Retention Development at NHS Improvement

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

[email protected]