File Retention Periods – Corporate Affairs

This page was last updated on 25th August 2022

Forward

The main aim of this document is to list Corporate Affairs Information Assets and suggest suitable file retention periods for associated content. Retention periods follow current Agency guidelines as set out in Annex 1. Additionally, we have considered the approach taken by the Centre in respect of FOI, EIR and DPA cases and aligned our retention periods to match where it seems appropriate to do so.

List of Information Assets considered

Forward

List of Information Assets considered

• Asset: FOI / EIR Cases; PQs, TO’s and other ministerial correspondence; Subject Access Request under DPA; complex general enquiries; Fuel Consumption enquiries
• Asset: Dangerous Goods Seminar
• Asset: Customer Satisfaction
• Asset: POS Customer details
• Asset: Car Fuel Consumption and CO2 database / Van Fuel database
• Asset: Average Emissions database
• Asset: Advertising Advice
• Asset: Advertising Infringements
• Asset: Advertising Publications
• Asset: VCA Corporate Website

Asset: FOI / EIR Cases; PQs, TO’s and other ministerial correspondence; Subject Access Request under DPA; complex general enquiries; Fuel Consumption enquiries

About the Asset:

Documents exist in multiple MS Office formats and stored on the Corporate Affairs Network Drive; and Web Outlook applications. Handling processes are available in Q-Pulse.

Case Management processes are currently shared between the XRM (FOI, EIR and DPA cases); ELog (PQs and TOs); and a spreadsheet for complex enquiries. We hope to amalgamate all streams into a single Case Management system shortly.

Fuel Consumption enquiries that are complex or noteworthy will also be amalgamated into the singe database with the aim of creating a single “Enquiries” Asset.

Retention:

Guidance on The National Archives (http://www.nationalarchives.gov.uk/information- management/manage-information/policy-process/disposal/advice-on-retention/ suggests that we aggregate information into three categories, i.e.

• short – for example, up to two years
• medium – up to eight years
• long (time period unspecified).

In respect of FOI, EIR and DPA, DfT(c) have told us that they are also using these terms as follows:

• Short term (3 years);
• Medium term (7 years); and
• Long term (20 years);

Suggest that VCA follow DfT’s lead here and adopt their terms and the time periods assigned to each of them. A description of the case types that would fit into these categories are as follows:

Short term – 3 years retention

This would only apply to simple cases. For FOI, EIR and DPA cases, it would be those cases that were either allowed or refused and had not been appealed, nor had an effect on policy decisions going forward. For Fuel Consumption and other enquiries, again, straightforward requests and responses that did not impact on policy.

We would record the original question and final decision within the CRM (or similar database), redacting personal data after three years. In that way we would retain the basic information indefinitely, less any personal data in order to help build a knowledge base. All documentation outside of the database however, would be deleted after 3 years. Suggest that all Round Robins are treated in the same way, i.e. we keep a record of the question and answer (where notable), with correspondence being deleted after 3 years.

The term ’notable’ applies to enquiries where consultation with technical colleagues or senior managers is required in order to arrive at a decision. Those that require little or no consideration, e.g. misdirected enquiries; requests that can be answered by pointing the enquirer to a web resource; or short telephone conversations are not routinely recorded.

Medium term – 8 years retention

Where an FOI case was appealed either internally or with the ICO, documentation would be held in its entirety within a discreet folder. PQs and other ministerial correspondence dealt with directly by VCA should also fall into this retention period. Prior to deletion, a record of the questions and answers raised – both in the original request and to conclusion of the appeal would be recorded, again less any personal data.

Some more complex enquiries may also need to be kept for 8 years

Long term – 20 years retention

Where a case might affect VCA policy or had a political dynamic, the retention period should be set at the highest figure.

Database records with summary information are designed as a knowledge resource, so should be kept as long as relevant / required and reviewed after 20 years.

Some other correspondence may also require a longer retention period.

Reviewing and deleting files

Deciding on the retention period should be the responsibility of the Corporate Affairs Manager. Initially, assume a retention period of 8 years until the case is complete. This period should then be reviewed on completion of the case and documents suitably marked or a case note included. The Corporate Affairs Manager should then oversee the copying of the questions and answers onto a suitable database such as the CRM prior to deletion. The database record will include very basic, non-personal information about the case to include the date of receipt; date of issue; questions raised; answers provided and date on which the case was deleted.

When the Corporate Affairs Manager is satisfied that the case record is complete, he will delete all associated records and make it clear on the published disclosure log that this is the case.

Asset: Dangerous Goods Seminar

About the Asset:

VCA receives a mailing list from the Scottish Qualification Association (SQA) annually. This is a complete list of all current Dangerous Goods Safety Advisors (DGSAs) in the UK. From 2018, SQA will be asked to confirm that the contact details provided are being done so legally, i.e. permission has been sought and given for personal data to be passed to VCA to be used for sending invites to the DG Seminar.

VCA also keeps its own list of attendees from previous years, used to send out invites.

While the current Asset concerns itself with the mailing list, the full process for managing the DG Seminar includes contracts with suppliers, obtaining copies of presentations (owned by named presenters) and various other types of correspondence.

Retention:

Other than the following, those documents that relate to the setup and management of the event should be deleted after two years. Exceptions are:

• SQA Delegate contact list – replaced each year, so not to be retained beyond the period required and for no longer than 12 months;
• VCA Delegate contact list – should not be deleted in its entirety, rather we should only keep the last three years’ worth of contact data and remove anything older;
• Contracts – such as those with the venue and AV providers should be retained for 12 years (in line with Agency recommendations)
• Admin spreadsheets provide a history of the costs and allow comparisons to be Copy key information onto the most recent version for stats purposes before deleting after 12 months.
• Presentations should be deleted each year – just prior to the current year
• The wash-up report should be retained for 8 years (Feedback will be included).

Reviewing and deleting files

No special requirements needed. A data sharing agreement with SQA may be needed in 2018/19, so may impact on this.

Asset: Customer Satisfaction

About the Asset:

The Customer Satisfaction survey is carried out each November / December using information provided by Finance colleagues and operational branches. The Asset comprises of internal emails, a list of our customers showing who will be canvassed for their opinions and the feedback information provided to us at the end of the process by the third party provider – Metra Martech.

Retention:

Along with the Admin spreadsheet and Master customer list, email items in the ‘Products’ sub- folder should be retained for 8 years. This includes the final spreadsheet from Metra Martech, annual report and PowerPoint presentation.

Standard letters to be repurposed annually and should only exist for the current survey year

Emails relating to the management of the annual survey event should be deleted after two years. Exceptions are emails to customers following direct feedback from the survey which should be held for a period which is appropriate to the subject as set by the department responsible for dealing.

Reviewing and deleting files

No special requirements needed.

Asset: POS Customer details

About the Asset:

Corporate Affairs keep a number of records on Customers who have chosen to use the VCA Point of Sale system to produce labels and posters.

Retention:

Correspondence around the data which underpins this work is covered under recommendations for handling information on the Car Fuel Consumption and CO2 database.

Correspondence with manufacturers managing the contract (may be treated as contractual), hold for 12 years (duplicate invoices and Purchase Orders etc. will not be held by Corporate Affairs).

Correspondence with dealers regarding the availability of vehicles on the database – hold for 2 years. Simple requests for login details etc. need not be held.

System development request from certain manufacturers – hold for as long as the contract is running or 12 years as this may be treated as a contract variation.

Labels – current masters kept for as long as needed. Redundant versions, keep for 2 years.

Templates for labels, used-car labels and posters, keep current versions for as long as required. Superseded versions to be deleted after 2 years.

Reviewing and deleting files

No special requirements, although this is a live rolling list, so responsibility for maintaining it lies with the Manufacturer, although responsibility for holding the information remains with VCA. Suggest we send out a request every six-months to manufacturers asking that they review their list of dealers.

Asset: Car Fuel Consumption and CO2 database / Van Fuel database

Submissions from Manufacturers – spreadsheets and individual requests to add or remove information from the databases (Car and Van). Hold for 8 years to allow auditing of the historic database.

Correspondence with the central DfT where policy discussions exist, hold for 20 years Project discussions e.g. WLTP – hold for 8 years after the go live date

Fuel consumption text – redundant versions to be deleted after 2 years Correspondence otherwise to be kept for 2 years

Reviewing and deleting files

No special requirements.

Asset: Average Emissions database

Data provided by the DfT(c) and / or vehicles manufacturers to allow VCA to calculate Average Emissions and levy excess emissions premiums. Personal data will include manufacturer contact details and the full VIN number (determined to be personal data once the car has been sold).

• Hold each year’s full dataset for at least one year following publication to allow appeals to be completed, but otherwise no more than 2 years from the publication date.
• Versions of the data published for public consumption should be retained on the appropriate website, or otherwise archived elsewhere for 10 years to allow longer term comparisons to be made.
• Correspondence with the central DfT – where those policy discussions exist, should be held for no longer than 8 years;
• All documentation in relation to Appeals against excess emissions premiums to be kept for 8 years following resolution;
• Other correspondence, for example with manufacturers in relation to data submissions, to be held as long as required but typically, for no more than 2 years :
• Project discussions – hold for 3 years after the go live

Reviewing and deleting files

No special requirements.

Asset: Advertising Advice

No active enforcement, but advice given periodically. Correspondence and examples to be held for 8 years from the date advice was given.

Reviewing and deleting files

Before deleting, keep a record of the question and answer and where relevant, also include any notes that may help future readers to understand how the answer was arrived at. Ensure than any and all personal details and other identifying information (such as the company name) are removed from the record.

Asset: Advertising Infringements

VCA do not currently have an active enforcement role. All exiting communications are in the process of being archived and will be held as a group of files for 8 years from the date of the last document.

Reviewing and deleting files

No special requirements.

Asset: Advertising Publications

Covered under Advertising Infringements. Erroneous Asset Register entry to be deleted.

Asset: VCA Corporate Website

Asset includes the following content:

• HTML content – held within the Content Management System (CMS). Backups of HTML pages are not created for the purposes of creating a change record, although they will be available from the Internet Archive, “Wayback machine”. Some complex information relating to Type Approval is managed through Q-Pulse (ref no. prefixed “WEB”) and subject to an annual
• Linked PDF files owned by other areas within VCA and managed through Q-Pulse. All documents managed through Q-Pulse are owned by the relevant area within the Agency, but any document not reviewed at the correct interval will be removed from the corporate
• Images – held by VCA within the content management system and on the ‘R’ network These are available as a library resource and removed only where
• A) the image was created by a third party and the license is no longer valid;
• The image can be classed a personal information which is no longer required, so there is no reason to keep it
• The image is known to be unusable or will not be suitable in the future, in which case it will be

The following tasks are also carried out by Corporate Affairs:

• Infrastructure – technical changes are made by a third party software engineer. Corporate Affairs manage all aspects of the contract; are responsible for the content displayed within the website; and accessibility issues under the World Wide Web Consortium (W3C);
• Hosting requirements, e. ensuring availability of the site and planned downtime, as well as overseeing the server management process.
• Reviewing and deleting files