1. Records Management Code of Practice for Health and Social Care 2016
Sarah Graham, NHS England, 28th April 2017

2. Introduction
Main focus of the presentation - key messages within the Information Governance Alliance Code of Practice
Brief case study - how NHS England applied the Code of Practice
Questions / discussion
….but happy to take queries during the presentation!

3. Background
The Code of Practice replaces the Records Management: NHS Code of Practice parts 1 and 2 (2006) that had previously been produced by the Department of Health
This Department of Health guidance was very good and detailed but was due for a refresh
The new guidance has more focus on electronic records and has a reduced retention schedule
User friendly and has practical case studies
Main section, three appendices – final third appendix concentrates on retention schedule pgs 53-80
The Code was drafted by a working group of representatives from the Information Governance Alliance, the Health and Social Care Information Centre, NHS England, the Department of Health, The National Archives and from a range of NHS and social care organisations, including Acute and integrated Mental Health Trusts, Clinical Commissioning Groups, GP practices and professional bodies.

4. Section 1: Regulatory Framework
Pgs 6 – 11
NHS records – patient records, corporate records
The framework is based on established standards Concerns records regardless of format
The Public Records Act 1958 – all of us in this room are affected by this act!
DPA / FOI
The Academy of Medical Royal Colleges (AoMRC)
Training / Policy required
The Public Records Act requires that all public bodies have effective management systems in place to deliver their functions. For health and social care, the primary reason for managing information and records is for the provision of high quality care.
AoMRC provides guidance for standards of medical records specifically.
Organisations advised to have suitably trained RM staff and to have adequate policies and procedures in place.

5. Section 2: How to Manage Records
Pgs 12 – 25
Bread and butter of what the people in this room do!
Lifecycle, records system
ISO & DIRKS,
Cabinet Office e-Government Metadata Standard v
Cabinet Office Government Security Classifications April 2014
Storage, maintenance, retention and disposal
I don’t propose to dwell for long on this section as this is an area that people in the room will be well versed in – this section is more generic about RM standards rather than purely NHS features of records. Very useful summary of records management and records management principles. My belief is that a new starter in RM should take a look at this 14 page section as a starter for 10.
Designing Information and Recordkeeping Systems

6. Section 3: How to deal with specific types of records
Pgs 26 – 40
Specific to Health and Social Care records
Section on Lloyd George papers is causing some issues within GP practices
The Good Practice Guidelines for GP electronic patient records Version 4 (2011)
Contract closure guidance
Prison Health Care / Youth Offenders Institutions
Complaint records
Useful information Pg 28 on corporate records
s guidance / scanning guidance
NB: NHS England cannot advise GP surgeries whether to destroy paper and purely digitise – it is a risk assessment on the part of the GP to consider if the electronic record is complete. If so, they may choose to destroy the paper version. However, this is their decision to make, not for NHS England to advise.
Contract closure has been proving challenging!
Hybrid system in place at prisons / YOIs.
NHS England inherited some complaints records from PCTS and SHAs – kept separately from patient files.
Generic and scanning guidance is useful to all organisations.

7. Section 4: Retention Schedule
Pgs 41 – 48
Retentions are minimums – therefore, if there is a proven business need, then records could be kept for longer than the recommended minimum
Access via DPA and Access to Health Records Act
Pages 45 – 49 contains a useful list of records which may be held in health and social care settings
Organisations could use the list to ensure that all these records are covered in their retention schedule
DPA for living individuals, AHRA for deceased individuals (access limited to certain people – designate rep or someone with a claim on the estate).
NHS England retention schedule has just been refreshed by referring to this list and to the retention schedule available later in the document.

8. Useful Websites and Links
 Pgs 49-50
Useful resources list that could be used in developing a new member of RM staff as well as a useful glossary for seasoned professionals.

9. Appendix One: Acknowledgements
Pg 51
Many RM professionals involved in the development of this piece of guidance
Some members of the reference group may be in this very room!
Colleagues at NHS England and National Archives known to me and I have benefitted greatly from their knowledge and expertise. A certain Emily Overton too….! 

10. Appendix Two: Standards
Pg 52
Another useful list that is worth having a look at whether new or experienced RM practitioner

11. Appendix 3: Retention Schedule
Pgs 53 – 80
Schedule is significantly stripped down from the previous code of practice which dated back to 2009
Pg 79 Complaints retention is set at 10 years (was previously 8 years)
Pg 79 FOI requests retention where there has been an appeal is set at 6 years (was previously 10 years)
Not many significant deviations from previous guidance available (i.e. Code of Practice).

12. NHS England Implementation
Our key move was to align our Records Retention and Disposal Schedule to reflect the guidance – Version 2.0 published in January 2017
Some key areas had changed in terms of retention (e.g. complaints) Corporate Records Manager visited the team to ensure that paper / electronic systems were adjusted accordingly to reflect the July 2016 change in guidance.
Reflect guidance within the Records Management Policy – new Version 4.0 of the Policy just being ratified at the moment
NHS England also advertised the new guidance to all staff via the comms mechanisms such as ‘Engage’, Records Management Co-Ordinators meetings.

13. Questions / Discussion
For more information, please contact: Sarah Graham, Corporate Records Manager, NHS England: