Records Management Handbook

5. Records Management Policies

The OIC Records Management Policies are required to provide guidelines to all OIC staff on the handling of documents and other forms of records. These policies are closely linked to procedures which describe the step-by-step tasks for complying with a policy. Without policies staff may make decisions on the retention and storage of documents and other forms of records that are uncoordinated and which result in inefficiencies and increased resource costs.

It is vital that staff are familiar with and adhere to these Policies.

Filing of Hard-Copy Documents

All hard-copy documents must be filed as soon as it is possible to do so.
All case related hard-copy documents must be placed in chronological order on the appropriate case file.
All other hard-copy documents must be placed on the appropriate Office File, or other as appropriate.
Any queries in relation to the appropriate file that a particular document should be placed on should be directed to the HEO in the Support Unit or to the Records Manager.

Responsibility for Filing of Documents

The person responsible for a hard-copy case file is the official recorded as the "case worker" on the case tracking system.
It is the responsibility of all staff to ensure that they have been recorded as the "case worker" each and every time they take physical possession of a case file.
All documents relevant to a case file should be passed to the "case worker" as soon as possible and that person is then responsible for filing the latest documents received.
As regards non-case related documents, it is the responsibility of the "relevant" official to ensure that documents created and/or received are properly filed and can be readily accessed both physically and electronically.
The "relevant" official is the signatory to a document that originates in the Office or, if the document was submitted to this Office by a third party, the person to whom the correspondence has been addressed. If the correspondence is not addressed to any particular official, if it is addressed to the Commissioner, or if it is sent to the wrong official, it is the responsibility of the person who ultimately deals with the correspondence to ensure that it is properly filed.

Scanning of Hard Copy Documents

All hard copy documents received, except the actual records that are the subject of a review, must be scanned and saved in the appropriate file on the case tracking or other database, as appropriate . Exceptions would be hard-copy documents received that are of no value to the Office, such as innocuous circulars or publications, including documents received in error, that are not being placed on a hard-copy file.
Hard copy documents being placed on a hard copy file must be scanned onto the electronic version of that file thereby ensuring consistency between the two systems which in due course will facilitate destruction of the hard copy version in accordance with the policies that are referred to below.
If hard copy documents are received which are difficult to scan, such as bound publications etc., the Office should request the sender to forward an electronic version of the document. If an electronic version is not available, the cover of the document should be scanned and a "Quick Note" created to indicate that a full version of the document has been placed on the hard copy file.

Logging of General Enquiries

Apart from innocuous enquiries directed to or received by the Office in error, all enquiries dealt with by the Office should be recorded on the General Enquiries database. This would include enquires received by phone, letter, fax, e-mail and from persons who call to reception. Such enquiries should not be recorded as EGENs on the case tracking system.
The General Enquiries database provides for the capture of the name and address of the person making the enquiry, their query and the nature of the answer provided and these should all be recorded to the greatest extent possible. Enquiries received by letter or fax should be scanned onto the database and those received by e-mail should be copied onto the database.
In the case of persons who call to reception or elsewhere to make a face to face enquiry, these details should also be entered onto the database.

Case and non-Case Related Typing Policies

All case related typing should be created and retained in the appropriate case file on the Case Tracking database. No case related work should be created or saved elsewhere e.g. in the OIC Typists General database.
Non-Case related official typing should be carried out in the appropriate folder of the staff member concerned in the OIC Typists General database. All staff members should save any such typing in a folder under their own name within this database. If a record created in the OIC Typists General database becomes official and is finalised i.e. it is issued, published, circulated or retained as a final document, it must be then copied and moved into the appropriate file in the Office Files database and be deleted from the OIC Typists General database i.e. the record should not be retained in two separate databases. Staff should not create draft documents in the Office Files database as this should always reflect the final position of a document. This is not to say that short memos or notes of meetings etc. cannot be created in Office Files but it is important that they are finalised immediately and not left as a work in progress.
Draft documents created in OIC Typists General that are not subsequently finalised should be deleted as soon as the staff member that created the record is satisfied that it will not be required and therefore has no retention value. Deletion of records from the Typists General database can only be carried out by the HEO in the Support Unit or by the Records Manager. Accordingly, when staff wish to delete a record, they should contact one of those persons, preferably by way of an e-mail with a link to the record in question.
All staff also have a Private Typing database which should generally be used only for the creation of personal records. It is important that this database is not used for drafting case related or other official OIC work which other OIC staff may require urgent access to e.g. when staff are on leave etc. Personal records of staff should not be created or saved in any other database, such as OIC Typists General, as all OIC staff have open access to all records in OIC related databases e.g. staff member A can view the content of staff member B's folder in the OIC Typists General database.

Case Work Retention Policies

All review applications received are allocated a case reference number and both a hard-copy file and an electronic case record is created even if the application is subsequently found to be invalid or is not accepted for whatever reason.
As regards records retained electronically on the case tracking system, these records should be retained for a period of seven years. There are two exceptions to this policy. The first applies to the actual decision letter in cases where a decision issued under section 34(2) of the Acts. Decision letters are to be retained indefinitely on the case tracking system. The second exception applies to the electronic records relating to a case that is or has been the subject of a High Court appeal and also a small number of cases that are considered to be of "precedent value" (e.g. the decision taken has been published on our website and may also include a number of reviews given a category 3 ranking by the Investigator).
All hard copy records of both reviews carried out and applications that were not accepted should be destroyed one year after a final decision has been taken. Exceptions to this policy are cases that are or have been the subject of a High Court appeal and cases that are considered to be of precedent value, as per above, hard copies of which should be retained indefinitely.
Apart from cases that have been or are to be the subject of a High Court appeal, the Office will seek to return all of the records that were the subject of a review to the public body concerned eight weeks after the Commissioner's decision or immediately if the case has been withdrawn or settled. If the public body indicates that it does not want the records to be returned, they shall be shredded as soon as possible by OIC staff.

Non-Case Work Retention Policy

An electronic version of all non-case work records must, where practicable, be created. All letters, notes, reports, memos and other records created by staff must be saved, when finalised, in the appropriate electronic Office File or General Enquiries database. All correspondence received from outside of the OIC must be scanned or, if applicable, an electronic version should be sought and saved in the appropriate file.
The electronic version of all Office Files can be retained indefinitely subject to the Personal Data Retention Policy. However, apart from sensitive original documents that may be required to be retained in that format, hard copy records can be destroyed one year after receipt provided an electronic version has been created. Where it was not possible to scan or acquire an electronic version of a record, the hard copy will be retained on file, subject to the Personal Data Retention Policy, for as long as it is considered by a Senior Investigator to be of retention value.
Given that all correspondence in relation to General Enquires is captured electronically, it is not necessary to retain hard copies of such correspondence for longer than one year after the enquiry was dealt with. The electronic record of such enquiries must be retained for seven years and then deleted.

Statistical Records Retention Policy

All statistics generated must be filed both electronically and on the appropriate hard copy file.
All such statistics, apart from those that relate to identifiable individuals, should be retained indefinitely in electronic format whilst hard copy records should be destroyed in line with the general policy of destroying hard copy non-case related records after one year.

Personal Data Retention Policy

Apart from the exceptions referred to under the Case Work Retention Policy, all personal data held in respect of case work should be deleted/ destroyed after seven years.
If any personal records whether hard-copy or electronic, such as statistics generated in respect of identifiable individuals, are held on the Office Files or other databases and are over seven years old, these must be reviewed each year in order that a decision can be taken as to whether they still need to be retained and, if so, whether they can be anonymised i.e. if the record must be retained is it still necessary to identify the person about whom the record relates.

Recording of E-Mails and Faxes Received

All case related e-mails and faxes received electronically must be copied and saved, either by way of clicking on the "Receive" button in the appropriate "Review Details" page or by creating a "Quick Note" under the appropriate case reference on the case tracking database. In the case of faxes received electronically, it may be necessary to amend this policy to provide that all faxes musts be scanned on to the database rather than copied. If this arises, an addendum to this Handbook will be issued.
All attachments received by e-mail must be sent to the IT Unit for virus scanning before being opened.

Destruction of Hard Copy Records

Records that are to be destroyed should be shredded, if necessary by an external firm under appropriate supervision.

Electronic capture of all relevant events

It is the Office policy to electronically capture all relevant events in relation to reviews and also all relevant information in relation to issues that arise which result in copies of correspondence being filed on the Office and General Enquiry filing systems and databases.
Accordingly, annotations, unless innocuous, should not be entered on hard copy records. An electronic (typed) note should be created and saved under the appropriate electronic file thereby ensuring that a record of all relevant events is retained and will not be lost when the hard-copy file is destroyed. If a hand written annotation is made on a record, by the Commissioner for example, then that document should be scanned and saved under the appropriate file before the case is closed.
The case closure checklist provides that the Investigator responsible for a case must ensure that this policy has been adhered to before the file can be returned to the Support Unit.

Back to contents