DD1482 GLA Records Management Policy

1.1 The records of the GLA are its corporate memory, and are necessary for good corporate governance, to be accountable, to comply with legal requirements, to provide evidence of decisions and actions, and to provide information for future decision-making.
1.2 Effective records management helps ensure that the Authority is able to effectively exploit the information that it creates and retains while ensuring that it retains certain key records to meet certain specific legislative requirements. It ensures that the GLA preserves records that are essential to documenting and supporting key decisions made by the Authority, not only for of posterity, openness and transparency, but also to evidence and justify those decisions in the event of legal challenges and scrutiny.
1.3 The standing GLA Records Management Policy was drafted in February 2004 to ensure the GLA complied the Records Management Code of Practice issued under s.46 of the Freedom of Information Act. Since its introduction, the policy has been reviewed and updated on several occasions, but it has been due a thorough revision to ensure it remains relevant for the GLA of 2016.
1.4 The GLA Records Management Policy is supported by two key documents:
• The Retention & Disposal Schedule sets out retention periods for particular types of records held by the GLA to ensure compliance with relevant statutory and regulatory provisions. The existing schedule was also introduced in 2004 and incorporates a detailed list of specific types of records held by the GLA. Although it has also been updated since its introduction, it no longer accurately reflects the work of the GLA, the types of information and records the Authority creates, or our business requirements for retaining those records; and
• The GLA Historical Archiving Policy was introduced in 2006 after the GLA signed an agreement with the London Metropolitan Archives (LMA) for the transfer of GLA records for permanent preservation. The policy details the types of information that have been identified as being of historical interest and importance to the LMA.

1.5 The consequence of out of date and unclear guidance results in the GLA retain more and more information over-and-above what it is necessary or advisable. As a result, the GLA’s IT storage requirements double every 18 months, and short-term archiving requirements for paper records totals just under £50,000 per year.

1.6 As a result, the GLA has taken a corporate initiative to update its records management and associated policies so that best practice is followed. The revised policies were presented to the GLA’s Governance Steering Group for consideration. The Group is an internal officer forum established to discuss key corporate governance issues arising in the Authority. It is chaired by the Executive Director of Resources and its membership includes the Head of Paid Service, the Monitoring Officer, the Head of Governance and the Information Governance Manager.

1.7 Following consideration and agreement by the Governance Steering Group, the Assembly party groups and the Mayoralty were consulted on the proposed revisions. There was unanimity that the updated approach would work well for the GLA and reflects the practice being adopted on related issues by the Authority.

2.1 The GLA has reviewed its Records Management Policy, along with the historical archiving and retention guidance documents. The guidance is now more relevant, more concise, more useable and, as a result, will be more effective; improving compliance and encouraging the disposal of records that do not need to be retained.

2.2 The revised policy now incorporates the associated retention and historical archiving guidance documents and proposes that the majority of GLA records should be retained for the duration of the Mayoral Term in which they were created and for the duration of the subsequent Mayoral Term. This is deemed to be the most appropriate period in organisational terms and mirrors approach adopted for retention of material on the GLA’s website. The Policy also sets out clear exceptions to this rule, notably where records are subject to specific legislative or regulatory requirements or the historical archiving policy, or where there is the potential for litigation or regulatory investigations or scrutiny.

2.3 Improving compliance with the Records Management Policy will:
• Increase efficiency and cost-effectiveness by ensuring that records are disposed of when no longer needed, enabling more effective use of resources, saving staff time searching for information that may not be there;
• Supports compliance with legislation that requires records and information to be kept, controlled and accessible, such as the Data Protection Act 1998, employment legislation and health and safety legislation; and
• Improve the GLA’s institutional memory by ensuring the records retrained are reliable and helping ensure future decisions are based on accurate information.

2.4 Improved records management will also significantly improve the ability of the GLA to comply with information access requests made under the Freedom of Information Act and Environmental Information Regulations, and improve assurances that the information provided will be complete and reliable.

3.1 In formulating the revised policy and guidance, GLA has complied with its obligation set out in s.149 Equality Act 2010 (the Public Sector Equality Duty) to have due regard to the need to:
• Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act;
• Advance equality of opportunity between people who share a protected characteristic and those who do not; and
• Foster good relations between people who share a protected characteristic and those who do not.
No adverse impact on any protected group has been identified.
3.2 The amended policy makes specific reference to the importance of complying with the GLA Data Protection Policy where records contain personal data, particularly where they involve sensitive personal data or reference to any protected characteristics.

4.1 The revised Records Management Policy will help mitigate general information-management-related risks across the GLA by ensuring that relevant records are retained by the Authority and that those that are no longer relevant or required are destroyed.
4.2 The Information Governance team will work with directorates, individual teams and senior managers to help mitigate the risks inherently associated with disposing of public authority records.

5.1 There are no specific financial issues arising from this decision. It is hoped that costs will reduce over time if more effective archiving practices are adopted.

6.1 Section 224 Local Government Act 1972 applies to the GLA by virtue of section 75 GLA Act 1999. Section 224 provides that the GLA must make “proper arrangements” with respect to any documents that belong to or are in the custody of the GLA or any of its officers.

6.2 This means having in place processes to ensure effective records management, to achieve the aims referred to in section 1 above. In addition, as mentioned at 1.3 above the GLA complies with the Code of Practice on records management issued under section 46 Freedom of Information Act 2000.

6.3 Subject to any specific legislative or other requirements to retain records or documents for a particular period of time (as referred to in the Retention and Disposal Schedule), the detail of the GLA’s records management policy is a matter for the GLA in its discretion, taking account of the aims referred to in section 1 above.

7.1 The next steps following this Director Decision are summarised below.

Appendix – GLA Records Management Policy