preferable because it is more detailed, and reflects the type of information that Electronic Document and Records Management systems will require. Sample 2 is the more traditional and simple schedule, which may best suit the needs of smaller public authorities.

For the most part, the Schedule of Records should identify and describe each record collection or file series, not individual records. Of course, there will be exceptions to this general rule. Where individual records or files have been selected for permanent preservation (eg, because they contain information which marks a precedent), it makes sense that they are identified and described clearly on the Schedule of Records. When the time comes for the destruction or review of the record collection or file series of which they form a physical part, it will be much easier to sift them out of the pile.

DISPOSAL CATEGORIES

There are three possible disposal actions/instructions:

Category 1: Files/records for Review by the Public Authority and PRONI

These are record collections or file series that require appraisal on an item-by-item (or file-by-file) basis because it is not easy to determine whether destruction or transfer to PRONI is appropriate. The public authority should examine this material first. If destruction is recommended - because the administrative/legal use of the material has been exhausted - then PRONI should carry out its review to determine whether or not the material is of long-term historical/research value. If it is, then PRONI will either seek its transfer for permanent preservation as soon as is administratively convenient or put the material into internal limbo17 storage to await a second review, 15 years later. If PRONI does not want the material,

______17 When files/records are put into ‘internal limbo’, it means that the material has been taken into the temporary custody of PRONI until it reaches the 20-year mark. It is then reviewed again by PRONI staff to determine whether or not it should be preserved permanently. Remember, under the Public Records Act (NI) 1923, official records are to be transferred 20 years after the date of the last paper on the file, volume, etc. If PRONI does not want to keep the material, it will provide the public authority with a list of the files/records to be destroyed for information/reference purposes.

29 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

then the files/records concerned should be destroyed as soon as is administratively convenient.

Category 2: Files/records identified for Permanent Preservation by the Public Authority and PRONI

These are files/records of long-term historical/research value, such as policy files, precedent files, annual reports and accounts, unpublished or published administrative histories, organisational charts, etc, which should be transferred to PRONI no later than 20 years after the date of the last paper on the file, volume, etc.

Category 3: Files/records for Destruction by the Public Authority

These are low-grade files/records of no lasting administrative/legal value to the public authority and of no long-term historical/research value to PRONI, such as vouchers, invoices, travel claim forms, attendance books, stationery and supplies requisitions, in-coming circulars (for information). It is the responsibility of the public authority to arrange for the destruction of this material (see para. 3.12 below).

Note:

Records documentation or metadata, ie, records that document record collections or file series such as registers and indexes, form part of the records created by public authorities and must not be excluded from the disposal scheduling process. The National Archives (London) advises that

They should be kept at least until all the registered or indexed records have been disposed of, whether this is by destruction or by transfer to the PRO [ie, in the case of Northern Ireland public records, PRONI]. Thereafter some of these records may themselves be transferred to the PRO [ie, PRONI] with the records they document or may be retained for a further period for the business needs of the organisation.18

______18 See, ‘Records Management Standards: Disposal Scheduling’, RMS 5.1, (National Archives (London), 2000), p.8. Web reference: http://www.pro.gov.uk/recordsmanagement/standards/disposal-scheduling.pdf

30 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

SCHEDULE OF RECORDS LAYOUT (SAMPLE 1)19

FILE/RECORD FILE/RECORD RETENTION WORK AREA TYPES OF FILES/RECORDS REFERENCE or ACTION PERIOD FINAL ACTION DESCRIPTION Office Support Accommodation files ACC/1/1/1998 Close at end of 5 years Destruction by Head of Branch financial year Chief Senior Management Team CX/1/1/2003 Close at end of 5 years Normal Review Process20 Executive’s minutes financial/Business Office Plan year Personnel Individual Staff files (locally- PR/1/33/1995 Held by line Until 6 months after Destruction by line manager held duplicate files) manager staff member leaves Corporate Annual Report & Statement of CS/1/1/2002 Close when report 2 years or until Destruction by Head of Branch Services Accounts file has been published audited Corporate Annual Report & Statement of Publication Activate mailing list Retain copy in library, Permanent Preservation: transfer Services Accounts information centre, copy to PRONI etc Finance Accounts files FIN/ACC/10/1997 Close at end of 7 years Destruction by Head of Branch financial/Business Plan year Research & Airport: Noise Pollution Survey: RD/1/1/1998 Close when survey 5 years Normal review process (if a report on Development correspondence, papers and has been completed the findings is published, transfer a statistics files copy to PRONI) Complaints Case files CF/2/77/2000 Close when case 3 years Destruction by Head of Branch has been concluded (except for Investigation Reports which are all to be transferred to PRONI no later than 20 years after their compilation).

Complaints Register of Cases CR/2/1/2000 Close at end of 3 years Permanent Preservation: transfer financial/Business registers together with corresponding Plan year Investigation Reports to PRONI

______19 For ease of reference the sequence of files/records listed in the Schedule of Records Sample 1 should follow the sequence of work area descriptions listed in the previous section of the Disposal Schedule (see para. 3.9.7). 20 See NIRMS ‘Reviewing Procedures’ at http://www.proni.gov.uk/NIRMS/NIRMS1.pdf

31 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

SCHEDULE OF RECORDS (SAMPLE 2)21

Destruction List

File Reference File Description/Title Destroy After ACC/1/1/1998 Accommodation Files 5 years

PR/1/33/1995 Individual staff 6 months after staff File held by line member leaves manager FIN/PAY/4/1996 Payment files 7 years after file closure

CS/1/1/2002 Annual Report & 2 years or until Statement of Accounts audited file CF/R/ file series Complaints files: cases 2 years rejected by Investigating Officer as falling outside jurisdiction

Review List

File Reference File Description/Title Review Date MIN/7/3/2000 Ministerial meetings Normal review process if and visits files files contain useful summaries of significant issues and visits (otherwise destroy) OPS/3/2/1997 Branch operating Normal review process instructions DCAL/LANG/3/2001 Bi-lingual Place Name Normal review process files CX/1/1/2003 Senior Management Normal review process Team minutes RD/1/1/1998 Airport: Noise Normal review process Pollution Survey: (if a report on the correspondence, findings is published, papers and statistics transfer a copy to files PRONI)

______21 The Schedule of Records Sample 2 is divided up into three distinct lists (as opposed to one all-inclusive list in the Schedule of Records Sample 1).

32 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

SCHEDULE OF RECORDS (SAMPLE 2) (CONTINUED)

Preservation List

File Reference File Transfer [to PRONI] Description/Title Date DCAL/SD/6/2000 Departmental When business use has Working Group on ceased, but no later National Sports than 20 years after file Stadium: policy and closure consultation papers CS/NDPB/1/2001 Establishment of When business use has Legal Aid Society as ceased, but no later an NDBP: draft than 20 years after file legislation, and closure policy/strategy papers N/A (related file, Annual Report & Copy to PRONI upon CS/1/1/2002) Statement of publication Accounts CF/2/77/2000 Complaints When business use has Investigation Reports ceased, but no later than 20 years after file closure

CR/2/1/2000 Register of Transfer together with Complaints corresponding Investigation Reports

3.9.9. A list of signatories should follow the Schedule of Records. The Public Records Act (NI) 1923 requires the signatures of at least three ‘Inspecting Officers’ plus the officer ‘specially conversant’ with the records of the public authority22. They are signing in accordance with the provisions of the Public Records Act (NI) 1923, and the Disposal of Documents Order (NI) 1925, No.167, and they should include:

♦ the PRONI officer who has liaised closely with the public authority, and has quality assured the disposal schedule in its draft form, eg, the Head of Records Management and Administration Section, PRONI, or one of his/her curatorial staff ♦ the Chief Executive/Deputy Keeper of the Records, PRONI

______22 See para. 1.1 above.

33 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

♦ the Permanent Secretary, Department of Culture, Arts and Leisure (DCAL) or the Deputy Secretary and Principal Establishment and Finance Officer (PEFO)

♦ the most senior public servant in the public authority concerned. For example:

• Permanent Secretary of the Department of Health, Social Services and Public Safety • Chief Officer, Western Health & Social Services Council • Chief Executive, Western Health & Social Services Board • Director, General Consumer Council for Northern Ireland • Chief Executive/Town Clerk of Belfast City Council • Secretary, Staff Commission for Education & Library Boards • Chief Executive of the Northern Ireland Tourist Board • Lord Chief Justice, Northern Ireland Court Service

♦ another senior officer in the public authority, eg, a Grade 5 (Assistant Secretary) in one of the Northern Ireland Departments or the head of a significant Divison or operational area within the public authority, eg, Director of Corporate Services

♦ the principal professional officer in the public authority if the records of a professional body forms part of the Disposal Schedule, eg, the Chief Inspector of Schools

♦ the officer ‘specially conversant’ with the records of the public authority, appointed by the most senior public servant in the public authority, pursuant to rules 5 and 6 of the Disposal of Documents Order (NI) 1925. In the Northern Ireland Departments they are called either Departmental Information Managers (DIMs) or Departmental Record Officers (DROs). In local authorities and NDPBs, they are usually called Information Managers or Records Managers

The reason for signing the Disposal Schedule is to give legal authority to the disposal of records, and to ensure that responsibility for doing so is shared

3.9.10. As far as the order of signing is concerned, the disposal schedule should be signed first by PRONI’s Head of Records Management and Administration. It should then be signed in turn by PRONI’s Chief Executive, the Permanent Secretary of DCAL, the most senior public servant in the public authority (egs, Permanent Secretary of the Department of Health, Social Services & Public Safety, Chief Executive/Town Clerk of Belfast City Council, etc) and another senior officer in the public authority. At this point the schedule may also be signed by an appropriate professional officer in the public authority. The final signature should be that of the officer (Information/Records Manager) ‘specially conversant’ with the records of the public authority. It is recommended that three original copies of the disposal schedule

34 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

are signed by each of the signatories. At the end of the signing process, one copy should be given to PRONI, one copy should be held by the Information Manager of the public authority, and finally one copy should be given to the public authority’s Head of the Branch, business unit, etc., for implementation.

ROLE OF SIGNING

PRONI Head of Records Management & Administration

Public Authority PRONI Chief Information Executive Manager

Most Senior DCAL Permanent Officer in Public Secretary Authority

3.9.11. It is useful, not to mention courteous, to compile a list of those consulted (individuals, business units, etc) during the course of the disposal scheduling process. Such a list could take the form of an appendix to the schedule.

3.10. What happens after the disposal schedule is signed?

3.10.1. It is the responsibility of the Information/Records Manager to ensure that the Disposal Schedule is implemented fully (see para. 3.5 above). Once the Schedule is ‘up and running’, he/she should continue to meet regularly with LIMs to monitor its operation and to check that:

♦ disposal instructions are still appropriate in the light of experience (eg, it may be that files marked for review do not yield material of

35 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

long-term historical/research value, and can be marked for destruction in the revised Schedule)

♦ files/records no longer created are removed from the Schedule(s) after disposal action on them is complete

♦ newly-created record collections or file series are added to the Schedule(s)

♦ records which are noted on the Schedule(s) as needing retention are still in existence and can be located quickly and efficiently

3.10.2. It is particularly important to record on any revised disposal schedule(s) the transfer of functions from one public authority to another, eg, if a function(s) moves from one Northern Ireland Department to another or becomes the responsibility of a Non-Departmental Public Body/Executive Agency, etc, then relevant details (including the date on which the transfer of the function(s) becomes effective) should be recorded.

3.10.3. Changes to the disposal schedule(s) must be discussed and agreed with PRONI before the revised schedule(s) is signed and issued.

3.11. How long do you keep files/records about information audits and disposal schedules?

3.11.1. The National Archives (London) in its guidance publication, Retention Scheduling: 9. Information Management Records (version 1, September 2002), recommends the following:

Description of Record Disposal Instruction Information audits and record Destroy after 5 years surveys Correspondence and papers Destroy after 10 years relating to the compilation of disposal schedules Disposal Schedules Permanent Preservation

It is essential that disposal schedules are retained permanently by the public authority because enquirers for information under the FOI Act 2000 have the option of seeking evidence of when and why information has been disposed of.

3.12. How should the physical destruction of files/records be carried out?

3.12.1. National Archives (London) advises that the method of destruction of records will depend on their protective marking. Protectively marked

36 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

waste, before destruction, should be clearly identified and kept separate from other waste.23

3.12.2. Many public authorities in Northern Ireland will have their own procedures on the destruction of files/records.24 Where such procedures do not exist, the following methods are recommended by the National Archives (London) as minimum requirements25:

♦ non-sensitive files/records (no protective marking)

Ordinary rubbish bins should only be used for public domain material. Records which otherwise would not be made available to the public should be torn into small pieces and placed in a rubbish bag for collection by an approved disposal firm. ♦ Restricted

Waste should be strip-shredded and placed in paper rubbish sacks for collection by an approved disposal firm. ♦ Confidential

Waste should be crosscut-shredded and placed in paper rubbish sacks for collection by an approved disposal firm. The material should be pulped or burnt. ♦ Secret and Top Secret

Waste should be crosscut-shredded or disintegrated using a grille size no larger than 6mm and placed in paper rubbish sacks for collection by an approved disposal firm. The material should be burnt.

3.12.3. If you are in doubt about which protective marking should apply (or if any marking should apply) to any of the files/records to be destroyed, then you should consult with the Departmental Security Officer (in the case of the Northern Ireland Departments) or senior officer in the public authority with responsibility for security.

______23 See, ‘Records Management Standards: Disposal Scheduling’, RMS 5.1, (National Archives (Kew), 2000), p.9. Web reference: http://www.pro.gov.uk/recordsmanagement/standards/disposal-scheduling.pdf 24 See footnote 13. 25 See footnote 22.

37 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

4. The Backlog: APPRAISAL

4.1. Most, if not all public authorities, will possess a backlog of files/records which need to be appraised in a special ‘one-off’ exercise. It is important to attend to this material as soon as possible, and certainly before January 2005 (see para. 2.1 above). The type of files/records involved are:

♦ Unregistered files, folders, etc, whether held by individual staff members and/or by a Branch/business unit/Agency, etc. If a Registry exists and is workingproperly, it should not possess any unregistered files, folders, etc.

♦ Registered files/records that have missed either their 1st or 2nd review (see, NIRMS ‘Reviewing Procedures’: http://www.proni.gov.uk/NIRMS/NIRMS4.pdf

♦ Registered files/records which, because of their importance (eg, legal ‘precedent’ files) or their confidentiality (eg, medical case files), do not participate in the normal review process, but are overdue their ‘special’ review

♦ Registered files/records (current or semi-current) that will not feature in the new file plan/disposal schedule(s) created by the public authority

♦ Any combination of the above

Note:

If you are thinking of weeding or stripping files, please bear in mind that it is a very tedious task and is rarely cost effective. More importantly, as the Northern Ireland Records Management Standard warns, ‘misunderstanding of the procedure could give rise to public criticism’.

It must be applied with the utmost caution and only after consultation with PRONI.

4.2. The aim of the appraisal exercise is to determine the fate of the files/records that do not have a continuing administrative/legal value to the public authority, and that will not feature in any new or revised file plan or filing system established by the public authority.

38 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

5. Bibliography

Northern Ireland Records Management Standard (NIRMS), May 2002, compiled by the Public Record Office of Northern Ireland. This has been published on the PRONI website http://www.proni.gov.uk/NIRMS/NIRMS1.pdf under the heading Records Management.

Lord Chancellor’s Code of Practice on the Management of Records under section 46 of the Freedom of Information Act 2000, November 2002, presented to Parliament by the Lord Chancellor pursuant to section 46(6) of the Freedom of Information Act 2000. This has been published on the Lord Chancellor’s Department website: http://www.lcd.gov.uk/foi/codemanrec.htm

Records and Information Surveys, compiled by the National Archives (Kew), 1999. This has been published on the National Archives website: http://www.pro.gov.uk/recordsmanagement/standards/surveys.pdf

Records Management Standards: Tracking Records, RMS 2.1, compiled by the National Archives (Kew), 2000. This has been published on the National Archives website: http://www.pro.gov.uk/recordsmanagement/scoping/gsrmtra.pdf

Records Management Standards: File Creation, RMS 1.1, compiled by the National Archives (Kew), 2000. This has been published on the National Archives website: http://www.pro.gov.uk/recordsmanagement/scoping/gsrmscre.pdf

Records Management Standards: Disposal Scheduling, RMS 5.1, compiled by the National Archives (Kew), 2000. This has been published on the National Archives website: http://www.pro.gov.uk/recordsmanagement/standards/disposal-scheduling.pdf

Requirements for Electronic Records Management systems, October 2002, compiled by the National Archives (Kew). This has been published on the National Archives website: http://www.pro.gov.uk/recordsmanagement/default.htm under the heading Electronic Records.

Effective records management – Part 1: A management guide to the value of BS ISO 15489-1, 2002

39 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

Effective records management – Part 2: Practical implementation of BS ISO 15489-2, 2002

Ready Access to Essential Evidence: the Strategic Plan of the National Archives and Records Administration 1997-2007, Washington D.C., revised 2000.

40 Guidelines on Information Audits and Disposal Schedules for Northern Ireland Public Authorities

6. Note on Author

Dr David Lammey, BA (Hons), Phd

David Lammey has worked in the Public Record Office of Northern Ireland (PRONI)26 for 16 years and is responsible for advising public authorities on best practice in records management and for ensuring that records of historical value are selected and acquired, and that wider public access under Freedom of Information is supported. He is also Chairman of the Information Managers’ Forum in Northern Ireland.

______26 An Executive Agency within the Department of Culture, Arts and Leisure.

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