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Retention Development at NHS Improvement
Sarah Graham
Corporate Records Manager
19 October 2018
Introduction
• Key messages within the Information Governance Alliance
Code of Practice
• NHS Improvement retention development
• The move towards ‘Big Bucket’ retention
• Questions / Discussion
….but happy to take queries during the presentation!
Background to CoP
• Replaces the Records Management: NHS Code of Practice
parts 1 and 2 (2006) that had previously been produced by
the Department of Health
• The new guidance has more focus on
electronic records and has a reduced
retention schedule
• User friendly and has practical case studies
• Main section, three appendices –
final third appendix concentrates on
retention schedule pgs 53-80
Section 1: Regulatory Framework
Pgs 6 – 11
• NHS records – patient records, corporate records
• The framework is based on established standards
• The Public Records Act 1958 – all of us in this room are
affected by this act!
• DPA / FOI
(being adapted to reflect the new GDPR)
• The Academy of Medical Royal Colleges
• Training / Policy required
Section 2: How to Manage Records
Pgs 12 – 25
• Bread and butter of what the people in this room do!
• Lifecycle, records system
• ISO 15489 & DIRKS
• Cabinet Office e-Government
Metadata Standard v3.1 2006
• Cabinet Office Government Security Classifications April
2014 (will be updated to reflect the 2018 guidelines)
• Storage, maintenance, retention and disposal
Section 3: How to deal with specific
types of records
Pgs 26 – 40
• Specific to Health and Social Care records
• Section on Lloyd George papers is causing some issues
within GP practices
• The Good Practice Guidelines for GP electronic patient
records Version 4 (2011)
• Contract closure guidance
• Prison Health Care / Youth Offenders Institutions
• Complaint records
• Useful information Pg 28 on corporate records
• Emails guidance / scanning guidance
Section 4: Retention Schedule
Pgs 41 – 48
• Retentions are minimums – therefore, if there is a proven
business need, then records could be kept for longer than
the recommended minimum (links to BB approach)
• Access via DPA and Access to Health Records Act
• Pages 45 – 49 contains a useful list of records which may
be held in health and social care settings
Appendix One and Two
Pg 51 - Acknowledgements
• Many RM professionals involved in the development of this
piece of guidance
• Some members of the reference group may be in this very
room!
Pg 52 – Standards
Another useful list that is worth having a look at whether new
or experienced RM practitioner
Appendix Three: Retention Schedule
Pgs 53 – 80
• Schedule is significantly stripped down from the previous
code of practice which dated back to 2009
• Pg 79 Complaints retention is set at 10 years (was
previously 8 years)
• Pg 79 FOI requests retention where there has been an
appeal is set at 6 years (was previously 10 years)
NHS Improvement Implementation (1)
Background to NHS Improvement
• April 2016 - merger of Monitor and Trust Development
Authority
• Patient Safety, Intensive Support Team and ACT Academy –
joined in 2017 from NHS England
• Applying the IGA guidance until recruitment of RM
NHS Improvement Implementation (2)
New Organisation – New Approach / Clean Slate
• Decided to approach retention from a Big Bucket approach
as a brand new retention schedule has to be developed
• Prioritisation on Strategy / Policy / Guidance in 2017/2018
• Now the focus is on retention
• Initial thoughts taken to the Information Governance Group
on the 12th September 2018
NHS Improvement Implementation (3)
Starting the Work – September / October 2018
• Analysis of Code of Practice from a ‘Big Bucket’ perspective
• Discussions with colleagues in NHS England, Information
Governance Alliance and The National Archives
• Information Governance Leads in NHSI to get team buy in
• Now working on developing the retention schedule
• Previous information from Monitor and TDA
NHS Improvement Implementation (4)
Barriers
Concern from IGG that we may be keeping records for longer
than recommended in IGA – and the cost implications of this
• Explained the minimum provision
• NHS Improvement staff are new to retention therefore
implementation of any retention rules is a good thing
(pockets of good practice such as HR and Finance but in
the main are new to this)
NHS Improvement Implementation (5)
Opportunities
• This is a chance to embed a big bucket approach from the
outset with no legacy internal retention schedules to
complicate matters
• Links with the implementation of a new document and
records management system at NHSI
• Simple set of retention rules demystifies retention for staff
and will encourage implementation and use
NHS Improvement Implementation (6)
Our Approach – 5 retention categories
• 3 years
• 6 years
• 10 years
• 20 years
• Contracts (where the user will input in the system the
planned closing date of the contract which will then trigger
retention)
Questions / Discussion
For more information, please contact:
Sarah Graham
Corporate Records Manager
NHS Improvement
