European Structural and Investment Funds: document retention guidance

Format of documents

2.1. Documents can be retained in any of the following formats detailed below.

2.2. Documents that originate and exist only in their native digital form i.e. so-called ‘born digital’ records such as e-mails, database records, spreadsheets and word processing files etc. This extends to both structured and unstructured records, and includes, for example:

• electronic records management systems
• digital file formats, such as PDF, JPEG and TIF when created and then transmitted digitally
• databases
• video clips
• digital photography etc. 
• electronic/digital versions of original paper documents held on commonly accepted data carriers such as microfilm, digitised/scanned/replica images etc.
• original paper documents

2.3. Certified true copies of an original paper document (as detailed in article 140 of EU 1303/2013). Conditions for accepting documents that originate in electronic/digital form to ensure that the authenticity and integrity of ‘electronic/digital only’ records so that they can be relied upon for legal and audit purposes, you must be satisfied that the ICT/information management systems in place are designed to conform to accepted security standards in the UK.

2.4. You should obtain the relevant assurances on security standards from your ICT/Information Assurance Officer or management team. This approach extends to seeking assurance on records held on the ICT systems of any joint beneficiaries or contracted/third party deliverers holding documents electronically/digitally.

2.5. For the purposes of our verifications and audits, you should keep a document that describes the procedures you have undertaken to obtain the necessary assurances that adequate security standards are in place to rely on the information held electronically/digitally.

2.6. If you are unable to obtain the necessary assurances on the security standards, then the records will not be acceptable for EC/Managing Authority compliance purposes (as detailed in article 140(6) of EU 1303/2013). 

2.7. Conditions for accepting digitised, scanned, replica digital versions of original paper documents:

2.7.1. Lead Partners using scanning, e-archiving or image processing systems (where original paper documents are scanned and stored in digital form) must ensure that certification processes and controls are in place that, at least:

• guarantee that each ‘e-document’ (scanned image) is identical to the paper original

2.7.2. Prevent or detect the scanning of the same paper document to produce several different e-documents of the same original document (each e-document remains unique and cannot be re-used for any other than its initial purpose).

2.7.3. Where the document evidences a financial transaction, the approval, accounting and payment process for each e-document should be unique (it should not be possible to approve, account for, or pay the same e-document twice).

2.8. Once scanned, processes and controls prevent or detect the amendment of e-documents or the creation of altered copies (or amended/altered versions are held as separate versions and the original, unaltered version of the image remains available for audit purposes).

2.9. Verifications and audits may ask to examine the policies and procedures in place to provide assurance of the above certification processes and controls, and may also ask to observe the scanning and certification process taking place in real time.

2.10. Where originals are not retained, certified true copies of original paper documents (photocopies) can be used, but should comply with best practice:

2.10.1. The photocopied document must contain a ‘certification statement’. The certification declaration must be annotated on, or appended to, the copy. The original document does not need to be marked.

2.10.2. If a document contains multiple pages then the first page should be certified and the number of attached pages indicated on the front page (alternatively, each page could be certified).

2.10.3. The certification statement must be authorised/signed and dated by an employee who can vouch that the copy is a true replica image of the original.

2.10.4. The certification statement is added at the time that the copy is made. Alternatively, the certification statement can be added shortly afterwards if the signatory can recall seeing the original and is therefore still able to confirm that the copy is satisfactory.

2.10.5. The ‘certification statement’ can be chosen by each Lead Partner but must, at least, contain the following:

• signature (or similar evidence of authorisation) 
• date 
• ‘true copy’, ‘certified copy’, ‘certified’ (or similar phrase to signify what the signature and date represents)

2.10.6. It is recommended, but not mandatory, that the certification statement also includes the printed name/position of the signatory or other unique reference (such as employee/payroll number) so that future project staff and/or auditors are able to easily identify the signatory if required. The following is an example of a compliant certification statement:

2.10.7. If more efficient, a single certification declaration can be used for a batch of photocopies. The certification statement must include: 

• a unique batch reference number/code to identify the batch
• the number of documents – and pages if individual documents contain more than one page – included in the certified batch
• the references/numbers of each of the documents included in the batch. If the documents are not already referenced/numbered, then references/numbers should be added to each document prior to batch certification

2.11. Where originals are not retained, and best practice as outlined is not followed, the Managing Authority reserves the right to assess the processes and procedures of the organisation to determine whether sufficient assurance of document authenticity is provided. Expenditure may be deemed ineligible if document authenticity cannot be verified.