Document Management Policy

Document Management Policy

Adopted by Council: 31st March 2020

Review Date: February 2021

Scope and Purpose

The purpose of this policy is to provide a corporate policy framework to govern management decisions on whether a particular document (or set of documents) should either be:

  • Retained – and if so in what format, and for what period; or
  • Disposed of – and if so when and by what method

Additionally, this policy seeks to clarify the roles and responsibilities in the decision-making process.

This policy is not concerned with the disposal/retention of unused materials (e.g. stocks of paper, unused forms, duplicated documents).

Introduction

In the course of carrying out its various functions and activities, the Council collects information from individuals and external organisations and generates a wide range of data/information both electronically and in hard copy.

Retention of specific documents may be necessary to:-

  • Fulfil statutory or other regulatory requirements
  • Evidence events/agreements in the case of disputes
  • Meet operational needs
  • Ensure the preservation of documents of historic or other value

The untimely destruction of documents could cause the Council:-

  • Difficulty in defending litigious claims
  • Operational problems
  • Embarrassment
  • Failure to comply with the Freedom of Information or Data Protection Acts
  • A breach of a particular piece of legislation.

Conversely, the permanent retention of all documents is undesirable, and appropriate disposal is to be encouraged for the following reasons:-

  • There is a shortage of new storage space
  • Disposal of existing documents can free up space for more productive activities, even in digital form
  • Indefinite retention of personal data may be unlawful
  • Reduction of fire risk (in case of paper records)
  • There is evidence that the de-cluttering of office accommodation can be psychologically beneficial for many workers

Modern day records management philosophy emphasises the importance of organisations having in place systems for the timely and secure disposal of documents/records that are no longer required for business purposes. Additionally, both the Freedom of Information Act and new data protection legislation make it important for the Council to have clearly defined policies and procedures in place for disposing of records, and that these are well documented.

Document Handling

The Council will keep paper records to the absolute minimum and where ever possible hard copy information will be scanned and circulated by email. The email will be retained in line with policy and the hard copy recycled or shredded depending on its nature and level of confidentiality.

Documents will be filed in either cabinets (hard copy) or on Sharepoint (digital). Where documents in either form contain confidential, personal or sensitive information, they will be stored securely with authorised access only on a “need” basis.

The Council’s electronic records are backed up according to the Digital and ICT Policy. 

The Retention / Disposal Protocol

Any decision whether to retain or dispose of a document should be taken in accordance with the following criteria:

  • Has the document been appraised?
  • Is retention required to fulfil statutory or other regulatory requirements?
  • Is retention required to evidence events in the case of dispute?
  • Is retention required to meet the operational needs of the Council?

Where a retention period has expired in relation to a particular document a review should always be carried out before a final decision is made to dispose of that document. Such reviews need not necessarily be detailed or time consuming. Where the Managing Officer is familiar with the contents of the document or where the contents are straightforward and easily apparent then such an exercise may only take a few minutes.

In the event that a decision is taken to dispose of a particular document or set of documents, then consideration should be given to the method of disposal.

Roles and Responsibilities

Responsibility for determining (in accordance with the Retention/Disposal protocol mentioned above) whether to retain or dispose of specific documents rests with the Town Clerk, in respect of those documents that properly fall within the remit or control of his/her responsibilities. The rationale for this is that it is reasonable to both assume and expect that the Town Clerk should be broadly conversant with the types of documents received, generated and stored.

Managing officers are expected to make the decisions for disposing of routine documents and junk mail within their remit. With non-routine documents they should recommend a course of action and seek approval from the Town Clerk. Similarly, individual officers are expected to cull their emails of unwanted documents, particularly those containing personal information.

Because of the clear benefits resulting from the disposal of unnecessary documentation, the Town Clerk is expected to be proactive in carrying out or instigating audits of existing documentation that may be suitable for disposal.

Councillors are also encouraged to properly dispose of unnecessary council related documentation and emails.

Data Protection Act 2018 and General Data Protection Regulations

Managing Officers are aware that under the data protection regulations, personal data processed for any purpose must not be kept for longer than is necessary for that purpose. In other words, retaining documents or records that contain personal data beyond the length of time necessary for the purpose for which that data was obtained is unlawful.

Disposal

Disposal can be achieved by a range of processes:-

  • Confidential waste – i.e. making available for collection by a designated refuse collection service.
  • Physical destruction on site (paper records – shredding)
  • Deletion – where digital files are concerned. Deleted records must also be cleared
  • Migration of document to external body

Managing Officers should take in to account the following considerations when selecting any method of disposal:-

  • Under no circumstances should paper documents containing personal data or confidential information be simply binned or deposited in refuse tips. To do so could result in the unauthorised disclosure of such information to third parties, and render the Council liable to prosecution or other enforcement action under the Data Protection Act. Such documents should be destroyed on site (e.g. by shredding) or placed in the specially marked “Confidential Waste” refuse bins for collection by a designated contractor.
  • Deletion – the Information Commissioner has advised that if steps are taken to make data virtually impossible to retrieve, then this will be regarded as equivalent to deletion.
  • Migration of documents to a third party (other than for destruction or recycling) is unlikely to be an option in most cases. However, this method of disposal will be relevant where documents or records are of historic interest and/or have intrinsic value. The third party here could well be the Cheshire Record Office. “Migration” can, of course, include the sale of documents to a third party.
  • Recycling – wherever practicable disposal should further recycling, in-line with the Council’s commitment to sustainable development and promoting an alternative waste disposal strategy.

Disposal of all but routine documents should be documented by keeping a record of the document disposed of, the date and method of disposal, and the officer who authorised disposal. The documenting of disposal will be particularly important to ensure compliance with the Freedom of Information Act.

Monitoring

Member Audits will take place to periodically monitor compliance with this Policy.

Photographs and Digital Images

This policy is applicable to all forms of visual media, including film, print, video, DVD and websites.

The Town Council use images and videos for a variety of purposes, publicity, records of events, training purposes, security, crime prevention and the website. Whilst we recognise the benefits of photography and videos to our work and the community, we also understand that these can have significant risks for those involved. Under the legal obligations of the Data Protection Act and GDPR, the council has specific responsibilities in terms of how photos and videos are taken, stored and retained.

For the purpose of this policy we consider photographs and digital images as documents and have included a retention guide below.

Democracy
Document Minimum Period of Retention Reason
Record of disposal records Destroy after 12 years Common practice
Approved Minutes

Council and Committee/Sub-Committee

Permanent archive after administrative use Copy available on website Public Inspection/Scrutiny
Notices and Agendas

Council/Committee meetings

Destroy 1 year after year end Local decision
Council/Committee meetings

Reports and other documents

Electronic archive after administrative use Local decision
Working party agendas, reports Destroy after 5 years Local decision
Minute taking notes Destroy after minutes approved Local decision
Record of Officer decisions under

delegated authority and background documents

Destroy after 6 years Statutory (2014

Regulations)

Scales of Fees and Charges 5 years Management
Elections

Register and associated lists

Destroy after 4 years Local choice
Lists of candidates Destroy after 4 years Local choice
Election results Permanent Local choice

Permanent record with Cheshire East

Member contact and other details Personal Details-review regularly and delete if retention can no longer be justified

 

Other details – generally destroy when no longer a member of Council, except if ongoing issue, then destroy.

Data Protection

 

 

Common practice and Data Protection

Representation – list of members representing the Council on outside bodies 4 years Local choice

 

Finance
Document Minimum Period of Retention Reason
Receipt and payment(s) accounts 6 years VAT
Receipt books of all kinds 6 years VAT
Bank statements, including deposit/savings accounts Last completed audit year Audit
Bank paying-in books/records Last completed audit year Audit
Cheque book stubs Last completed audit year Audit
Agreements between organisations and partners Destroy 6 years after expiry Common practice
Quotations and tenders

Successful

12 years Limitation Act
Quotations and tenders

Unsuccessful

Destroy after 3 years Challenge
Contracts and Tendering

All documents

Destroy 6 years after last action except contract under seal (12 years) Part Limitations Act
Correspondence and papers on

important local issues or activities

Destroy 5 years after last activity or archive. Local choice
Building contracts Life of building + 15 years Statutory
Licensing or lease Agreements.

Rental/ Hire Purchase Agreements

Indefinite

Archive after end date

Limitations Act
Paid invoices 6 years VAT
Paid cheques 6 years Limitation Act
VAT records 6 years VAT
PAYE returns and supporting documents

 

PAYE related records not needed by Inland Revenue

6 years

 

 

3 years after end of tax year

Income Tax

 

 

Local choice

Budget and estimates

 

Working papers

Permanent archive after 3 years

 

2 years

Statutory

 

Local choice

Accounts and Audits

 

 

Associated documents

Permanent archive after administrative use concluded.

 

Destroy after administrative use

Common practice

 

 

Postage and telephone records 6 years Tax, VAT and Limitation Act
Timesheets Last completed audit year Audit
Salaries and wages documents, Inland Revenues (tax and NI) 12 years Superannuation

Limitation Period

Record of Members allowances 6 years Income Tax, Limitation Act
Insurance policies

Claims

While valid & permanent archive

Destroy after 7 years

Management

 

Insurance certificates/Employers’ Liability Certificates Indefinite, archive after 5 years. Management
Investments Indefinite, archive 5 years after ended Audit, Management
Loans Permanent archive after 2 years Common practice
Annual Return to external auditor Destroy after 6 years Audit
Internal and external audit reports Destroy after 6 years Audit
Grants and donations made

 

Destroy after 6 years

Where personal data included, destroy once no longer needed unless written permission to retain

Audit and VAT

 

 

Personnel Records
Document Minimum Period of Retention Reason
Personnel administration Destroy 5 years after person leaves Authority (except staff working with children-25 years) Local choice &

statutory

Recruitment and interview documents 1 Year for most documents

 

Equality monitoring forms, immediately person not appointed

Equal opportunities

claims

Volunteers e.g. marshalls for events, work experience

 

Destroy I year after volunteering completed, unless written permission to retain for future volunteering Local choice

Data Protection

Employers Liability Certificates Retain for 40 years Common Practice
Equality documents, Destroy 15 years after last action Common practice
Records with Personal or sensitive information Review regularly. Destroy when no longer

needed or cannot be justified for one of

specified reasons

Data Protection
Health and Safety Destroy 15 years after last action or after

6 years if superseded

40 years for asbestos & other occupational

health records

Statutory and Common practice

 

Administration
Document Minimum Period of Retention Reason
Title deeds, leases, agreements, contracts Indefinite, archive after 5 years Audit, Management
Maps, plans and surveys of property owned by Council Indefinite. Archive after 5 years. Common Practice
Planning lists, plans and observations Destroy after 1 year. Local choice
Statutory Development Plans

 

Observations

Destroy 5 years after expiry or when draft is superseded do the same Local choice
Consultations on statutory functions e.g. Licensing, Highways Destroy after 1 year Local choice
Corporate plans, Strategies, policies

Business plans, annual reports, Asset register

Permanent archive after superseded Common practice
Routine correspondence, papers and emails Destroy when not current or no longer needed for operations.

Where contains personal information, destroy as soon as matter resolved

Local choice and Data Protection
Complainants and enquirers about the council’s own services, and enquiries about other third-party services e.g.) unitary authority and housing associations and allotment associations

 

Destroy when not current or no longer needed for operations.

 

Where contains personal information, destroy as soon as matter resolved.

 

Do not pass on details without written permission

Local choice and Data Protection
Documents, and emails containing personal information

Officers and Councillors

Destroy as soon as possible. i.e. when retention no longer justified for one of the specified reasons. Data Protection
Third party emails and contact details containing personal data Destroy, when retention no longer justified for one of the specified reasons. Data Protection
Email account contents

Former Councillors

Review and permanently delete within 2 months of leaving council, except if relate to an ongoing issue then destroy when no longer needed Common practice and Data Protection
Email account contents

Former Employees

Review and permanently delete within 2 months of leaving council, except if relate to an ongoing issue then destroy when no longer needed Common practice and Data Protection
Statutory returns to Government etc. 7 years Common practice
Operating procedures 1 year after superseded Local choice
Consultations of public and staff Destroy after 3 years from closure Common practice
Record of complaints against Council Destroy after 6 years

Destroy personal information once matter resolved unless permission to retain.

Common practice

Data Protection

Freedom of information

Reviewing the quality, efficiency, or performance of the Council

Destroy after 5 years Common practice
Publicised work of the Council One copy to Permanent Archive

Destroy after administrative use

Common practice
Media Relations

Records of interactions

Destroy after 3 years Common practice
Marketing and promotions literature Destroy after 6 years Local choice
Civic and Royal events

Records of organising documents

Permanent Archive after administration use concluded

Destroy after 7 years

Common practice

Common practice

Making local byelaws, copies and procedures Permanent archive after administrative

use ended

Common practice
Administration and enforcement of local byelaws Destroy 2 years after conclusion of action Common practice
Emergency planning and Environmental issues Destroy 7 years after administration concluded Common practice
Town newsletters, press cuttings and photographs not containing personal information. Archive after no longer current Historic value
Ancient and historical records Record and Archive or to Cheshire Records Historic value
Reports, Guides, handbooks etc from other bodies Destroy when no longer current or useful Local choice
Consultees

Details of persons responding to consultations by hard copy, email, online or social media

Destroy once information taken for statistical

Purposes. Only attribute comments with written consent

Data Protection and good practice
Competition entrants Destroy once competition over.

Require written permission to use personal details for publicity. e.g. winners

Data Protection and good practice
Civic and ball list of attendees Destroy once event over.

Require written permission to use personal details for publicity or future invitations

Data Protection
Twinning with Macon Council

Details of visitors or organisers

Destroy personal information once matter completed unless permission to retain. Data Protection
Community safety and vulnerable adults information received through community engagement. Destroy, when retention no longer justified for one of the specified reasons. Data Protection

 

Photographs and Digital Images
Document Minimum Period of Retention Reason
Photographs/images without personal data, including from CCTV Destroy when no longer of use

 

Indefinite archive if required as permanent record or required for historical record

Local choice
Photographs/images considered to contain personal data, including from CCTV Destroy as soon as possible. i.e. when retention no longer justified for one of the specified reasons.

 

Retain only if positive consent of data subject and for the period of the consent only.

Data Protection

 

 

Data Protection

footer logo
Our Location
A: Crewe Town Council Office, 
1 Chantry Court, Forge Street, 
Crewe, CW1 2DL
Contact Us
T: (01270) 756975
E: @crewetowncouncil.gov.uk