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June 2016 Trust in water

Retention and disposal policy

www.ofwat.gov.uk

Information and records management policy and procedure OFFICIAL – SENSITIVE [if necessary]

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Introduction

This policy supports the classification and protection of Ofwat’s information assets to

ensure it fulfils its statutory duties, manages and mitigates risks to its assets. As a

public body, we have a duty to retain proper records of our activities. This duty does

not, however, require us to retain all information indefinitely. The guiding principle is

to retain information that allows key regulatory decisions to be explained.

Scope

This schedule covers the whole of Ofwat’s information, both electronic and paper. (It does not include any non-Ofwat documents we hold unless listed in Appendix 1) Retention periods for paper records are the same as for electronic records, although the methods of disposal will differ. The retention schedule assists the:

meeting our legal obligations regarding which records to keep and for how long;

provision of Ofwat staff with the information needed to make correct disposal decisions;

reduction of storage costs; and

improvement of the security of information. This policy is mandatory and applies to all information in all formats through all stages of an information lifecycle from creation through to disposal.

Roles and responsibilities

The retention period includes the time individual documents are kept both in the office and in archive. Once this date has expired, all documents, including paper and electronic, should be reviewed for disposition. Information Asset Owners will be responsible for applying the retention and disposal policy to these documents and ensuring the Master is retained for the appropriate length of time. Where third party providers and suppliers engage with Ofwat and have access to information. It is the responsibility of Ofwat to ensure appropriate return or disposal of Ofwat information. This will be embedded into any information sharing agreements.


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Disposal

All documents that are considered sensitive will be placed in the confidential waste

bins. Other records not deemed sensitive will be recycled.

The retention and disposal schedule in Appendix 1 will be used to identify records be

for disposal.

Records will be destroyed in a timely and controlled manner when the appropriate

retention period has been met. All records will be reviewed prior to destruction.

On an annual basis records will be reviewed and culled for disposal.

Where only a year date has been provided, it will be considered 31st December of

the applicable year and will fall into the catchment of the following January disposal.

e.g. any records that are due for disposition in 2016 may not be destroyed until the

January 2017 cull.

Documents that can be disposed of without reference to Appendix 1

Working documents, such as drafts, notes, local copies of meetings when no longer needed. (Note that drafts should be disposed of once a final version of a document is published.)

Duplicates – any document where a master copy is held elsewhere. This includes any printed material from electronic systems. If available electronically, the electronic copy is the master copy including scanned records.

Ancillary records or ephemeral documents, for example notices of meetings and events, announcements, invitations and acceptances, internal administrative requests, facilities bookings and marketing materials.

Conference and training materials – these should only be kept while relevant to current work or personal development. Copies can be destroyed when no longer needed.

Local copies of performance agreements and documentation on individual members of staff should not be kept for longer than is necessary. Master copies are held by the People Hub.


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Records needing permanent retention

A number of Ofwat records will be held in perpetuity under the terms of the Public

Record Act. The following documents are transferred to The National Archives (TNA)

according to the Operational Selection Policy (OSP 47). Note that since 2002, the

TNA acquires web publications by the regular capture of Ofwat’s website.

Annual reports (held by House of Commons Library and British Library);

consultation papers;

investigations;

letters to Managing Directors;

letters to Regulatory Directors;

position papers (Ofwat policy statements);

reports commissioned by Ofwat and published;

reports on water companies (annual comparative reports which were published);

submissions, responses, evidence (policy statements to other government departments, or witness statements to the Competition Commission which were published)

Board minutes and papers (includes any draft papers discussed at meetings);

Executive Team minutes and papers (includes any draft papers discussed at meetings); and

price review and interim determinations (final determinations document, methodology paper and financial rule book and IDOKs).

Any queries will be directed to the Information and Records Manager.

Classification and retention schedule

Record series The type of record to be retained

Retention period How long Ofwat will keep this information (applies to all master documents kept on site and in archive regardless of medium)

Derivation The reason for the retention period

Notes Any notes applicable to the retention of the records and their disposition

Monitoring arrangements

Area for

monitoring

How Who by Reported to Frequency

retention annual culling of records

Information and Records Manager

SIAG Annually

http://www.nationalarchives.gov.uk/documents/osp47.pdf


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Links to any associated documents

Information and Records Management Policy and Procedure

Information and Technology Security Policy

Information Risk Policy

Government Classification Policy

Handling Market Sensitive Information Guidance

IT Acceptable Use Agreement

Ofwat Code of Conduct

Assurance for 3rd party information sharing agreement

How to Guide: Handling commercially sensitive information

Data Protection Policy

Freedom of Information Policy

Access to Information Policy


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Appendix 1

Record series Retention

period

Derivation Notes

Finance and Governance

Fountain (inc. previous systems such as Water 2000, Reservoir etc)

Permanent

Security Emergency Measures Direction (SEMD)

Permanent

Finance and Governance Programme files -

Close of programme

Review to see whether there is any value to retain any further.

IDOKs

Previous Price Reviews (This includes: submissions, periodic reviews, business plans and June returns)

Acceptance of final determination plus 3 price reviews

Business best Review to see whether there is any value to retain any further

Legal

Official Register Permanent S.195 Water Industry Act 1991

Must be made available for public inspection.

Legal Advice Last action/entry plus 10 years

Business best

Licences Information

Maps Permanent S.195 Water Industry Act 1991

Must be made available for public inspection.

Litigation Case close plus 15 years

Business best

People Hub

Payroll Last action/entry plus 6 financial years.

Limitations Act 1980

Main Personnel file (inc. Cascade)

End of employment plus 6 years

Limitation Act 1980, c. 58, s. 5

Summary to be retained until the 75th Birthday whichever is sooner.

Bonus Data

Pensions starter form & calculation data.

Last payment plus 6 years

Full pensions records kept by MYCSP.

Finance (Compliance and Assurance)


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period

Derivation Notes

Board/SLT financial reports, Programme financial reports, Pool financial reports, transactional listings

iPOS purchase ledger records (Requisitions, Purchase Orders, Goods Receipts and Invoices)

Last action/entry plus 6 financial years.

Limitations Act 1980 & http://www.nationalarchives.gov.uk/documents/information-management/sched_accounting.pdf

Expenses@Work financial records (employee expenses, GPC transactions, Redfern Transactions)



Financial ledger data (Sun Systems), this includes Ofwat's Asset Register

Manual Accrual and prepayment records

Employee bank details Until no longer required

Supplier bank details Until no longer required

Sales invoices and supporting calculations



Routine journals



Tax records



HMT returns


Limitations Act 1980 & http://www.nationalarchives.gov.uk/documents/information-

http://www.nationalarchives.gov.uk/documents/information-management/sched_accounting.pdf





























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period

Derivation Notes

management/sched_accounting.pdf

Transparency Reporting



Casework

CMO

Case files - evidence, information on cases and evidence for key decisions

Process and procedures

Draft and Final Determinations

CMO Enquires and responses.

Programme management records - Project Diaries, Dashboards, Delivery, Int/Ext expenditure summaries and Programme Board papers

Strategy and Policy

Supply & Demand Last action/entry plus 1 year

Business best Delete

Learning and Development plan and associated correspondence

Last action/entry plus 1 year

Business best Delete

Water 2020

Consultation on licensing and policy issues in relation to the opening of the non-household retail market

PR14 reconciliation rulebook

Evidence to the CMA - Bristol Water's price controls for 2015-20

Towards Water 2020 – meeting the challenges for water and









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period

Derivation Notes

wastewater services in England and Wales

PR14 Lessons Learned

Consultation on charges scheme rules for 2016-17 and future developments

Consultation on initial proposals for areas for regulatory change in PR19

Water 2020 consultation - Design Decision & Impact Assessment

Non-Household (NHH) re-opener Methodology

Markets and Regulation (MAR): Methodology Condoc

Non-Household (NHH) re-opener: Company plans

Non-Household (NHH) re-opener: Draft determinations

November Condoc

Section 13 document

Licencing consultation

Analytics

Fountain Permanent Business best Joint asset with Finance and Governance

Portfolio Management Office


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period

Derivation Notes

Strategic risks and opportunities framework

Risk and opportunities strategy

Ofwat Risks Appetite Statement

Board minutes and papers

SLT minutes and papers

Procurement evaluations

Freedom of Information & Environmental Information Regulation requests

Last action/entry plus 5 years

Business best Review for internal views and tribunals

Subject Access Requests

Last action/entry plus 2 years

Business best Review for internal views and tribunals

Procurement specifications and awards

Governance Framework

Board rules of procedure

Infrastructure and technology

Journal

Archived Email accounts

Archived H Drives

Back up tapes (Weekly, Monthly and Annual)

Last action/entry plus 13 months

Delete/Overwrite

CCTV Not in scope Not in scope Not owned by Ofwat. Owned by building managers.

Business transformation

Programme - Delivery, Governance

& People Pillar inc. Business Cases, Programme papers, Project docs inc. tech design, quotes, strategy, products.

Closure of individual projects plus 6 years

Transforming Ofwat Infographic


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period

Derivation Notes

Transforming Ofwat Hexagon Toolkit

Information Library

Business Transformation 'Tube Map'

Programme Management Library

Communications

Intranet

Internet

Social Media interactions

Social Media direct messages

Corporate (all pools and programmes have this asset

Local Personnel Files (DDCs, 121 Notes etc)

Pass to People Hub to merge with main file once employee leaves.

Voicemails Delete once actioned

Dashboards

Document control

Version history

Version Status Date Author Summary of changes

0.1 Final Draft

June 2016 Emily Overton

First draft for review

Sign off

Name Date Version No. Date of Next review


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