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Document Retention Policy *

1 . Information:

1.1) This policy relates to records (including electronic data) belonging to StreetVibes (SV) and applies throughout the Company, including, where appropriate,

its subsidiaries and partner organisations as defined in paragraph 2.7.

1.2) This policy is formed of two parts: this document sets out the general principles and responsibilities while the Records Retention Schedule , as defined in paragraph 2.4,

sets out the length of time records should be retained.

1.3) Records, as defined in paragraph 2.1, are a vital asset required by SV to support its daily functions, policy formation and decision-making; they protect its rights and those of its staff,

students and others and they form the corporate memory. The management of records is therefore imperative and SV recognises the importance of this activity.

1.4) The purpose of this document retention policy (and associated retention schedule and procedures) is to promote best practice in records management in order to

protect the interests and support the core functions of the Company by ensuring the consistent and orderly maintenance and retention of adequate,

unaltered and accurate records for the appropriate periods of time to satisfy relevant statutory and contractual legal, financial,

operational and research requirements. It is also to ensure the prompt and confidential disposal of records when such requirements have ceased so as to avoid

unnecessary costs relating to records maintenance or any possible liabilities. SV also desires to comply with the Lord Chancellor’s Code of Practice

issued under s.46 of the Freedom of Information Act 2000 to enable it to comply with its statutory obligations under the Act.

1.3) This policy is subject to the laws and regulations of relevant jurisdictions and may be modified and supplemented from time to time.

Other policies may be relevant in relation to records retention (see appendix 1 for a non-exhaustive list).

Definitions:

2.1) Records are defined as “information created, received, and maintained as evidence and information by an organisation or person,

in pursuance of legal obligations or in the transaction of business” (ISO 15489-1:2001 s.3.5).

2.2) Recorded information includes documents and data and can be in any format or media, including paper, film and digital or electronic media

(see appendix 2 for a non-exhaustive list of possible formats). This policy applies to recorded information in all possible formats.

2.3) Records management includes the processes for implementing records retention and disposal, storage and retrieval, in accordance with this policy and associated retention schedule and procedures.

2.4) A records retention schedule is a document (e.g. list or matrix), tailored for a particular entity or department, describing the different records series belonging to each function of that entity and specifying the appropriate retention period for each, as determined by legal and other relevant requirements.

This retention period may include the starting point for its calculation, the length of time and what action should be taken when the period expires.

The Records Retention Schedule forms part of this policy.

2.5) A records series is a group of similar or related records which serve a common purpose or function and have the same retention period.

(Examples of records series are employee personnel files, accounts payable invoices, exam papers).

2.6) References to “partner organisations” include any partner organisations and any third party service providers who are contractually obliged to maintain records on the

SV’s behalf in accordance with this policy.

Principles:

3.1) Records that are created or received and maintained by SV employees - and those working for the Company as contractors or in partner organisations - in the course of their business activities,

are deemed to be records belonging to SV. This applies whether or not the records are held on SV premises.

3.2) Company records are a valuable resource as sources of information for re-use and as evidence of actions, rights and obligations.

However, records that are out-of-date, inadequate or unnecessary can be misleading and can impact storage / retrieval capability and costs without corresponding benefit.

3.3) To manage this resource, each department may have its own adapted procedures covering retention and disposal

storage and retrieval of its records which are implemented consistently and updated as necessary.

3.4) During their retention period, records may be held in different locations and on different media depending on operational efficiency but should always

be properly managed in accordance with this and other policies.

3.5) The majority of records will eventually be destroyed, however, the small proportion of records and artefacts deemed to be of permanent legal or historical

significance may be preserved in SV’s historical archives facilities.

3.6) Retention policies for different series of records should be decided on the basis of any relevant legal requirements and a consideration

of the value of the records for operational reasons both now and in the future.

3.7) Retention policies should be decided in consultation with the owners and users of records. If necessary, expert advice should be sought from appropriate external legal sources.

3.8) Retention policies should be the same for the same type of recorded information regardless of media

(i.e. information retained only in digital format should be retained for the same period as it would be kept if in paper form).

However, it is not necessary to retain duplicate copies of the same record, nor to retain both paper and electronic versions, for the same period.

Retention arrangements for electronic records should ensure that they will remain complete, unaltered and accessible throughout the retention period.

3.9) Operational retention requirements should be based on an assessment of the value of the information, taking into account the need for evidence of processes,

the probability of future use and the consequences if the information were not available.

Information value and reference rate usually decline over time so a decision should be made as to the point the records are likely no longer to be required.

3.10) Retention policies for different series of records should be codified in records retention schedules compiled on a functional

or departmental basis and regularly implemented and updated by staff with records management expertise.

Responsibilities:

4.1) Ultimate responsibility for compliance with this policy shall lie with the SV Managing Director.

4.2) The Managing Director is responsible for drawing up guidance for good records management practice, procedures and promoting compliance

with this policy as well as maintaining the master Records Retention Schedule.

4.3) Within each department a specific person should be responsible for managing the consistent implementation of the records retention policy.

This person should make available to other employees the relevant policy, procedures, retention schedules and advice.

S/he may also manage the provision of records storage and/or media conversion. S/he may also be responsible for notifying the owners

of records when they have reached the end of their retention period, making sure that a disposal or continued retention decision is made

and documented and that records no longer to be retained are destroyed or deleted confidentially and completely. Employees within

SV with records management responsibility are encouraged to share their knowledge and experience.

4.4) Line managers and supervisors must ensure that their staff are adequately trained and are made aware of the key principles of this and related policies.

4.5) All employees are responsible for ensuring that accurate and adequate records relating to their areas of responsibility are maintained.

They are also responsible for records inherited from predecessors in their role. They are also responsible for the disposal or storage of their records

when they cease to be in regular use. This should be done in compliance with the relevant records retention schedule. If these procedures are delegated,

appropriate guidance and controls should be put in place to ensure records are identified and described adequately and the correct retention periods allocated.

Employees may also be responsible for making decisions when stored records reaching the end of their retention period are referred to them for review.

4.6) Employees who are responsible for authorising the destruction of time-expired records must respond to review requests promptly.

4.7) Where permitted by law, any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

APPENDIX 1: POSSIBLE DOCUMENT FORMATS & MEDIA

This is a non-exhaustive list of possible document and other formats that may be records. It does not include every possible format.

Some formats may be specific to a particular type of media e.g. web sites on digital media; while others may be found in more than one medium e.g. memos and reports may be on paper and/or digital media.

Correspondence/letters
Coursework and exam scripts
Teaching materials
Meetings agendas, minutes/notes, supporting papers
Reports
Presentations (text, slides, charts, illustrations, etc.)
Directives and policy statements
Manuals and instructions
Drafts
Forms
Books of account (or equivalent)
Financial transactional documents e.g. invoices, statements, etc.
Legal documents e.g. agreements/contracts, deeds, etc.
Press releases
Internal announcements
Intranet sites
Technical drawings (including CAD)
Equipment monitoring/recording records
Photographs, slides, transparencies and digital images
Publications e.g. books, brochures, leaflets
Posters
Advertisements
TV & radio commercials
Film, video and sound recordings
Microfilm and microfiche
Memoranda
E-mails
Text and MMS messages
Instant messages
Voicemails
Word processing, graphics and spreadsheet applications
Specialist business IT applications
Databases
Data warehouses
Websites
Blogs
Wikis
Fixed or removable electronic or optical storage media including:
Desktop and laptop computers
CD-ROMs, DVDs and optical disks
Magnetic tape and disks
Miniaturised high density electronic storage devices e.g. memory sticks
Data held on PDAs (portable digital assistants) and phones e.g. BlackBerrys

APPENDIX 2: LEGAL CITATIONS

The following Acts (or Statutory Instruments) of the U.K. Parliament have been cited in determining retention periods and guidelines.

1957 c.31 - Occupiers Liability Act 1957
1958 c.51 - Public Records Act 1958
1969 c.57 - Employers' Liability (Compulsory Insurance) Act 1969
1970 c.9 - Taxes Management Act 1970
1970 c.41 - Equal Pay Act 1970
1974 c.37 - Health and Safety at Work etc. Act 1974
1975 c.65 - Sex Discrimination Act 1975
1976 c.74 - Race Relations Act 1976
1980 c.58 - Limitation Act 1980
1988 c.48 - Copyright, Designs and Patents Act 1988
1992 c.4 - Social Security Contributions & Benefits Act 1992
1993 SI 744 - Income Tax (Employment) Regulations 1993
1994 c.23 - Value Added Tax Act 1994
1994 c.30 - Education Act 1994
1995 c.50 - Disability Discrimination Act 1995
1998 c.29 - Data Protection Act 1998
1999 SI 3242 The Management of Health & Safety at Work Regulations 1999
2000 c.36 - Freedom of Information Act 2000
2002 SI 2677 The Control of Substances Hazardous to Health Regulations 2002
2004 SI 3391 - Environmental Information Regulations 2004


* This policy was last revised August 2018