Model Records Management Plan: consultation

Introduction

Under the Public Records (Scotland) Act 2011 ("the Act") Scottish public authorities must produce and submit a records management plan ("RMP") setting out proper arrangements for the management of an authority's public records to the Keeper of the Records of Scotland ("the Keeper") for his agreement under section 1 of the Act. To assist authorities in this process, the Keeper must publish a model RMP ("Model Plan") that has been produced in consultation with stakeholders. To this end the Keeper established a Public Records Stakeholder Forum ("the Forum")^[1] to help develop the Model Plan.

The Model Plan should be read in conjunction with the Guidance to the Form and Content of the Model Plan ("the Guidance"). The Guidance has been produced to comply with section 1(4) of the Act

The Model Plan suggests 15 elements that the Keeper would expect a Scottish public authority to consider when creating its RMP. It is recognised that all elements will not apply to every authority. However, should an authority consider that an element does not apply, the Keeper will expect to see an explanation in support of the omission of that element from its RMP.

Although the Model Plan is published by the Keeper, its content reflects the combined work of the Keeper and the Forum. The Forum membership had representation from a cross section of public authorities and other bodies who are affected, either directly or indirectly, by the Act.

In 2018 the Keeper established a new Stakeholder Forum to develop and produce this revised version of the Model Plan.

A glossary of terms used in the Model Plan is included as Appendix A in the Guidance. Reference in this document to an 'authority' should be taken to mean an authority listed in the schedule of the Act. (http://www.legislation.gov.uk/asp/2011/12/schedule/enacted)

The records management practices set out in the Model Plan and supported by the Guidance are essentially a matter of good business administration. Therefore, authorities should already be complying with the bulk of these, including the allocation of adequate resources to support their records management arrangements. Authorities should use the Model Plan and Guidance to assess the effectiveness of their existing records management arrangements. Any deficiencies will need to be addressed including where necessary some reallocation of existing resources. In considering what remedial action will be appropriate, authorities should consult the Model Plan and Guidance and take account of the consequences of failing to comply with the Act.

Section 8(3) of the Act states that authorities must have regard to the Model Plan, but it is not compulsory for an authority to copy the format of the Model Plan in developing their RMP. Where an authority has already developed a robust records management system the Keeper would not expect that authority to expend additional resources rewriting it in line with the Model Plan.

It is important to note that establishing effective records management arrangements will deliver significant benefits for authorities - for example it will help to:

• Increase efficiency and effectiveness, delivering savings in administration costs
• Improve and develop service delivery
• Achieve business objectives and targets
• Ensure compliance with the Public Records (Scotland) Act 2011 and other legislative requirements, standards and codes of conduct
• Support transparency and open government

The scope of the Model Plan applies to all records irrespective of the technology used to create and store them or the type of information they contain.