File Retention Periods – Estates, Health and Safety
This page was last updated on 25th August 2022List of Information Assets considered
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File retention periods – Estates, Health and Safety
List of Information Assets considered
Asset: Policies
Asset: Risk Assessments
Asset: Accident investigation and recording
Asset: Training Records
Asset: Reception, Contractors and Visitors
Asset: Occupational health assessment
Asset: Estates and buildings Information
Asset: Sustainability records
Asset: CCTV recordings
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The main aim of this document is to list the Estates and Health and Safety Information Assets and suggest suitable file retention periods for associated content. Retention periods follow current Agency guidelines as set out in VCARP-2.
Asset: Policies
About the Asset:
Policies exist in multiple MS Office formats which are stored on the Central Services Network Drive (H:), Q-Pulse and in paper hard copy format.
Draft information and templates can also be found in shared drives such as Share-point.
Retention:
Guidance on The National Archives (http://www.nationalarchives.gov.uk/information-management/manage-information/policy-process/disposal/advice-on-retention/ suggests that we aggregate information into three categories, i.e.
- short – for example, up to two years
- medium – up to eight years
- long (time period unspecified).
Reviewing and deleting files
Deciding on the retention period should be the responsibility of the Estates, Health and Safety Manager.
As policies are living documents where amendment requirements can occur at any time, all policies will be given a review period of not less than 1 year and not more than 3 years. This is to ensure that the policy remains ‘fit for purpose’.
When the policy becomes no longer valid or effective it is to be archived for a period of not less than 7 years before being removed/deleted/destroyed.
Asset: Risk Assessments
About the Asset:
Risk Assessments exist in a standard MS Word format which is stored on the Central Services Network Drive (H:), Q-Pulse and in paper hard copy format. Hard copies are held by Estates on both main sites for ease of access and to cover legislative requirements
Retention:
Risk Assessments can require amendment at regular intervals but copies of all versions should be kept for not less than 7 years due to their legal standing and legal time barring periods such as for personal injury claims.
Reviewing and deleting files
When the Risk assessment becomes no longer valid or effective or is succeeded by an updated version, it is to be archived for a period of not less than 7 years before being removed/deleted/destroyed.
Asset: Accident investigation and recording
About the Asset:
Accident Investigations and their recording are an integral part of the Health and Safety systems employed by the VCA. These provide a written record of incidents and their associated events in a chronological order in which they occurred. They then provide the platform to assess the reasons from which the incident happened, the root causes and give an insight to developing systems to prevent re-occurrence of the recorded incident. This could lead to changes in Policy, Risk Assessment and/or Safe Systems of work.
This system is in place to protect the VCA and its employees, contractors and visitors. It is also required to provide the necessary authorities with legally required information in the event the incident or accident needs to be reported to statutory bodies for further investigation.
Retention:
All accident, incident and its associated investigation material must be kept for a minimum of 7 years. This is due to the legal requirements for retention of H&S documentation and the keeping of accident investigation records. This also allows for the legal time barring periods to expire such as for personal injury claims.
Reviewing and deleting files
Files must be kept in a secure location with access limited to only those authorised to access the information contained within. Once it is deemed that the information is no longer to be kept by the H&S Manager then it is to be securely destroyed and/or deleted from the systems it is contained within.
Asset: Training Records
About the Asset:
H&S training records are kept for employees who are trained in subjects with a specific skills required for certain H&S tasks. These are required to prove the training and competence levels of the individuals that are tasked to carry out such tasks.
Retention:
Training records are to be kept for at least as long as they are of relevance, for example whilst the individual in question holds a role specifically required to carry out H&S duties, the documentation must be retained to verify competence. Copies of training certificates will be held by the H&S Manager as proof of an individual’s competence.
Relevant documentation may also need to be retained to support accident or incident investigations.
This kind of information should be kept as long as the minimum period of training validity remains but may also be required to be kept as long as the individual competent person remains in a post or holds a duty where the training requirement exists.
Reviewing and deleting files
The training requirements for H&S related tasks will be reviewed periodically by the Estates, H&S Manager. Where a training requirement is no longer needed or when an individual resigns from being an appointed person and documentation will be securely destroyed or deleted unless there is a specific reason to retain longer. eg: When required to be kept as supporting documents for an accident or Incident investigation.
Asset: Reception, Contractors and Visitors
All visitors and contractors to VCA sites are required to fill in the relevant signing in book as acceptance of code of conduct on VCA sites.
Reviewing and deleting files
All contractor induction information will be securely destroyed after a 2 year period, provided that the information is not required to be retained longer for accident/incident investigation reasons.
All visitor log information will be securely destroyed after a period not greater than 2 calendar years. A full calendar is to be identified as any period from January to December.
Asset: Occupational health assessment
The VCA undertake a number of different forms of occupational health assessment to ensure the wellbeing of its staff. These include: DSE assessment, eye tests, health checks and specialist assessments as carried out by specified external suppliers on request.
The VCA uses the information given in the resulting reports to ensure the best possible working environment for its employees in both created and maintained
Retention:
The records held are personal and held securely as they may include sensitive information. The information is only to be kept as long as it remains relevant to the individual concerned at which point it is to be destroyed or deleted.
DSE assessments will be held whilst an individual remains in a particular working location. As the period for review is currently set at 3 years the information held on file should be kept for a minimum of this period.
Reviewing and deleting files
All records identified for deletion/destruction should be processed expediently. Care is to be taken to ensure than any and/or all personal details and other identifying information (such as the individuals name etc.) are removed from the record.
Asset: Estates and buildings Information
There are a large number of documents relating to VCA buildings which include:
- Service contracts for the daily running of equipment and services used in VCA buildings
- Lease contracts relating to the individual buildings and land that does not fall under VCA ownership
- Building and site plans that relate to the numerous specific buildings and the sites and surrounds on which they stand
The VCA uses the information given in the resulting reports to ensure the best possible working environment for its employees in both created and maintained
Retention:
The records held relating to general service contracts are held within finance and are to be kept for at least 7 years following contract end.
Records for buildings and general estate are held securely where they may include sensitive information.
Building records are to be kept for as long as the VCA occupies any leased buildings and that the information provided remains relevant (For example the service equipment within the building may change or become redundant). Records for the land or estate will be retained for as long as the real estate in question remains under VCA occupancy or control.
Files that contain information relating to contracts must be kept in a secure location with access limited to only those authorised to access the information contained within. Contracts that hold financial information or legal value are to be kept for a minimum of 7 years or until they no longer hold any value as directed by the relevant regulations. Files then identified for destruction must then be securely destroyed and/or deleted from the systems it is contained within.
Reviewing and deleting files
Information relating to buildings shall be kept whilst the asset is under VCA occupancy or control. These documents shall be held in a secure location/file until the asset is either:
- Handed back to its owner/landlord
- Is removed or demolished
- No longer holds and value to either the Landlord/Owner or the VCA.
On review, documents that are identified for destruction must be securely destroyed and/or deleted from the systems it is contained within.
Asset: Sustainability records
The VCA keeps records relating to its actions around sustainable practice and development such as those directed upon it by the Greening Government Commitment (GGC) and other such directives. These can be anything from at a local level to government initiatives and directives.
Retention:
Records of this type generally hold information about group practices and do not hold any personal information. Where personal information is required to be held in conjunction with any reports or records, these will be held for only as long as the information contained within retains a useful value. For example, information held under the GGC (Which is a 10 year cycle) shall be held until at least the end of 2020 when a new cycle begins. The information held may still hold value but is only to be kept for as long as it remains relevant to the individuals concerned. Should the information no longer hold this value, it is to be destroyed or deleted accordingly.
Reviewing and deleting files
All records identified for deletion/destruction should be processed expediently. Care is to be taken to ensure than any and/or all personal details and other identifying information (such as the individuals name etc.) are removed from the record.
Asset: CCTV recordings
The VCA uses Closed Circuit Television (CCTV) on its sites to provide a safe and secure environment for employees and visitors to VCA premises, such as clients, customers, contractors and suppliers and to protect VCA property.
The VCA also uses CCTV cameras for the following reasons:
- To assist in the prevention or detection of crime or equivalent malpractice
- To assist in the identification and prosecution of offenders
- To monitor the security of the VCA’s premises
- To act as a deterrent to those who may wish to commit offences on or to VCA property such as theft, arson or other such acts.
The CCTV system will only be used to observe areas at risk and the immediate external surroundings of VCA buildings in order to identify incidents that may require a response
Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for its purposes as set out in the CCTV Policy SMP – 002. Maintenance checks of the equipment used are undertaken on a regular basis to ensure that the equipment is working properly and that the media is producing high quality images.
The VCA’s CCTV facilities record images only. There is no audio recording i.e. conversations are not recorded on CCTV.
The access to and disclosure of, images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected and the relevant legislation that applies.
The images that are taken are recorded centrally in a secure location. Access to these recorded images is restricted to the operators of the CCTV system and to those managers who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other employees will not have access whilst viewing is occurring. If media on which images are recorded are removed for viewing purposes, this will be documented.
Retention:
Images are recorded in constant real time, 24 hours a day throughout the year.
As the recording system records digital images, any CCTV images that are held on the systems hard drive will be deleted and overwritten on a recycling basis and in any event are held for no more than one month.
Further disclosure of images may be taken from the system and may be held for periods longer than one month in accordance with the purposes for which the system is used and will be limited to:
- The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness
- Prosecution agencies such as the Crown Prosecution Service (CPS)
- Relevant legal representatives
- Line managers where appropriate reasons exist
- Individuals whose images have been recorded and retained (Unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders)
Images retained for periods longer than month must be erased or destroyed once the purpose of their recording becomes no longer relevant.
Reviewing and deleting files
The usage of CCTV Policy SMP – 002 and its content shall be reviewed upon any significant changes to the relevant legislation occur or no later than every 2 years, whichever comes sooner. This is to be carried out by the Estates, H&S Manager. Reference will be made to the relevant legislation and guidance in effect at such time.
Images that are stored on, or transferred to, removable media such as CD’s or computer systems will be erased or destroyed once the purpose of the recording becomes no longer relevant. In normal circumstances, this would be a period of no longer than one month. However, where a law enforcement agency is investigating a crime, images may need to be retained for a longer period.
When the system or hard drive has reached the end of its use, it will be completely erased and/or destroyed securely upon disposal.
Asset Notes:
For the purposes of this document an asset may include the following content:
- HTML content – held within the Content Management System (CMS). Backups of HTML pages are not created for the purposes of creating a change record, although they will be available from the Internet Archive, “Wayback machine”. Some complex information relating to Type Approval is managed through Q-Pulse (ref no. prefixed “WEB”) and subject to an annual review.
- Linked PDF files owned by other areas within VCA and managed through Q-Pulse. All documents managed through Q-Pulse are owned by the relevant area within the Agency, but any document not reviewed at the correct interval will be removed from the corporate website.
- Images – Held on CCTV Hard Drive or other storage devices for the purpose of crime detection and deterrence. These records are continuously recorded over on a 28day rolling period unless otherwise directed by the relevant authorities.
- Images – Held by VCA within the content management system and on the ‘R’ network drive. These are available as a library resource and removed only where:
- the image was created by a third party and the license is no longer valid;
- the image can be classed a personal information which is no longer required, so there is no reason to keep it
- the image is known to be unusable or will not be suitable in the future, in which case it will be deleted.