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Progress Update Review - General Teaching Council for Scotland April 2025

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Progress Update Review - General Teaching Council for Scotland April 2025

Date published: 09 May 2025

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Contents

Public Records (Scotland) Act 2011
Progress Update Review (PUR) Mechanism
Executive Summary
Authority Background
Assessment Process
Progress Update Review (PUR): General Teaching Council for Scotland
The Public Records (Scotland) Act Assessment Team’s Summary
The Public Records (Scotland) Act Assessment Team’s Evaluation

1. Public Records (Scotland) Act 2011

The Public Records (Scotland) Act 2011 (the Act) received Royal Assent on 20 April 2011. It is the first new public records legislation in Scotland since 1937 and came into force on 1 January 2013. Its primary aim is to promote efficient and accountable record keeping by named Scottish public authorities.

The Act has its origins in The Historical Abuse Systemic Review: Residential Schools and Children’s Homes in Scotland 1950-1995 (The Shaw Report) published in 2007. The Shaw Report recorded how its investigations were hampered by poor recordkeeping and found that thousands of records had been created, but were then lost due to an inadequate legislative framework and poor records management. Crucially, it demonstrated how former residents of children’s homes were denied access to information about their formative years. The Shaw Report demonstrated that management of records in all formats (paper and electronic) is not just a bureaucratic process, but central to good governance and should not be ignored. A follow-up review of public records legislation by the Keeper of the Records of Scotland (the Keeper) found further evidence of poor records management across the public sector. This resulted in the passage of the Act by the Scottish Parliament in March 2011.

The Act requires a named authority to prepare and implement a records management plan (RMP) which must set out proper arrangements for the management of its records. A plan must clearly describe the way the authority cares for the records that it creates, in any format, whilst carrying out its business activities. The RMP must be agreed with the Keeper and regularly reviewed.

2. Progress Update Review (PUR) Mechanism

Under section 5(1) & (2) of the Act the Keeper may only require a review of an authority’s agreed RMP to be undertaken not earlier than five years after the date on which the authority’s RMP was last agreed. Regardless of whether an authority has successfully achieved its goals identified in its RMP or continues to work towards them, the minimum period of five years before the Keeper can require a review of a RMP does not allow for continuous progress to be captured and recognised.

The success of the Act to date is attributable to a large degree to meaningful communication between the Keeper, the Assessment Team, and named public authorities. Consultation with Key Contacts has highlighted the desirability of a mechanism to facilitate regular, constructive dialogue between stakeholders and the Assessment Team. Many authorities have themselves recognised that such regular communication is necessary to keep their agreed plans up to date following inevitable organisational change. Following meetings between authorities and the Assessment Team, a reporting mechanism through which progress and local initiatives can be acknowledged and reviewed by the Assessment Team was proposed. Key Contacts have expressed the hope that through submission of regular updates, the momentum generated by the Act can continue to be sustained at all levels within authorities.

The PUR self-assessment review mechanism was developed in collaboration with stakeholders and was formally announced in the Keeper’s Annual Report published on 12 August 2016. The completion of the PUR process enables authorities to be credited for the progress they are effecting and to receive constructive advice concerning on-going developments. Engaging with this mechanism will not only maintain the spirit of the Act by encouraging senior management to recognise the need for good records management practices, but will also help authorities comply with their statutory obligation under section 5(1)(a) of the Act to keep their RMP under review.

3. Executive Summary

This Report sets out the findings of the Public Records (Scotland) Act 2011 (the Act) Assessment Team’s consideration of the Progress Update Review template submitted for General Teaching Council for Scotland. The outcome of the assessment and relevant feedback can be found under sections 6 – 8.

4. Authority Background

The General Teaching Council for Scotland (GTC Scotland) is the independent regulator for teachers in Scotland. It works in the public interest to enhance trust in teachers by setting, upholding and promoting high standards.

GTC Scotland was set up in 1965. It was created following calls from teachers for a body to ensure teacher standards and was one of the first teaching councils in the world. In 2012, it became the world’s first independent professional and regulatory body for teaching.

https://www.gtcs.org.uk/about-us

5. Assessment Process

A PUR submission is evaluated by the Act’s Assessment Team. The self-assessment process invites authorities to complete a template and send it to the Assessment Team one year after the date of agreement of its RMP and every year thereafter. The self-assessment template highlights where an authority’s plan achieved agreement on an improvement basis and invites updates under those ‘Amber’ elements. However, it also provides an opportunity for authorities not simply to report on progress against improvements, but to comment on any new initiatives, highlight innovations, or record changes to existing arrangements under those elements that had attracted an initial ‘Green’ score in their original RMP submission.

The assessment report considers statements made by an authority under the elements of its agreed Plan that included improvement models. It reflects any changes and/or progress made towards achieving full compliance in those areas where agreement under improvement was made in the Keeper’s Assessment Report of their RMP. The PUR assessment report also considers statements of further progress made in elements already compliant under the Act.

Engagement with the PUR mechanism for assessment cannot alter the Keeper’s Assessment Report of an authority’s agreed RMP or any RAG assessment within it. Instead the PUR Final Report records the Assessment Team’s evaluation of the submission and its opinion on the progress being made by the authority since agreeing its RMP. The team’s assessment provides an informal indication of what marking an authority could expect should it submit a revised RMP to the Keeper under the Act, although such assessment is made without prejudice to the Keeper’s right to adopt a different marking at that stage.

Key

Green

The Assessment Team agrees this element of an authority’s plan.

Amber

The Assessment Team agrees this element of an authority’s progress update submission as an ‘improvement model’. This means that they are convinced of the authority’s commitment to closing a gap in provision. They will request that they are updated as work on this element progresses.

Red

There is a serious gap in provision for this element with no clear explanation of how this will be addressed. The Assessment Team may choose to notify the Keeper on this basis.

6. Progress Update Review (PUR): General Teaching Council for Scotland

Element 1: Senior Officer

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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Update required on any change

Self-assessment - 22 September 2023

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Our Chief Executive and Registrar is as reported, Dr Pauline Stephen.

Progress Review Comment - 16 January 2023

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Thank you for letting the Assessment Team know that there have been no changes to this Element. Update required on any future change.

Self-assessment Update as submitted by the Authority since 16 January 2023

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Our Chief Executive and Registrar continues to be Dr Pauline Stephen.

Progress update review - 17 April 2025

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Thank you for letting us know that there have been no changes to this Element. Update required on any future change.

Element 2: Records Manager

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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The Keeper acknowledges that GTCS have, since the Plan was submitted, appointed a Compliance Officer who will take on the implementation of the Plan as indicated Plan section 3. He accepts that future versions of the Plan may transfer the ‘element 2’ responsibility to this new officer.

Self-assessment -22 September 2022

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No change

Progress Review Comment - 16 January 2023

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Update required on any change

Self-assessment Update as submitted by the Authority since 16 January 2023

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Records Manager responsibility now sits with the Information Governance Officer. Their contact details are: [details provided]

Progress update review - 17 April 2025

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The Assessment Team thanks GTC Scotland for these details which have been noted.

Element 3: Policy

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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Update required on any change

Self-assessment - 22 September 2022

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Our Records Management Policy is due for review in the Autumn of 2022. We are currently engaged in a project to implement a new intranet solution in SharePoint online, this will be our new “Hub”. (The “Hub” is out internal SharePoint site – our intranet).
A project team has been established and they are working with external developers to build the new system. Files on the new Hub will be organised by Function rather than department and therefore a review of our Records Management Policy and Records Management and Retention Schedule (RMRS) is planned to incorporate these changes.

Staff will be given the opportunity to look at the new functional structure and ask questions as well as attend formal training sessions before the launch of the new hub.

Progress Review Comment - 16 January 2023

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The Keeper’s Assessment Team thank you for this update regarding a new SharePoint Online Hub. It is very reasonable that the Records Management Policy should be updated based on the major changes in business classification and retention scheduling about to take place.

It is evident from this update that GTC Scotland remains committed to keeping their information governance policies and guidance documents fit for purpose.

See Element 4 for further comments on Business Classification implementation and Element 12 for comments on training.

Self-assessment Update as submitted by the Authority since 16 January 2023

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The ‘Hub’ has now been implemented. It directs staff to resources within the organisation including those related to Records Management. A screenshot demonstrating this has been included as Appendix 1.

We are currently engaged in a ‘Data Review’ programme of work to implement changes and improvements to data and records held by GTC Scotland. This will also include updates to our records management policies in due course. We will provide an update in our next Progress Update Review.

We have also updated our Appropriate Policy Document as per Schedule 1, Part 4, section 38 of the Data Protection Act and provide a copy with this submission as Appendix 2.

Progress update review - 17 April 2025

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The Keeper expects each authority’s plan to include a records management policy statement. The policy statement should describe how the authority creates and manages authentic, reliable and useable records, capable of supporting business functions and activities for as long as they are required.

The Assessment Team understands that GTC Scotland continues to meet the requirements of element 3.

It is also interesting to hear of internal records management policy dissemination (“The hub”) as well as ongoing work on the “Data Review” Programme and relevant policy document updates. The receipt of evidence is also acknowledged with thanks. The team look forward to further updates in subsequent PURs.

Element 4: Business Classification

Status:

6 June 2018 - agreed plan - Amber
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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GTCS state in the Plan (section 5): “The Records Management and Retention Schedule was developed following a comprehensive data audit process. This process took a significant amount of time and the Schedule is still in the process of being finalised for use. We intend to roll the Records Management and Retention Schedule out across the organisation at the same time as we upgrade our SharePoint system (the principle document storage and management system that we use).” The Keeper agrees this action.

Meeting Note (19 July 2017) suggests the SharePoint section of the project will be implemented in 2018. The Keeper will ask for annual progress updates as the whole project goes forward.

The Keeper can agree this Element on an ‘improvement model’ basis. This means that the authority has identified gaps in provision (business classification/retention schedule and SharePoint upgrade has not been fully implemented). However he recognises that GTCS have identified how they intend to close this gap and committed to do so: The Keeper has been provided with a commitment to pursue records management improvements in the text of a Covering Letter from the authority’s Chief Executive and in the Corporate Management Team Meeting Note (above). The Keeper’s agreement is dependent upon him being kept informed of progress with this work when required.

Self-assessment - 22 September 2022

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As detailed above a review of our RMRS will take place once the functional structure of the new hub is confirmed. As part of the preparatory work for migrating files to the new hub from the current one, teams are looking at what information is held, what needs to be migrated and what can be archived, the retention times etc to ensure that the information held is in line with business needs.

Progress Review Comment - 16 January 2023

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Based on this update, GTC Scotland is working hard towards making the transition to a new Business Classification Scheme. It is likely the process will take some time to fully implement throughout all business areas.

It is also very good to hear that these major changes are being supported through Q&A sessions and training for staff (as reported under Element 3). See also Element 12.

Self-assessment Update as submitted by the Authority since 16 January 2023

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As part of our Data Review programme of work, we will be addressing the use of business classification on the Hub.

It is possible that “auto-labelling” through Microsoft Purview will apply retention periods to records automatically.

We are currently reviewing the work required to implement this and will be able to report back in the future.

To begin, we have compiled reporting on the metadata regarding those records we hold to begin a process of business and data classification.

All associated records management policies will be updated accordingly as part of the Data Review programme.

Progress update review - 17 April 2025

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Thank you for confirming that GTC Scotland continues to continually embed the Business Classification Scheme into its processes. This improvement work is noted with thanks.

Element 5: Retention schedule

Status:

6 June 2018 - agreed plan - Amber
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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Combined Retention Schedule and Business Classification Scheme see element 4.

As noted under element 4 above GCTS states that this scheme “is still in the process of being finalised for use. We intend to roll the Records Management and Retention Schedule out across the organisation at the same time as we upgrade our SharePoint system (the principle document storage and management system that we use).” This is confirmed in Plan section 6 which adds “the Schedule is new and is still to be rolled out so we expect it to be subject to refinement and amendment on an ongoing basis” and “We plan to do significant work over the next 12 months to ensure that the retention rules specified are consistently applied across GTCS record systems.” The Keeper agrees these actions.

The Extract Corporate Management Team Meeting Note (19 July 2017) suggests the SharePoint section of the project will be implemented in 2018. The Keeper is likely to ask for annual progress updates as the whole project goes forward.

The Keeper notes that the Plan (section 6) explains that the Records Management and Retention Schedule, although not fully implemented, is already available to view on the staff ‘Hub’ intranet. Can a screen-shot please be provided as evidence?

The Keeper can agree this Element on an ‘improvement model’ basis. This means that the authority has identified gaps in provision (retention schedule and SharePoint provision has not been fully implemented), but have identified how it intends to close this gap. The Keeper has been provided with a commitment to pursue records management improvements in the text of a Covering Letter from the authority’s Chief Executive and in the Corporate Management Team Meeting Note (see element 4). The Keeper’s agreement is dependent upon him being kept informed of progress with this work when required.

Self-assessment - 22 September 2022

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As detailed above a review of our RMRS will take place once the functional structure of the new hub is confirmed. The RMRS will be reviewed and updated to ensure that it also reflects and supports the business.

We expect that teams monitor their entries on the RMRS as part of their business as usual work. We have a process in place whereby Senior Managers can request amendments or additions to the RMRS out with formal reviews. A copy of this process is attached as appendix A.

Progress Review Comment - 16 January 2023

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Thank you for providing this update. It is great to hear that there is a detailed plan in place for the review of Records Management and Retention Schedule in line with the implementation of a new SharePoint-based records management environment.

The receipt of evidence provided under Appendix A (a guidance document and sample form for requesting an amendment or addition to the
Records Management & Retention Schedule) is acknowledged with thanks.

The Assessment Team has no particular concerns about this Element, but would like to encourage GTC Scotland to keep them informed of the progress of this project through the PUR mechanism.

Self-assessment Update as submitted by the Authority since 16 January 2023

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We continue to implement the Records Management Plan within the Sharepoint environment.

This is done through purpose limiting folders to specific users as required necessary to access folder.

Maintaining relevant time and date stamping for the application of auto labelling and disposing of records where needed under the Retention Schedule.

We consider it will be necessary to carry out a review of our Retention Schedule to reflect organisational changes and output from our ongoing Data Review programme, which require updating where necessary.

We will keep NRS informed of this review of our Retention Schedule through this process.

Progress update review - 17 April 2025

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Element 5 stipulates that public records are retained and disposed of in accordance with the Retention Schedule. The Assessment Team understands that GTC Scotland continues to better embed its retention schedule into its electronic records management environment.

As expressed by GTCS, as a living document, it is expected that the retention schedule will be regularly reviewed to ensure it continues to reflect statutory and business needs. The Team look forward to being updated on these improvements, especially as they connect closely with other elements.

Element 6: Destruction arrangements

Status:

6 June 2018 - agreed plan - Amber
16 January 2023 - review - Amber
17 April 2025 - review - Amber

Keeper's Report - 6 June 2018

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The Plan (page 4/5) states that: “The electronic deletion of electronic records is more complex given that we currently have a number of record repositories. The destruction arrangements for these records are described in detail in our Information Security Policy. We are in the process of initiating a project to replace our current teacher register database with a new system that will also introduce an automated form of case management (covering our fitness to teach investigation and adjudication function). The intention is that this change will mean that our records repository infrastructure is made more coherent and we will achieve better system integration that will lead to more consistent, efficient records management. The aim is also that this new coherent system will better facilitate comprehensive auto-destruction of records, in line with the retention periods identified in the Records Management and Retention Schedule.” The controlled and systematic deletion of records held on shared drives is a particular area of difficulty for many public authorities and the Keeper welcomes the acknowledgement of this. He agrees that the suggested improvements the Authority is considering are a reasonable response to these difficulties.

The Keeper agrees this element of the GTCS Plan on ‘improvement model’ terms. This means that he recognises that, having identified a gap in provision (in this case, around the systematic destruction of electronic records) , the authority has put in place a reasonable response to this gap. The Keeper’s agreement is conditional on him being updated as the improvement project progresses. The Keeper will prompt such updates annually.

Self-assessment - 22 September 2022

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Having consolidated the migration of the register of teachers and key registration processes on Atlas, we will shortly embark on an optimisation project which will include the review of retention policies and the development of automated deletion of records that are no longer required. This will include incomplete application forms.

Progress Review Comment - 16 January 2023

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The Assessment Team is grateful for this update. It is clear that work continues on the full implementation of the new line-of-business system, and that the optimisation project mentioned will help GTC Scotland to achieve controlled, secure and irretrievable destruction of records that are no longer required.

This Element will remain at Amber while the work is ongoing. It is clear, however, that GTC Scotland is continuing to make progress in this Element.

Self-assessment Update as submitted by the Authority since 16 January 2023

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As noted, the optimisation project, now referred to as our Data Review programme of work is underway.

Our analysis of the SharePoint has provided insight on where information is stored and processed to carry out data mapping.

We consider it necessary to implement the automatic destruction of records at the end of the retention period applicable on our SharePoint.

Our work in this area is continuing through the Data Review with its latest meeting on 23 September 2024. A key theme identified was the destruction of records.

Progress update review - 17 April 2025

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Thank you for providing this update on records destruction arrangements, including continuing work under the Data Review programme. It is understood that GTC Scotland is still working to implement the agreed improvement actions under this Element.

This Element will remain at Amber. The Assessment Team look forward to being updated on progress in subsequent PURs.

Element 7: Archiving and transfer

Status:

6 June 2018 - agreed plan - Amber
16 January 2023 - review - Amber
17 April 2025 - review - Amber

Keeper's Report - 6 June 2018

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The Plan confirms: “We are in the process of agreeing a Memorandum of Understanding with NAS [sic] to formally document the timing of our transfers, transfer mechanisms and other terms and conditions.”

The Keeper agrees this element of GTCS’ Records Management Plan under ‘improvement model’ terms. This means that he acknowledges that the authority has identified a gap in provision [there is no formal transfer agreement with the archive] and have put processes in place to close that gap. The Keeper’s agreement is conditional on his PRSA Assessment Team being provided with a copy of the signed MOU when available.

Self-assessment - 22 September 2022

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Thank you for this. I have sent Claire an email explaining that I will now be leading on this and suggesting that we start afresh and arrange a discussion so that I can get an understanding of what is required.

I have informed Claire that we have a temporary member of staff working with us at the moment who is pulling together an itinerary of all of the governance documents which we hold in paper format. Once we have an understanding of what is there – we will be in a better position to start to look at what should go to permanent archive. I need to get a clear understanding of what would be required so that we can consider if we would be in a position to resource it. An initial conversation with Claire will at least restart this process.

Progress Review Comment - 16 January 2023

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According to section 1(2)(b)(iii) of the Act, an authority must ensure that records of enduring value are deposited in an appropriate archive repository, and that a mechanism is in place for dealing with records identified as suitable for permanent preservation.

The Assessment Team is aware that GTC Scotland’s RMRS is currently awaiting review. This schedule should identify records of enduring corporate and legal value, and may also identify records of historical, cultural and research value, whether in digital or analogue format. The upcoming review of this document might give GTC Scotland an opportunity to address an ongoing shortfall in the identification of public records to be permanently preserved.

It is positive to hear that GTC Scotland has recently reached out to their NRS Client Manager as formal Deposit Agreement or Memorandum of Understanding is still pending. The Assessment Team would encourage GTC Scotland to continue to pursue this with some urgency as the finalisation of this has been outstanding since the original Agreement in 2018.

This Element will remain at Amber whilst the authority works towards closing this gap.

Self-assessment Update as submitted by the Authority since 16 January 2023

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We are currently in discussion with our relevant Client Manager reviewing the Memorandum of Understanding.

We recently met with Claire Sillick on 30 September to discuss the Deposit Agreement and ensuring it is signed as soon as possible. We will review the Deposit Agreement and will update her on progress.

We intend for the Deposit Agreement to be finalised by the next update to the Progress Update Review.

Progress update review - 17 April 2025

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Authorities should ensure that records that have enduring value are permanently retained and made accessible. An authority’s RMP must detail its archiving and transfer arrangements and ensure that records of enduring value are deposited in an appropriate archive repository. A formal Transfer Agreement is expected to be in place with the selected repository.

GTCS is currently working on getting the Transfer Agreement formalised with National Records of Scotland. The PRSA Assessment Team would like to encourage GTCS to continue engaging with our Archive Depositor Liaison colleagues to ensure this process is formalised as soon as possible. The Team welcomes the estimate that this should be completed within the year following the submission of this PUR.

This Element will remain at Amber while work continues.

Element 8: Information security

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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Update required on any change

Self-assessment - 22 September 2022

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During the Pandemic when all GTC Scotland staff were working from home, a Flexible Working project group was established to look at what needed to be put in place for the introduction of hybrid flexible working. Part of this was a substantial review of the Information Security Policy. The amended version was rolled out to staff in January 2022. A copy of the current version is provided at Appendix B.

Progress Review Comment - 16 January 2023

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Thank you for this update. It is positive to hear that the Information Security Policy has been substantially reviewed in light of hybrid working arrangements. The Team acknowledges the receipt of this policy with thanks.

Update required on any future change.

Self-assessment Update as submitted by the Authority since 16 January 2023

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In an updated version of our Information Security Policy (October 2023) which we have provided marked as Appendix 3 we included the requirement that users have two-factor authentication enabled as a minimum by users of GTC platforms.

We are currently reviewing the requirements of Information Security as part of a Data Review project which is ongoing and will be further addressed by the next submission.

Progress update review - 17 April 2025

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The Assessment Team is grateful for this update on information security, including a recent policy update on the adoption of two-factor authentication.

Element 9: Data protection

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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Update required on any change

Self-assessment - 22 September 2022

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The Data Protection policy was also reviewed and amended and rolled out to staff in January 2022. A copy of the current version is provided at Appendix C.

Progress Review Comment - 16 January 2023

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The Assessment Team thanks you for this update, and the updated Data Protection Policy, received with thanks. Update required on any future change.

Self-assessment Update as submitted by the Authority since 16 January 2023

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We have adopted a standardised Data Protection Impact Assessment template when reviewing whether the use of data involves a “high risk” to data subjects.

A copy of the template DPIA has been included as part of this review marked Appendix 4.

We continue to ensure that we adhere to data protection requirements through staff training and internal review.

Progress update review - 17 April 2025

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The Assessment team thanks you for this update on data protection, and acknowledges the receipts of the DPIA template in use with thanks.

Element 10: Business continuity and vital records

Status:

6 June 2018 - agreed plan - Amber
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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The Plan (section 11) states: “We are currently in the process of reviewing and revising our BCP to make it more comprehensive, including to cover access to vital records in the event of an emergency affecting our premises or systems.”

The Plan also states (section 9): “We ... need to do work to enhance our business continuity arrangements so that the availability of all of our vital records is maintained in the event of a critical incident.”

On the subject of vital records the Plan states (section 11): “Linked to work on the review, development and stress-testing of our BCP, we will be checking that we have identified our vital records accurately.” The Keeper agrees this action.

The Keeper is able to agree this element of GTCS’ plan under ‘improvement model’ terms. This means that he is convinced that, having identified a gap in provision (in this case the Business Continuity Policy is undergoing review and vital records have not yet been identified throughout) the authority has put measures in place to close that gap. His agreement is conditional on GTCS providing him with evidence that vital records have been identified and noted and that the review of the Business Continuity Arrangements has been pursued.

Self-assessment - 22 September 2022

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The move to remote working for all GTCS staff during the pandemic has allowed us to demonstrate that staff have access to records as their specific job requires. This has been instrumental in informing decision making about our new working model with staff working on a remote and hybrid basis to suit their circumstances, while continuing to provide business as usual service to stakeholders.

Progress Review Comment - 16 January 2023

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An authority’s business continuity arrangements should include the recovery of records made temporarily unavailable due to an unexpected event.

It is positive to hear that work-from-home and hybrid working arrangements have not impacted negatively on GTCS’s ability to conduct its business as usual

Self-assessment Update as submitted by the Authority since 16 January 2023

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Our business continuity plan continues to set out our process / procedure for the recovery of records made temporarily unavailable due to an unexpected event.

This includes reporting the event through our incident reporting form relating to internal data incidents with technical solutions for recovery or the restoration of data.

We have used this mechanism to consider the relevant records identified by an incident which are held one of our platforms and use these to avoid similar situations in the future.

We have included a recent data incident marked as Appendix 5 with this submission to provide an example of our records management practices in this area.

Progress update review - 17 April 2025

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Thank you for this update which confirms that arrangements continue to be in place for business continuity and vital records access in the face of an unexpected event.

The receipt of evidence provided is noted with thanks.

Element 11: Audit trail

Status:

6 June 2018 - agreed plan - Amber
16 January 2023 - review - Amber
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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The Records Management Policy gives basic naming convention guidance for staff. However, the Plan states: “We are aware that we need to introduce specific procedures and guidance in relation to version control within GTCS.” The Keeper accepts that this issue will be considered during the Records Management and Retention Schedule/SharePoint project (see element 4).

The Plan states (Section 5): “We intend to roll the Records Management and Retention Schedule out across the organisation at the same time as we upgrade our SharePoint system (the principle document storage and management system that we use). We intend to contract a specialist Information Architect to help us structure our new document storage and management system in order to address the issues (particularly as regards the duplication of records) that the data audit identified. Guidance and comprehensive training will support the roll out process.” The Keeper agrees this action.

The Keeper can agree this Element on an ‘improvement model’ basis. This means that the authority has identified gaps in provision (retention schedule, version control and SharePoint provision has not been fully implemented, which adversely effects document tracking), but have identified how it intends to close this gap. The Keeper has been provided with a commitment to pursue records management improvements in the text of a Covering Letter from the authority’s Chief Executive and in the Corporate Management Team Meeting Note (see element 4). The Keeper’s agreement is dependent upon him being kept informed of progress with this work when required.

Self-assessment - 22 September 2022

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Naming conventions are still manual and rely on staff being educated and diligent about it. Version control is currently disabled in the existing hub but this is something that will be considered if required going forward with the new SharePoint hub. This is something that we will discuss with our provider.

Progress Review Comment - 16 January 2023

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Element 11 stipulates that an authority must maintain a complete and accurate representation of all changes that occur in relation to a particular record. Version control is essential in establishing the authenticity of public record. ‘Changes’ can be taken to include movement of a record even if the information content is unaffected, so migration of any existing files into a new system should also be done with care.

All staff adhering to specific naming convention guidelines is essential to the future discoverability of records. The Assessment Team would encourage GTC Scotland to review, publicise and actively implement organisational File Naming Guidelines. This can be done in anticipation of the SharePoint project as this will hopefully make the transition to a new system smoother. Whilst the version control facility is still awaiting the implementation of SharePoint, new naming conventions can be implemented with immediate effect.

This Element remains at Amber. We look forward to being updated on progress in subsequent PURs.

Self-assessment Update as submitted by the Authority since 16 January 2023

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Version control exists within multiple platforms used by GTC Scotland.

Firstly, within the online repository known as Atlas (Dynamics) records related to Registrants are stored and accessed with changes over time recorded via an audit history. We have included an example of the audit history which can be viewed internally on Appendix 6.

Secondly, documents held on the Hub can reflect the date they were created, modified (the user who did so) and allows for them to go through an approval process where necessary. We have included an example of this as Appendix 7.

Thirdly, within the documents themselves, staff can give comments, markup text and review changes where the user, content and timestamp of the change is recorded.

Finally, within the platform of Zendesk, incoming calls and emails are time and date stamped with communication and internal notes displaying how interactions have gone and when they occurred for a shared response displaying a clear audit trail.

Progress update review - 17 April 2025

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Element 11 stipulates that the location of records is known and all changes (including changes in location) are accurately recorded.

An additional update and accompanying evidence has been provided, indicating that Naming Convention Guidelines are in place at General Teaching Council for Scotland, and that these are being communicated to staff and implemented with evidenced consistency.

GTCS has now let the Assessment Team know that it now believes it has closed the gap identified in the 2018 Records Management Plan (RMP) Agreement Report, and Element 11 can be turned Green for the PURs. The Assessment Team acknowledges that significant improvement that has taken place at GTCS under this Element and commends GTCS for this progress, encouraging the authority to continue to improve its provision under this Element by continuing to embed best practice.

Element 12: Competency framework

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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GTCS recruited a Records Manager (Compliance Officer) during the period of the assessment. At the time of the submission, the implementation of the Plan was the responsibility of the Director of Regulation and Legal Services. (see element 2). This arrangement has been confirmed in a Covering Letter from Kenneth Muir, Chief Executive and Registrar (see element 1). At the same time as the recruitment exercise for the new Compliance Officer , the authority developed records management competencies. The Keeper notes and agrees these actions. An update including the objectives, development plan and competencies for the new compliance officer can be provided at the next update (normally prompted annually). At that time GTCS should formally state whether the new officer will replace the Director of Regulation and Legal Services as the identified individual at element 2.

GTCS staff are trained on data protection procedures. This includes supplementary training in preparation for GDPR. Staff training on GDPR is being reviewed (Plan section 10). The Keeper would welcome any further information once this review has been carried out.

Self-assessment - 22 September 2022

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GTC Scotland is currently going through a restructure, the Assessment Team will be provided with any relevant information in this context in early 2023.

Progress Review Comment - 16 January 2023

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Element 12 is concerned with staff records management competencies. This is usually reflected in the way members of staff are trained and supported in their work with regard to the management of public records.

Thank you for letting the Assessment Team know of the current restructuring process. Alongside the implementation of the SharePoint Hub, staff training needs will be impacted by this as indicated in the update provided under Elements 3 and 4. It is good to see GTC Scotland is taking steps to make sure staff receive appropriate training. The Assessment Team welcomes further updates in subsequent PURs.

Self-assessment Update as submitted by the Authority since 16 January 2023

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The “Information Governance Officer” has oversight of the requirements of a Records Manager.

We conduct regular online UK GDPR training modules with all staff and require new staff to receive during induction training through the Cyber Essentials Plus Scheme. We have attached a copy of our most recent Certificate of Assurance with them as Appendix 8.

Additionally, we have conducted multiple staff training sessions to the organisation via the Information Governance Officer related to data protection, records management and compliance.

Progress update review - 17 April 2025

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Thank you for this update on staff competency framework and training. It is also positive to hear that GTC Scotland maintains its Cyber Essentials Plus Scheme accreditation, and continues to provide staff training accordingly. The submitted evidence has been received with thanks.

Internal knowledge sharing is also positive to hear about.

Element 13: Assessment and review

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report -6 June 2018

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Update required on any change

Self-assessment - 22 September 2022

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No change

Progress Review Comment - 16 January 2023

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Update required on any future change.

GTC Scotland is commended for its regular participation in the PUR process.

Self-assessment Update as submitted by the Authority since 16 January 2023

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We continue to apply and update our procedures as needed based on our participation with the Record Management Plan.

Progress update review - 17 April 2025

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Thank you for this update which has been noted.

Element 14: Shared information

Status:

6 June 2018 - agreed plan - Green
16 January 2023 - review - Green
17 April 2025 - review - Green

Keeper's Report - 6 June 2018

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Update required on any change

Self-assessment - 22 September 2022

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We are continuously working to improve our Data Sharing Agreements. An example of an agreed and signed off DSA is provided at Appendix D. The text of the document remains the same, it is the appendix that is amended to ensure that the data sharing activities with the recipient are documented.

We also hold a DSA Register, a screenshot of this is provided at appendix E.

Progress Review Comment - 16 January 2023

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The Assessment Team thanks you for this positive update, and the sample DSA, and screenshot of Register, kindly provided. It is apparent that GTC Scotland continues to understand the need to properly control this aspect of its information processes.

Self-assessment Update as submitted by the Authority since 16 January 2023

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We are continuously working to improve our Data Sharing Agreements.

An example of a recently agreed DSA with the Teaching Regulation Agency has been provided as Appendix 9.

Progress update review - 17 April 2025

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Thank you confirming that GTC Scotland continues to implement and improve Data Sharing Agreements. The receipt of a sample DSA is also acknowledged with thanks.

7. The Public Records (Scotland) Act Assessment Team’s Summary

Version

The progress update submission which has been assessed is the one received by the Assessment Team on 30th of September 2024. The progress update was submitted by James Ekron, Information Governance Officer.

The progress update submission makes it clear that it is a submission for General Teaching Council for Scotland.

The Assessment Team has reviewed General Teaching Council for Scotland’s Progress Update submission and agrees that the proper record management arrangements outlined by the various elements in the authority’s plan continue to be properly considered. The Assessment Team commends this authority’s efforts to keep its Records Management Plan under review.

General Comments

General Teaching Council for Scotland continues to take its records management obligations seriously and is working to bring all elements into full compliance.

Section 5(2) of the Public Records (Scotland) Act 2011 provides the Keeper of the Records of Scotland (the Keeper) with authority to revisit an agreed plan only after five years has elapsed since the date of agreement. Section 5(6) allows authorities to revise their agreed plan at any time and resubmit this for the Keeper’s agreement. The Act does not require authorities to provide regular updates against progress. The Keeper, however, encourages such updates.

The Keeper cannot change the status of elements formally agreed under a voluntary submission, but he can use such submissions to indicate how he might now regard this status should the authority choose to resubmit its plan under section (5)(6) of the Act.

8. The Public Records (Scotland) Act Assessment Team’s Evaluation

Based on the progress update assessment the Assessment Team considers that General Teaching Council for Scotland continue to take their statutory obligations seriously and are working hard to bring all the elements of their records management arrangements into full compliance with the Act and fulfil the Keeper’s expectations.

The Assessment Team recommends authorities consider publishing PUR assessment reports on their websites as an example of continued good practice both within individual authorities and across the sector.

This report follows the Public Records (Scotland) Act Assessment Team’s review carried out by

Iida Saarinen
Public Records Officer

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NRS Public Records (Scotland) Act (PRSA) General Teaching Council For Scotland Progress Update Review (PUR) 2024 Final Report Web Version 17 April 2025

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