GGGUUUIIIDDDEEELLLIIINNNEEESSS ooonnn IIINNNFFFOOORRRMMMAAATTTIIIOOONNN AAAUUUDDDIIITTTSSS aaannnddd DDDIIISSSPPPOOOSSSAAALLL SSSCCCHHHEEEDDDUUULLLEEESSS fffooorrr NNNOOORRRTTTHHHEEERRRNNN IIIRRREEELLLAAANNNDDD PPPUUUBBBLLLIIICCC AAAUUUTTTHHHOOORRRIIITTTIIIEEESSS 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