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The Public Records () Act 2011

Food Standards Scotland

Progress Update Review (PUR) Report by the PRSA Assessment Team

4th June 2021

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Contents

1. The Public Records (Scotland) Act 2011………………………………………... 3 2. Progress Update Review (PUR) Mechanism…………………………………… 3 3. Executive Summary……………………………………………………………….. 3 4. Authority Background……………………………………………………………… 4 5. Assessment Process……………………………………………………………… 4 6. Records Management Plan Elements Checklist and PUR Assessment…….. 5 7. The Public Records (Scotland) Act Assessment Team’s Summary…………. 11 8. The Public Records (Scotland) Act Assessment Team’s Evaluation………… 11

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1. Public Records (Scotland) Act 2011

The Public Records (Scotland) Act 2011 (the Act) received Royal Assent on 20 April 2011. It is the first new public records legislation in Scotland since 1937 and came into force on 1 January 2013. Its primary aim is to promote efficient and accountable record keeping by named Scottish public authorities.

The Act has its origins in The Historical Abuse Systemic Review: Residential Schools and Children’s Homes in Scotland 1950-1995 (The Shaw Report) published in 2007. The Shaw Report recorded how its investigations were hampered by poor recordkeeping and found that thousands of records had been created, but were then lost due to an inadequate legislative framework and poor records management. Crucially, it demonstrated how former residents of children’s homes were denied access to information about their formative years. The Shaw Report demonstrated that management of records in all formats (paper and electronic) is not just a bureaucratic process, but central to good governance and should not be ignored. A follow-up review of public records legislation by the Keeper of the Records of Scotland (the Keeper) found further evidence of poor records management across the public sector. This resulted in the passage of the Act by the in March 2011.

The Act requires a named authority to prepare and implement a records management plan (RMP) which must set out proper arrangements for the management of its records. A plan must clearly describe the way the authority cares for the records that it creates, in any format, whilst carrying out its business activities. The RMP must be agreed with the Keeper and regularly reviewed.

2. Progress Update Review (PUR) Mechanism

Under section 5(1) & (2) of the Act the Keeper may only require a review of an authority’s agreed RMP to be undertaken not earlier than five years after the date on which the authority’s RMP was last agreed. Regardless of whether an authority has successfully achieved its goals identified in its RMP or continues to work towards them, the minimum period of five years before the Keeper can require a review of a RMP does not allow for continuous progress to be captured and recognised.

The success of the Act to date is attributable to a large degree to meaningful communication between the Keeper, the Assessment Team, and named public authorities. Consultation with Key Contacts has highlighted the desirability of a mechanism to facilitate regular, constructive dialogue between stakeholders and the Assessment Team. Many authorities have themselves recognised that such regular communication is necessary to keep their agreed plans up to date following inevitable organisational change. Following meetings between authorities and the Assessment Team, a reporting mechanism through which progress and local initiatives can be acknowledged and reviewed by the Assessment Team was proposed. Key Contacts have expressed the hope that through submission of regular updates, the momentum generated by the Act can continue to be sustained at all levels within authorities.

The PUR self-assessment review mechanism was developed in collaboration with stakeholders and was formally announced in the Keeper’s Annual Report published on 12 August 2016. The completion of the PUR process enables authorities to be credited for the progress they are effecting and to receive constructive advice concerning on-going developments. Engaging with this mechanism will not only maintain the spirit of the Act by encouraging senior management to recognise the need for good records management practices, but will also help authorities comply with their statutory obligation under section 5(1)(a) of the Act to keep their RMP under review.

3. Executive Summary

This Report sets out the findings of the Public Records (Scotland) Act 2011 (the Act) Assessment Team’s consideration of the Progress Update template submitted for Food Standards Scotland. The outcome of the assessment and relevant feedback can be found under sections 6 – 8.

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4. Authority Background

Food Standards Scotland’s primary responsibility is to ensure that information and advice on and standards, nutrition and labelling is independent, consistent, evidence-based and consumer- focused. Its primary concern is consumer protection – making sure that food is safe to eat and ensuring consumers know what they are eating and improving nutrition. With that in mind, their vision is to deliver a food and drink environment in Scotland that benefits, protects and is trusted by consumers.

FSS develops policies, provides policy advice to others, is a trusted source of advice for consumers and protects consumers through delivery of a robust regulatory and enforcement strategy.

FSS was established by the Food (Scotland) Act 2015 as a non-ministerial office, part of the Scottish Administration, alongside, but separate from, the . It is mainly funded by government but also charges fees to recover costs for regulatory functions.

5. Assessment Process

A PUR submission is evaluated by the Act’s Assessment Team. The self-assessment process invites authorities to complete a template and send it to the Assessment Team one year after the date of agreement of its RMP and every year thereafter. The self-assessment template highlights where an authority’s plan achieved agreement on an improvement basis and invites updates under those ‘Amber’ elements. However, it also provides an opportunity for authorities not simply to report on progress against improvements, but to comment on any new initiatives, highlight innovations, or record changes to existing arrangements under those elements that had attracted an initial ‘Green’ score in their original RMP submission.

The assessment report considers statements made by an authority under the elements of its agreed Plan that included improvement models. It reflects any changes and/or progress made towards achieving full compliance in those areas where agreement under improvement was made in the Keeper’s Assessment Report of their RMP. The PUR assessment report also considers statements of further progress made in elements already compliant under the Act.

Engagement with the PUR mechanism for assessment cannot alter the Keeper’s Assessment Report of an authority’s agreed RMP or any RAG assessment within it. Instead the PUR Final Report records the Assessment Team’s evaluation of the submission and its opinion on the progress being made by the authority since agreeing its RMP. The team’s assessment provides an informal indication of what marking an authority could expect should it submit a revised RMP to the Keeper under the Act, although such assessment is made without prejudice to the Keeper’s right to adopt a different marking at that stage.

Key:

The Assessment The Assessment Team agrees There is a serious gap in Team agrees this this element of an authority’s provision for this element with element of an progress update submission as no clear explanation of how G authority’s plan. A an ‘improvement model’. This R this will be addressed. The means that they are convinced of Assessment Team may the authority’s commitment to choose to notify the Keeper on closing a gap in provision. They this basis. will request that they are updated as work on this element progresses.

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6. Progress Update Review (PUR) Template: Food Standards Scotland

Element Status Progress Progress Keeper’s Self-assessment Update Progress Review Self-assessment Update as Progress Review under status status Report 20APR20 Comment submitted by the Authority since Comment agreed 14MAY20 04JUN21 Comments on 14MAY20 30APR2021 04JUN21 Plan Authority’s 25JAN18 Plan 25JAN18

G G G Update required Change to Personnel. Ian McWatt is now The Keeper of the Records of Change in SIRO’s Title: Ian McWatt The Keeper’s Assessment 1. Senior Officer on any change. FSS New Deputy Chief Executive & Scotland’s PRSA Assessment is now Director of Policy and Team thanks you for this Director of Policy, Science and Team thanks Food Standards Delivery at FSS update which has been Operations. He is FSS’ SIRO Scotland for this update which noted. has been noted. G G G Update required No change to personnel. The Assessment Team note the No Change to personnel. However The Team thanks you for 2. Records on any change. Job regraded with a new title - change of job title. Thank you for with the doubling of the staff count in this update on recruiting Manager Information and Records Manager. this update. the past 18 months, a new Records additional staff to support Management Support Officer is the information and currently being recruited to support records manager in their the Information and Records work. Manager.

G G G Update required No change - Document reviewed and In their original submission Food No change – Records Management Thank you for letting us 3. Policy on any change. updated during annual policy review Standards Scotland committed Policy including procedural know there have been no process. to updating relevant policy documents are being reviewed major updates to this documents on a regular basis. annually. We are also planning on a element. The plans for a As before, the Assessment deep-dive review of our policies, thorough policy review in Team appreciates the confirmation that this is being procedures and template when the additional to the regular done. new Records Management Support annual review are noted Officer is in post to align with any and commended. new/updated SCARR guidance.

G G G Update required No change – FSS Information Assets are FSS make their record structure No change – FSS Information Thank you for letting the 4. Business on any change. monitored and annually reviewed on the publically available at Assets are monitored and annually Assessment Team know Classification Scottish Government Information Assets https://www.foodstandards.gov.s reviewed on the Scottish that the FSS information Register. The list of the assets is cot/publications-and- Government Information Assets assets continue to be published and updated annually on our research/open-data-portal/fss- Register. The list of the assets was monitored and follow the Open Data Portal information-assets-register This is to be commended. reviewed following an Open Data annual review schedule of Internal Audit and published on our SG IAR. We are also In 2018 the Keeper agreed that Open Data Portal. We also now grateful for the link to the FSS had a BCS (or equivalent) have a Data Inventory in eRDM but Open Data portal as well which identified its functions and is not published because it contains as the notification of a the records created in carrying personal and sensitive data. Data Inventory on eRDM. these out. There is nothing here It is clear that FSS to suggest that this has changed continues to recognise the and, in fact, it can be importance of a robust acknowledged that their business classification structure undergoes routine review to ensure that all public framework. records are known and are identified within a structure, as expected by the Keeper.

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G G G Update required No change – FSS retention schedules The Assessment Team thanks No change – FSS retention Thank you for letting us 5. Retention on any change. are reviewed and updated annually. FSS for reconfirming that their schedules are reviewed and updated know that there have Schedule retention schedules reviewed annually. We are also following new been no changes to FSS and update annually. Scottish Government (SG) updated retention schedule disposal schedule guidance for files arrangements, and that Again there is a clear indication that the authority recognises that which have an action of archive less any changes a retention schedule is a living than 15 years after closure following necessitating a change in document liable to regular discussion between SG and NRS. approach are actioned adjustments in line with FSS The change has been automated on swiftly. The Assessment business needs. eRDM. Team is confident that FSS continues to take its responsibilities with regard to this element seriously.

G G G Update required We are still using Ecocleen for our The Assessment Team thanks No change to destruction The Assessment Team 6. Destruction on any change. confidential paper disposal but they are FSS for this update regarding arrangements. However, with the thanks FSS for this Arrangements now trading as ‘Tidy Green Clean’ the change in the trading name new way of working where all our update on how home- of their confidential waste office based staff are now working working has impacted All IT hardware disposal is either done by supplier. This makes no from home, paper shredders have destruction arrangements Scottish Government iTECS team or on difference to the Keeper’s their instruction using SG IT/SCOTS original agreement that the been procured and delivered to key and how it has been guidance records destruction procedures staff who have a business addressed. We are in the authority are appropriate. requirement to print out documents. confident that the FSS The purchase of the paper has a good handle on this shredders is to ensure the secure element. disposal of sensitive documents when no longer required.

G G G Update required No Change. In their original submission No change, web harvesting with Thank you for notifying us 7. Archiving and on any change. Continuous preservation of FSS Website (2018) FSS identified the NRS has been excellent. FSS’s that there has been no Transfer by National Records of Scotland. National Records of Scotland as electronic records on eRDM will be change to this element. Discussion will be held with NRS and SG a suitable repository for the archived at NRS along with other SG We are very pleased to Corporate Records team on the best preservation of the public records. hear that the web option available for archiving FSS records selected for permanent records that are held on SG eRDM retention. There is an agreement harvesting and electronic system. (in the form of an MoU) to record arrangements with enable the transfer of such the National Records of records. Scotland are working well.

The Assessment Team thanks FSS for confirmation that they are also working with NRS regarding web-harvesting.

Archiving digital records is in its infancy in the Scottish public sector. It is commendable that FSS is already addressing this with their archive provider.

G G G Update required No change – FSS information security In their original submission Food No change – FSS information The Assessment Team is 8. Information on any change. policies and procedures are reviewed Standards Scotland committed security policies and procedures are grateful for this update on Security and updated annually. to updating relevant policy reviewed and updated annually. FSS security policies and documents on a regular basis. procedures. The new All Information Assets Owners in FSS The Assessment Team FSS are in discussion with SG focus om implementing regularly monitor and manage the assets appreciates the confirmation that Digital Transformation Services changes in order to meet

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within their respective business areas. this is being done. (DTS) on getting an ISO27001 the ISO27001 standard is An annual report is then submitted to our expert to help FSS implement the particularly welcome SIRO. Evidence 77 : Annual IAOs report The Keeper would commend ISO27001 information security news, as this shows to SIRO Communication local business area involvement controls across all FSS business continuous commitment to in the records management areas. The gap analysis and improvement. A Records Management Maturity Model provision in an authority. There procedure benchmarked against PRSA is ample evidence in this PUR statement of applicability are standards was developed to ensure the that that is standard practice in completed. A paper was sent to, and The Assessment Team is confidentiality, integrity, and availability FSS through their Information approved by FSS SIRO to contented that the FSS is of all information assets across the Asset Owner structure. implement ISO 27001 controls in taking steps in the right organisation. A report is generated and FSS. direction in order to sent to our SIRO for review and approval The Assessment Team maintain their Green RAG of any recommendations identified in the acknowledge the receipt of All information assets have been status. IAO submissions, and to further facilitate evidence. monitored, reviewed and updated the implementation of our RMP. throughout the reporting year. New The Assessment Team thanks information assets were identified We will be exploring ISO27001 FSS for the update regarding accreditation in the 2020/21 reporting ISO27001. They look forward to and registered as an outcome of the year by doing a gap analysis and a further update on this in Data Inventory exercise. producing a Statement of Applicability subsequent PURs. (SoA). Regular cybersecurity updates are For records management provided to all FSS staff as part of maturity model, see under the Chief Executive Weekly news element 13 below. update to remind all FSS staff of the threats and vulnerabilities out there and the need for all FSS staff to remain vigilant especially while working from home.

G G G Update required No change – FSS data protection The Assessment Team thanks No change in this area but increase Thank you for updating us 9. Data on any change. policies and procedures are reviewed FSS for this update. awareness across the business on on FSS’s continuing good Protection and updated annually. The new technological solution, our collective responsibility for the practice in terms of its making FSS data protection handling of information including approach to Data A 6 monthly data protection report is provision more robust, has been personal data. Protection. produced and discussed at our senior noted. This is an interesting management team meeting. expansion of the functionality of O365 which will be of interest to A data protection check list was The privacy statement, We now have a Stakeholder the many other public authorities produced to ensure that privacy accessible on the FSS Engagement Management System built already using this suite of tools. consideration is central to the website, is also noted with on Microsoft Dynamic 365 platform. The introduction of new projects or thanks. SEMS system ensures that we comply Again there is evidence here services in FSS. with the principles of GDPR/DPA 2018, that policies and procedures in in particular, Accuracy, Storage the authority are appropriately We have further revamped our Limitation, and Integrity and updated. privacy section of the website to Confidentiality of all personal data in our comply with our obligations for organisation. documentation, accountability in the processing of personal data under the UK GDPR and DPA 2018. Privacy | Food Standards Scotland

G G G Update required FSS continues to operate a Business The submission of the FSS PUR No significant change. Thank you for informing 10. Business on any change. Continuity Plan (BCP) that is periodically coincided with the actual us that there has been no Continuity and reviewed and kept up to date. implementation of their business FSS continues to operate a significant changes to this Vital Records continuity arrangements due to Business Continuity Plan (BCP) that element. The adjustments The current Coronavirus pandemic the Covid19 crisis. The Keeper is periodically reviewed and kept up made during the ongoing tested our procedures and systems for will be pleased to learn that in prompt communication and continuation FSS the switch to working from to date. The following changes were COVID-19 pandemic are of both crises related critical work home went smoothly. made to the BCP noted with thanks. It is clear that the FSS has

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streams, and other essential core Some of Changes added to the BCP made the necessary activities. Again there is evidence here during the COVID-19 outbreak are: changes to their Business Our systems and communication that policies and procedures in  Updated data and process on Continuity Plan to adjust channels coped extremely well and the authority are appropriately maintenance of GroupCall in the altered situation facilitated a steady working from home updated. system while maintaining arrangement, and a robust crises and resilience management.  Section included on Risk business resilience. Assessments relating to incident and any associated action tracking  Updated Hyperlinks throughout Included and Adapted Roles and Responsibilities in line with FSS Incident Management Framework  Inclusion of Business Continuity Classification Matrix  Change of Appendix 1 – ‘Business Critical Activities’ to include contingency plans and required equipment  Restructure of sections to signify Business Continuity Event and the potential steps/experiences/work scopes contained within  Addition of Section ‘20 COVID Addendum’ in line with SG Guidance on update of BCP  Sections added on Concurrent Events, Working From Home, Internal Communications, Briefing Cell, Business Recovery Timescales and Human Resource Factors

G G G Update required No change. No action required. Update No change. Thank you for indicating 11. Audit Trail on any change. eRDM and SharePoint are the corporate required on any change. eRDM and SharePoint are the there have been no major records repositories that we use in our corporate records repositories that changes to audit trail organisation. They both have appropriate we use in our organisation. information arrangements, audit mechanism to support Freedom of and that FSS continues to Information requests and any other legal or regulatory compliance requests. Important reports generated from our recognise the importance bespoke applications and presented of complete an accurate to management or Ministers, are representation of all saved to either eRDM or SharePoint changes that occur in as part of our internal process of relation to a particular capturing corporate records of record. enduring value.

G G G Update required The Information and Records Manager is In 2018 the Keeper agreed that The Information and Records Thank you for the update 12. Competency on any change. a member of the Information and Food Standards Scotland had Manager continues to be a member on the information and Framework Records Management Society (IRMS) appropriately resourced of the Information and Records records manager’s and member of the International information governance training Management Society (IRMS) and continuing professional Association of Privacy Professionals for their staff particularly the member of the International engagement and (IAPP). individual identified at element 2. Association of Privacy Professionals development, including

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The Information and Records Manager There is ample evidence in the (CAPP). information security takes advantage of these networks to previous PUR and now again in certification and identify and attend courses, webinars, this submission that this The information and Records memberships of CAPP conferences, to learn and share best resource remains available and Manager introduced a Ways of and IRMS. This is all very practices with peers. that the authority takes this vital Working (WoW ) series, organising reassuring and shows that aspect of records management The Records Manager provides regular provision seriously. drop in sessions on different topics FSS is committed to updates and refresher training to FSS within the Knowledge and supporting the staff on key elements of the RMP. The Assessment Team Information Management (KIM) development of their key acknowledges receipt of recently subject areas. information governance Evidence: E78: Knowledge and produced staff guidance staff. In addition, the Information InfoMap documents as evidence that The Information and Records supply of mandatory training is continually reviewed manager completed the Certified training on data protection Evidence: E79: Data Protection and enhanced. Information Security Manager and information Compliance- Staff Update training in this reporting year. management for all staff The Assessment Team notes shows commitment to this The Records Manager will undertake the the professional memberships of Certified Information Security Manager the Information and Records All FSS staff and contractors element throughout the course in 2020/21 reporting year to Manager and that he will be complete the mandatory training on organisation. acquire further information security undertaking supplementary data protection (Scottish management skills. information security training in Government e-learning) and the next year. This is managing information (Civil Service Our Information Assets Owners will commended both in itself and as Learning). This is monitored closely receive their annual information assets evidence that the authority with a report sent to SIRO. training when we return to normal supports the development of key working arrangements. information governance staff.

All FSS staff and contractors complete the mandatory training on data protection (Scottish Government e-learning) and managing information (Civil Service Learning).

G G G Update required No change. The Act requires all public No change. Thank you for letting us 13. Assessment on any change. authorities to keep their plan know there have been no and Review However, there is a strong commitment under review. There is strong The information and Records major changes to this to annual review of our RMP, Records evidence that Food Standards Manager now sits on FSS Data and element. It is reassuring Management Policy, and other Scotland properly does this. Digital Forum providing expert to see that the FFS Knowledge and Information Management (KIM) policies and procedures, as a FSS have developed a Maturity advice on records management, continues to keep up with standard objective of the Information and Model which was shared with information security and data their robust assessment Records Manager. the Keeper in 2019. This is protection. and review processes. The Information and Records Manager highly commended and has, now meets monthly with the SIRO, to with FSS permission, been However, there is a strong update the SIRO on any information published by the Keeper as an commitment to annual review of our security concerns or issues in the example of best practice in this RMP, Records Management Policy, organisation and to highlight/promote area. and other Knowledge and best practices. Reporting to the DPO is Information Management (KIM) by exception but the DPO is always kept A specific use of the Maturity policies and procedures, as a up-to-date where an information security Model within FSS is discussed incident is under investigation or his under element 8 above. standard objective of the Information advice or approval is required. and Records Manager. The Assessment Team thanks Any information security or privacy FSS for the update regarding concerns in the organisation is further reporting in the organisation. It is discussed at Senior Management Team clear that there is a direct meeting, Corporate Leadership Group method to bring information meeting and at all staff meeting. If and governance issues to the where necessary or appropriate, it can attention of senior management. be escalated to the Board Again this is commendable.

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In short, this element is a particular highlight of what is already a very strong plan.

G G G Update required eRDM Connect is officially the default In 2018 the Keeper agreed that There has been significant The Assessment Team 14. Shared on any change. corporate tool to share information and FSS had appropriate safeguards improvement in this element in this thanks FFS for this Information collaborate on documents with in place to ensure the controlled reporting year. More business areas update. It is positive to stakeholders and key delivery partners sharing of information with third now use eRDM Connect to share hear that significant steps up to Official-Sensitive. parties. There is nothing here to and collaborate on documents with have been taken with suggest that this has changed. We have tightened our information external stakeholders and key regard to element 14, and sharing procedure further by ensuring The Keeper acknowledges that delivery partners. continue to be taken to that we have appropriate use of Objective Connect as a improve the shared data/information sharing agreements in data sharing tool. He already There has also been an increase in information procedures place before sensitive data is shared with endorses this product by using it the drafting and approval of data and policies. external stakeholders including other for data sharing by NRS. sharing agreement with key delivery public sector organisations, with partners in this reporting year. exception where the Law allows emergency sharing of data across the public sector E.g., in the detection and prevention of crime.

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7. The Public Records (Scotland) Act Assessment Team’s Summary

Version

The progress update submission which has been assessed is the one received by the Assessment Team on 30 April 2021. The progress update was submitted by Tigan Daspan, Information and Records Manager.

The progress update submission makes it clear that it is a submission for Food Standards Scotland.

The Assessment Team has reviewed Food Standards Scotland’s Progress Update submission and agrees that the proper record management arrangements outlined by the various elements in the authority’s plan continue to be properly considered. The Assessment Team commends this authority’s efforts to keep its Records Management Plan under review.

General Comments

Food Standards Scotland continues to take its records management obligations seriously and is working to maintain all elements in full compliance.

Section 5(2) of the Public Records (Scotland) Act 2011 provides the Keeper of the Records of Scotland (the Keeper) with authority to revisit an agreed plan only after five years has elapsed since the date of agreement. Section 5(6) allows authorities to revise their agreed plan at any time and resubmit this for the Keeper’s agreement. The Act does not require authorities to provide regular updates against progress. The Keeper, however, encourages such updates.

The Keeper cannot change the status of elements formally agreed under a voluntary submission, but he can use such submissions to indicate how he might now regard this status should the authority choose to resubmit its plan under section (5)(6) of the Act.

8. The Public Records (Scotland) Act Assessment Team’s Evaluation

Based on the progress update assessment the Assessment Team considers that Food Standards Scotland continue to take their statutory obligations seriously and are working hard to maintain all the elements of their records management arrangements in full compliance with the Act and fulfil the Keeper’s expectations.

The Assessment Team recommends authorities consider publishing PUR assessment reports on their websites as an example of continued good practice both within individual authorities and across the sector.

This report follows the Public Records (Scotland) Act Assessment Team’s review carried out by

Iida Saarinen Public Records Support Officer

A33542276 - NRS - Public Records (Scotland) Act (PRSA) - Food Standards Scotland - Progress Update Review (PUR) - 2021 PUR Final Report