This Guidance Document is designed to assist Scottish public authorities create a records management plan (RMP) that is sufficiently robust to receive the agreement of the Keeper of the Records of Scotland (the Keeper). It provides links to published best-practice and sample documents that an authority might adapt for their own purposes. Samples are for ‘inspiration’ only, and should not be taken to represent the current procedures operational in any authority.
This guidance has been prepared by the National Records of Scotland in consultation with a cross-section of bodies affected by the Public Records (Scotland) Act 2011 (the Act). The guidance is not prescriptive, but is designed to be used in part, or adopted wholesale, as public authorities think appropriate.
As well as samples, this document occasionally provides links to guidance created and published on the websites of other organisations. The National Records of Scotland has no control over this material or when and how often it is amended or updated. You should be aware that, while we will make every effort to keep our Guidance Document up to date, it will not be possible to guarantee that links are to the latest versions of any external document.
The Keeper is committed to helping public authorities comply with the Act. If, having consulted this guidance, an authority is still unsure of what is required, they should contact the Keeper’s implementation team.
About the Public Records (Scotland) Act 2011
1. What is meant by the “form” of the Records Management Plan (RMP)?
The Keeper is statutorily obliged to issue guidance on this aspect of the RMP because authorities may wish to use a variety of media when submitting an RMP to the Keeper for consideration and agreement.
While it is expected that most scheduled authorities will chose to support their plan digitally, it may be the case that a paper copy (or in some other format) will be necessary or suitable. The Keeper wishes to be flexible in approach regarding this and will consider all formats on a case-by-case basis.
Similarly, it is expected that most authorities will choose to submit the supporting evidence for their plans, for the Keeper’s consideration, in digital format. However, the option to do this by some other means remains open to the Keeper and authorities to mutually agree.
2. What is meant by the “content” of the RMP?
There are certain elements of records management provision that the Keeper will expect authorities to address, and clearly evidence, in their RMP.
These elements are explained in the Keeper’s Model RMP. This can be followed by authorities without modification if it fits their circumstances, or by amendment to suit their records and their particular business needs. The Keeper’s Model Plan has been issued following extensive consultation with public authorities and others affected by the legislation. You can view the Model Plan.
Under the terms of the Public Records (Scotland) Act 2011, the Keeper is required to publish guidance so that the individual elements of the Model Plan can be readily understood by all who are obliged to produce a RMP, and to help authorities make accurate and sensible decisions on what their own RMP should contain. It is also vital that authorities understand what is expected of them under each element of the RMP. This is of critical importance because it may be that for some bodies not all the elements of the model RMP will be relevant.
Evidence
In order to agree the records management plan (RMP) of a public authority, the Keeper must be satisfied that the policies and procedures explained in the plan are in fact operational throughout an authority. To do this, the Keeper will ask that an authority submits evidence that supports the claims made in their RMP.
The nature of this evidence will depend on the individual authority. The ‘evidence’ section under each element in this guidance is not prescriptive nor is it comprehensive.
There are, however, some points that scheduled authorities should consider before submitting evidence to the Keeper:
- The single most important piece of evidence that the Keeper would expect to see with each RMP is the sign-off of a senior accountable officer from the authority. This aspect of the RMP (Element 1 in the Model Plan) is mentioned specifically in the Act (1 2(a)i) and is therefore compulsory for its agreement.
- If an authority’s RMP refers to a formal policy document, the Keeper would expect to see a copy of that document and expect to see evidence that the policy is approved by a relevant accountable officer. It is accepted that, in some specific cases, access to documents by the Keeper’s assessment team might be restricted. An explanation of this, again approved by the senior accountable officer, would suffice.
- Submitted evidence should not be created solely to comply with the Public Records (Scotland) Act 2011 (the Act), but should be drawn from current records management policies and procedures.
- A records management self-assessment exercise, as advocated by the Keeper, would generate evidence that might be submitted in support of an authority’s RMP (see below). The self-assessment programme is not however, in itself, a substitute for a RMP.
- The Keeper does not require multiple copies of similar evidential documents. One robust piece of evidence should suffice. For example, a single sample contract, might be used as evidence of the type of arrangement that would apply to all comparable contracts.
- Please do not send the Keeper, as evidence, documents labelled ‘draft’, ‘business case’ or similar. The Keeper can only consider documents that appear to be final and approved.
