Model Plan Review 2018
Model Plan Review 2018
The Public Records (Scotland) Act 2011 (the Act) has been in operation for 5 years. The Keeper of the Records of Scotland (the Keeper) considers it is therefore time to review the Model Plan and the Guidance Document published to help public authorities comply with the Act.
A new Stakeholder Forum consisting of information specialists invited from various sectors has been convened to conduct the review. It was, of course, necessary to limit the number of colleagues and authorities invited to participate in the Forum. It is, however, vital that all public sector colleagues have the opportunity to engage with the work of the Forum and by so doing assist the Keeper to update the Model Plan. To this end a record of the Forum deliberations is published here for access and comment.
The Forum is looking at all elements and aspects of the current Model Plan, but it is also considering two particular aspects of wider record-keeping under the Act:
- To what extent can an agreed records management plan contribute to evidence of compliance under the new Data Protection Act 2018?
- How can the Model Plan articulate and reinforce the existing obligations on a public authority to ensure appropriate records management provisions of third-party 'contractors' carrying out functions on behalf of an authority under s.3(2) of the Act?
The Forum met for the first time on 25 July. The next meeting will be on 23 August in the National Records of Scotland and a final meeting is scheduled to take place on 3 October in the offices of North Lanarkshire Council in Motherwell. The Keeper will submit the proposed new Model Plan for public consultation in the late autumn. The Keeper will then consider all consultation responses and aim to publish a final version of the revised Model Plan in the spring of 2019.
The minutes, notes and speaker slides from Forum meetings are published for consultation below. Please forward comments and suggestions to: [email protected]. The assessment team will collate any comments and submissions received and present these to Forum members for inclusion in their deliberations.
Model Plan Consultation – now open
Following on from the work of the Stakeholder Forum over the last few months it was recognised that some textual changes were required to clarify what each element of the Model Plan asks for, supported by the addition of best practice guidance under each element. This is reflected in the revised Plan. Furthermore, the revised Plan promotes our data protection obligations more obviously throughout the text and in relation to each element where relevant. Stakeholders were particularly keen that the revised Plan should include explicit reference to public records created by third parties under contract to a named public authority. This has been accommodated by adding a new element to the Plan.
The Model Plan is statutory guidance required to be developed and published by the Keeper under the Public Records (Scotland) Act 2011 to aid public authorities in the development of robust Records Management Plans. S8(2) of the Act requires him to consult authorities and other persons he considers appropriate and have regard to their views in response to this consultation. He has therefore published the revised Model Plan for formal consultation. This can be accessed by clicking on the following link.
The consultation will close at 17:00 on Thursday 7th March.
The Keeper encourages all those with an interest in the Model Plan to participate in the consultation and record their views on the amendments being proposed.