An individual senior staff member is identified as holding corporate responsibility for records management.
It is vital that the RMP has endorsement at the highest levels in an authority.
A RMP will require resources to implement and maintain, and therefore the Keeper, in agreeing an authority’s RMP, will need to be assured that it is supported by a commitment at a senior level.
Section 1(2)(a)(i) of the Act specifically requires a RMP to identify the individual responsible for the management of the authority’s public records. It is, therefore, essential that the authority identifies a senior post-holder to take overall responsibility for records management. That person is unlikely to have a day-to-day role in implementing the RMP, although they are not prohibited from doing so.
The identification of an individual is specifically mentioned in the Act (1 2(a)i) and a name must be supplied. Neither a job title (i.e. ‘CEO’) nor a collective body (i.e. ‘XXX City Council’) is acceptable under the terms of the Act.
Current best practice guidance advises senior management to:
- Recognise records management as an important corporate responsibility and give it the appropriate level of priority and authority
- Assign overall line management responsibility for records management to a senior member of the management team. Where an authority has already appointed a Senior Information Risk Owner (SIRO) or similar person, they should consider making that person responsible for the records management programme.
If all information functions are not part of the same command, it is important that the Keeper can be confident that there are close working relationships between them.
Evidence
The Keeper will require evidence to be submitted, confirming the name and job title of the senior responsible officer with overall responsibility for the RMP, which has been submitted for agreement.
The Keeper will write to the CEO (or equivalent) of an authority inviting them to submit the RMP. It would be beneficial if the CEO could respond to the Keeper indicating who the individual at element 1 in the plan ought to be and providing their contact details. In some cases this will be the CEO themselves. In other cases this will be delegated. The CEO should make any delegation clear in a covering letter or a foreword to the RMP.
If it is not possible for the CEO to produce such a covering letter, the individual identified at element 1, who must still hold a senior position in the authority, should provide one. Again, this does not have to be a separate document and may take the form of a foreword to the RMP.
It would also be useful if the covering letter identifies the individual at element 2 and endorses the Records Management Policy statement (see element 3).
If the authority has a Records Management Policy and if that Policy has a ‘roles’ section, the responsibility of the senior officer named at element 1 should be supported.
If the authority has formally allocated responsibilities to each of the elements in their RMP (many have done this, but it is not compulsory) then the Keeper would expect the senior officer to be directly responsible for, at least, element 2. The individual identified at Element 1 retains overall responsibility for records management in an authority, but the individual at element 2 may have delegated responsibility for elements 3 – 15.
