Creating a records management policy

Neil Maude

Neil joined the Arena Group in 2006 and has almost 20 years of experience in the electronic document management industry, working with both private and public sector customers. Neil sits on Arena’s board of directors and manages the delivery operations of Arena’s EDM business. His team spend their time developing software, implementing solutions for customers and providing after-sales software support services, both in the UK and internationally.

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The Information and Records Management Society (IRMS) curates a regularly updated “Records Management Toolkit” written specifically to assist UK public sector schools in their compliance with the Freedom of Information Act 2000. In a series of articles, Arena Group’s Neil Maude looks at the practical application of the principles described in this toolkit, using his 20+ years of experience in the provision of document management solutions within and outside of the education sector.

Is there really a need?

Before we get into the detail of records management and the practical elements of implementing a policy, there is a fairly obvious first question to ask. Most schools have been around for a while – some for a very long while – and already have processes in place to manage documents in line with legislation and sector best practice. So is there really a need to change?

We believe there are 3 compelling reasons for a school to take a good look at the way it manages records and information:

  1. Legislation – there’s plenty of it and it’s increasingly vigorous. Schools are subject to Freedom of Information and Data Protection rules, just like any other public organisation. In the event of a breach, the Information Commissioner’s Office (ICO) can, and sometimes does, impose fines or require organisations to sign undertakings to improve processes. Clearly it is better to be proactive and prepared.

  2. Retention requirements - The amount of information being retained is ever growing, increasingly time-consuming and expensive to deal with. As well as cost, this might lead to problems with storage – especially for schools in a new building with limited space to store paper files. Academies may be required to retain even more records - those previously held by the LEA - creating another new problem.

  3. Continued improvement - There is an expectation of continual improvement in every organisation. Record keeping should be no exception. With these points in mind, the IRMS toolkit becomes a very useful framework within which to revise or refresh your procedures.

What is a record?

The IRMS defines a record as “all those documents which facilitate the business carried out by the school and which are thereafter retained … to provide evidence of its transactions or activities. These records may be created or received, and then stored, in hard copy or electronically.”

This definition pretty much means that every item of data you create is a record – from formal typed documents to handwritten permission slips and every single e-mail. That’s a pretty daunting list. Clearly some records are more valuable than others and there are various pieces of legislation and guidance as to how long each record should be retained. All of which adds complexity.

Starting Point: Developing a formal records management policy

The IRMS toolkit recommends starting with a formal written records management policy or code of practice that sets out the scope, responsibilities and links to other existing policies.

This policy needs to be endorsed by senior management and readily available to staff at all levels. The document should provide a mandate for records and information management and a framework for supporting standards, procedures and guidelines.

The precise contents of the policy should, as a minimum:

  • Set out a commitment to create, keep and manage records which document the principal activities of the school

  • Outline the role of records management, identifying and making appropriate connections to related policies, such as those dealing with email, information security and data protection

  • Delegate roles and responsibilities for creating and using records appropriately

  • Indicate how compliance with the policy and the supporting standards, procedures and guidelines will be monitored.

  • Outline how the policy will be reviewed and updated. This should be done at regular intervals and following any significant changes that may affect records management.

The toolkit includes a template which needs only the school name to be inserted and the document is then signed as a formal record of the school’s commitment to its implementation.

This is a good starting point because it clearly demonstrates and allocates responsibility. With the legislative implications, it’s hardly surprising that the IRMS suggests that the one senior representative for the school (e.g. Head teacher) should take overall responsibility for implementing the policy. A second important point to note is that this person should also be responsible for providing guidance and promoting good practice. This is a little more contentious, as there is a time implication so it may be that this task is delegated and then audited.

Homework

Once this high level policy is in place, the next step is an information audit that looks at the information being held by the school. A sensible starting point for your information audit is to think about the types of information you hold, it may fall into categories, like these:

  1. Current pupil records

  2. Former pupil records

  3. Finance records

  4. Human resources/staff records

Considerations:

  • Your classifications may be unique to your school, and you may be storing more or less information within each category. For example, an academy may have buildings and facilities management records to hold and these could be considered either a subset of Finance or an entirely separate category.

  • Each category will have its own set of retention rules, governing how long each type of document should be stored.

  • Each category should consider security – who needs to see particular information and who should not. This is a big topic and will be considered in a separate article.

A proper classification of information, with defined security and disposal timelines, introduces a number of rules-based ‘housekeeping’ tasks and there are various ways in which you can handle these. An electronic document management system (EDMS) can easily automate the process and is well worth consideration. Retrieval of documents on a computer can take a matter of seconds, improving speed of access and responsiveness to enquiries and requests for information. Also, documents stored within a suitable EDMS (compliant with BSi standards for legal admissibility of electronic documents) will allow the original paper to be destroyed – removing the need for large physical filing areas, better protecting your records and releasing physical space for other uses.

For these reasons, the IRMS toolkit can be viewed not only as a best practice guide for records management, but a route forward to electronic record keeping.

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