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Records Management Strategy
Version 5
Name of responsible (ratifying)
Information Governance Steering Group
committee
Date ratified 11 July 2012
Document Manager (job title) Information Governance Manager
Date issued 26/10/2012
Review date July 2014
Electronic location Trust Management Policies
Clinical Records Management Policy, Non-Clinical Records
Related Procedural Documents
Management Policy, Records Retention and Disposal Policy
Information, Clinical Record, Non-Clinical Record, File,
Key Words (to aid with searching)
Records Management, Audit
Records Management Strategy Issue 5 26/10/2012
Review Date: July 2014
Page 1 of 17
CONTENTS
QUICK REFERENCE GUIDE ............................................................................................................. 3
1. INTRODUCTION ......................................................................................................................... 4
2. PURPOSE ................................................................................................................................... 4
3. SCOPE ........................................................................................................................................ 4
4. DEFINITIONS .............................................................................................................................. 5
5. DUTIES AND RESPONSIBILITIES .............................................................................................. 5
6. PROCESS ................................................................................................................................... 5
7. TRAINING REQUIREMENTS .................................................................................................... 17
8. REFERENCES AND ASSOCIATED DOCUMENTATION .......................................................... 17
9. MONITORING COMPLIANCE WITH THE STRATEGY ............................................................. 17
Records Management Strategy Issue 5 26/10/2012
Review Date: July 2014
Page 2 of 17
QUICK REFERENCE GUIDE
This strategy must be followed in full when developing or reviewing and amending Trust procedural
documents.
For quick reference the guide below is a summary of actions required. This does not negate the need
for the document author and others involved in the process to be aware of and follow the detail of this
policy.
1. The aim of the Trust’s Records Management Strategy is to ensure a systematic and planned
approach to records management covering records from creation to disposal
2. All staff must be aware of the importance of records management and the need for
responsibility and accountability at all levels
3. Trust records should be accurate and complete in order to facilitate audit, fulfil the Trust’s
responsibilities, and protect its legal and other rights. Records should show proof of their
validity and authenticity
.
4. Record-keeping systems should be easy to understand, clear, and efficient in terms of
minimising staff time and optimising the use of space (physical or virtual) for storage
.
5. Records must be kept securely to protect the confidentiality and authenticity of their contents,
and to provide further evidence of their validity in the event of a legal challenge
6. Improve patient safety by using the NHS Number to link patients to their records. The NHS
Number should be present in all active patient records and determined as early as possible in
the episode of care (NHS Number Standard for Secondary Care)
7. The Trust must have approved documentation which describes the process for managing the
risks associated with clinical records in all media (NHSLA Risk Management Standards)
8. The Trust must ensure that service users are protected against the risks of unsafe or
inappropriate care and treatment arising from a lack of proper information about them by
means of the maintenance of records (Care Quality Commission)
9. The Trust must have in place organisation-wide records management policies to include the
process for managing risks associated with clinical records on all media (Information
Governance Toolkit)
Records Management Strategy Issue 5 26/10/2012
Review Date: July 2014
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1. INTRODUCTION
1.1 This document sets out an overarching framework for integrating current records
management initiatives. This will enable overall coordination of all records
management activities and ensure alignment with the Trust’s business strategies.
1.2 The records management strategy should be read in conjunction with the Trust’s
policies for the management of clinical and non-clinical records and for retention and
disposal.
1.3 With the commencement and implementation of Connecting for Health’s delivery of
the National Programme for Information Technology (NPfIT), it is imperative that the
Trust has an effective, robust Records Management Strategy.
1.3.1 Increasingly, electronic patient records will be introduced to negate the need
for paper health records, although full implementation may be several years
off. The NHS Care Records Service (Summary Care Record), the Hampshire
Health Record (HHR) and Trust’s Electronic Document Management (EDM)
Programme are all examples of a electronic patient records, that must be
effectively and accurately aligned with existing paper records.
2. PURPOSE
This strategy provides a framework for current records management practices and potential
initiatives. It is a strategy to improve the quality, availability and effectiveness of all Trust
records, providing a strategic framework for records management activities.
3. SCOPE
3.1 This strategy relates to all clinical and non-clinical operational records held in any
format by the Trust as detailed in the Department of Health’s publication Records
Management: NHS Code of Practice, i.e.:
all administrative records (e.g. personnel, estates, financial and accounting
records, notes associated with complaints etc); and
all patient health records for all specialties and including records for private
patients treated on NHS premises
3.2 These include records held in all formats, for example:
paper records, reports, diaries and registers etc;
electronic records;
x-rays and other images;
microform (i.e. microfiche and microfilm); and
audio and video tapes
‘In the event of an infection outbreak, flu pandemic or major incident, the Trust recognises that
it may not be possible to adhere to all aspects of this document. In such circumstances, staff
should take advice from their manager and all possible action must be taken to maintain
ongoing patient and staff safety’
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Review Date: July 2014
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4. DEFINITIONS
Clinical Record: anything that contains clinical information regarding an individual patient, which
has been created or gathered as a result of any aspect of work of NHS health professionals,
and may be contained on any media.
5. DUTIES AND RESPONSIBILITIES
All departments / specialties must have a clear chain of managerial responsibility and
accountability for the records they create. All staff are responsible for the day-to-day
management of records whilst in their possession, or under their control.
The Information Governance Manager is responsible for coordinating audit of records
management practices and reporting on findings.
6. PROCESS
6.1 Aims
The aims of the Trust’s Records Management Strategy are to ensure:
a systematic and planned approach to records management covering records
from creation to disposal
efficiency and best value through improvements in the quality and flow of
information, and greater coordination of records and storage systems
compliance with statutory requirements
awareness of the importance of records management and the need for
responsibility and accountability at all levels; and
appropriate archiving of the Trust's important records
6.2 Key Elements
The Records Management Strategy comprises the following key elements:
6.2.1 Responsibility and Accountability
To provide a clear system of accountability and responsibility for record keeping and
use
It is important that all individuals in the Trust appreciate the need for responsibility and
accountability in the creation, amendment, management, storage of, and access to all
Trust records. A major target is therefore to have a clear chain of managerial
responsibility and accountability for all records created by the Trust. This is the
prerequisite for an effectively coordinated Records Management Strategy.
6.2.2 Record Quality
To create and keep records which are adequate, consistent, and necessary for
statutory, legal and business requirements
Trust records should be accurate and complete, in order to facilitate audit, fulfil the
Trust’s responsibilities, and protect its legal and other rights. Records should show
proof of their validity and authenticity so that any evidence derived from them is clearly
credible and authoritative.
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Review Date: July 2014
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6.2.3 Management
Achieve systematic, orderly and consistent creation, retention, appraisal and disposal
procedures for records throughout their life cycle
Record-keeping systems should be easy to understand, clear, and efficient in terms of
minimising staff time and optimising the use of space for storage.
6.2.4 Security
Provide systems which maintain appropriate confidentiality, security and integrity for
records in their storage and use
Records must be kept securely to protect the confidentiality and authenticity of their
contents, and to provide further evidence of their validity in the event of a legal
challenge.
6.2.5 Access
Provide clear and efficient access for employees and others who have a legitimate
right of access to Trust records, and ensure compliance with Access to Health
Records, Data Protection and Freedom of Information legislation
Access is a key part of any records management strategy. Fast, efficient access to
records unlocks the information and knowledge they contain.
6.2.6 Audit
Audit and measure the implementation of the records management strategy against
agreed standards
The performance of the records management programme will be audited.
6.2.7 Training
Provide training and guidance on legal and ethical responsibilities and operational
good practice for all staff involved in records management
Effective records management involves staff at all levels. Training and guidance
enables staff to understand and implement policies, and facilitates the efficient
implementation of good record keeping practices. New staff receive training (an
introduction to records management and current issues) at Trust Induction.
6.3 Current Position
6.3.1 National Drivers
Records Management: NHS Code of Practice is a guide to the standards of practice
required in the management of NHS records, based on the current legal requirements
and professional best practice. The guidance applies to all NHS records and contains
details of the recommended minimum retention period for each type of record.
The NHS in England is introducing the NHS Care Records Service (NHS CRS) to
improve the safety and quality of patient care. Over time, the NHS CRS will begin to
provide healthcare staff with quicker access to reliable patient information to help with
treatment, including in an emergency.
Computer systems are already used to keep notes of patient appointments, medicines
prescribed, test results and details of any referrals to other healthcare staff. X-rays
and scans are also increasingly held on computers rather than sheets of film. The
NHS Care Records Service will make providing care across NHS organisations, such
as the GP practice and the hospital safer and more efficient.
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The purpose of NHS CRS is to allow information about patients to be accessed more
quickly, and gradually to phase out paper and film records which can be more difficult
to access.
The (NHS) Care Record Guarantee sets out the rules that govern how patient
information is used in the NHS and what control the patient can have over this. It is
based on professional guidelines, best practice and the law and applies to both paper
and electronic records.
The NHS Care Record Guarantee is significant for records management practices as
it includes information on:
People’s access to their own records
How access to an individual’s healthcare record will be monitored and policed
and what controls are in place to prevent unauthorised access
Options people have to further limit access
Access in an emergency
What happens when someone is unable to make decisions for themselves
NHS Number Standard for Secondary Care – the Trust is currently in the process of
outlining and implementing a Project Plan to meet the requirements of the NHS
Number Standard for Secondary Care. The key purpose of the NHS Number
Standards is to improve patient safety by using the NHS Number to link patients to
their records. The NHS Number should be present in all active patient records and
determined as early as possible in the episode of care.
The NHS Number is the only National Unique Patient Identifier in operation in the NHS
at this time. The use of the NHS Number is fundamental to improving patient safety
across all care settings by:
Reducing clinical risk caused through misallocation of patient information
Resolving some of the barriers to safely sharing information across healthcare
settings
Assisting with long term follow-up processes and audit
There are four major principles:
The NHS Number will be included as a patient identifier on all systems and
documents which include Patient Identifiable Data
The NHS Number will be the “first choice” for searching electronic patient
records
All practical attempts should be made to determine the NHS Number before or
at the start of an episode of care, but if this is not possible then tracing should
be performed as early as possible in the episode
The NHS Number will be supplied as a patient identifier for any Patient
Identifiable Data that passes across system or organisational boundaries
Information Governance Toolkit (Records Management Standards)
All NHS organisations should have in place an organisation-wide Information Lifecycle
Management (ILM) Policy or equivalent policies, to include the process for managing
risks associated with clinical records on all media. A strategy for implementing the
policy should also be in place that identifies the resources needed to ensure records
of all type are properly controlled, tracked, accessible and available for use and for
eventually archiving or otherwise disposing of records. All documents should be in line
with the principles contained within the NHS Records Management Code of Practice.
Without a comprehensive approach the Trust will be unable to fully implement the
Freedom of Information Act 2000 requirements.
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Care Quality Commission (Outcome 21: Records Management)
(1) The registered person must ensure that service users are protected against the
risks of unsafe or inappropriate care and treatment arising from a lack of proper
information about them by means of the maintenance of—
(a) an accurate record in respect of each service user which shall include
appropriate information and documents in relation to the care and
treatment provided to each service user; and (b) such other records as are
appropriate in relation to —
(i) persons employed for the purposes of carrying on the regulated activity,
and
(ii) the management of the regulated activity
(2) The registered person must ensure that the records referred to in paragraph (1)
(which may be in paper or electronic form) are—
(a) kept securely and can be located promptly when required
(b) retained for an appropriate period of time
(c) securely destroyed when it is appropriate to do so
NHSLA Risk Management Standards
(1.7) Health Records Management
The Trust must have an approved documented process for managing the risks
associated with paper and electronic health records.
The document process must include:
Duties
Legal obligations that apply to records
How a new record is created
How health records are tracked when in current use
How health records are retrieved from storage
Process for retention, disposal and destruction of records
How the organisation monitors compliance with all of the above
(1.8) Health Record-Keeping Standards
The Trust must have an approved document process for health record keeping.
The documented process must include
Basic record-keeping standards, which must be used by all staff
Process for making sure a contemporaneous record of care is completed
How the organisation trains staff, in line with the training needs analysis
How the organisations monitors compliance with all of the above
6.3.2 Local Drivers
Storage issues – previous lack of adequate storage has been addressed through the
Health Records Library’s relocation to a purpose-built off-site location. However, this
facility does not have unlimited storage and routine disposal of records must be
undertaken to ensure its storage limit is not compromised.
Accessibility – Following the Health Records Library’s relocation and accessibility of
casenotes has seen a significant improvement. The Information Governance Steering
Group will continue to receive regular reports on casenote availability and other
accessibility issues to maintain appropriate monitoring.
Governance – there are recognised governance issues around the quality of health
records, including the accuracy and completeness of documentation, misfiling of
information and poor physical state of the record. The improved establishment of the
Health Records Quality audit process has enabled a greater awareness of governance
issues to be identified and addressed.
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Volume of electronic records – due to the less virtual nature of electronic records there
is a greater potential for uncontrolled increases in volume and the use non-
standardised filing conventions and records management practices. Assessment and
remedy of such issues will require a co-ordinated approach from ICT and records
management leads.
Information Risk Management -
Management of Local Risks
Any risks associated with Records Management practices – e.g. issues with casenote
availability – should follow the Trust’s normal risk reporting processes.
Risks will be initially identified on Clinical Service Centre Risk Registers, to be
presented through the Risk Assurance Committee (RAC) for a decision on
whether to escalate to the Trust-wide Corporate Risk Register
From the Corporate Risk Register, high-risk will go on to the Trust’s Assurance
Framework
This approach will ensure consistent reporting and management of risks associated
with Records Management and offer the opportunity for early identification of risks that
could affect other areas.
Strengths
Head of Patient Services within Health Records is a dedicated post guide the
management of health records and the Health Records Library
Information Governance Manager responsible for providing strategic direction
for the management of records, supported by clinical and non-clinical records
management policies
Information Governance Steering Group includes clinical and corporate
records management as standing agenda item, and responsible for
progressing the work programme associated with records management
Establishment of Senior Information Risk Officer with Executive responsibility
for information risk management (where associated with poor records
management)
Information Risk Management Programme identifying information assets,
information asset owners and associated risks, which incorporates records
management practices
Establishment of purpose-built Health Records Library which, whilst based at
an off-site facility, is manned 24 hours per day and can provide records in an
emergency within 30 minutes. Operational changes within the Health Records
Library have seen a significant increase in quality of case note availability (to
around 99%)
More robust and established Health Records Quality Audit, assessing the
quality of clinical record keeping
Weaknesses
Issues with some aspects of health records management, e.g. documentation
standards, misfiling of patient information etc. – activities which are the
responsibility of those individuals handling the records
Lack of engagement with records management issues / prioritisation due to
other workload pressures
Financial restrictions may apply should any records management solutions be
identified
Instances of records being decanted on wards, which can introduce a risk to
patients if the decanted record is not subsequently married back with the main
record
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Lack of detailed assessment of the quality of electronic record keeping and the
potential proliferation of electronic records (due to their virtual nature)
increases the potential for unstructured / non-standardised filing systems
Opportunities
The IGSG to identify and address records management related issues across
the Trust and thus reduce risk
Records Management e-learning modules provide by Connecting for Health
and available online on the Information Governance Training Tool
To impress on senior managers the importance of records management and
the key role in which it plays in service delivery and to promote consistency of
practice
Departments to increase working with ICT to achieve a better understanding of
local needs relating to electronic records management
An increased understanding of day-to-day records management issues should
result from increasing the requirement for all CSCs and corporate functions to
undertake corporate records inventories
Increase in the availability of specialist Electronic Document Management tools
(for the management of corporate records), which could be explored to aid
compliance with best practice in this area (although products would carry
potentially significant outlay and / or maintenance and / or licence costs)
6.4 Implementation
The action points, in the table below, have been developed from the Trust’s records
management policies which require the following fundamentals to be present:
existence of an overall policy statement on how records (including electronic
records) are to be managed;
endorsement of policy by senior management;
dissemination of policy to staff at all levels;
provision of corporate mandate for the performance of all records and
information functions;
organisational commitment to create, keep and manage records which
document activities;
definition of roles and responsibilities;
definition of responsibility of personnel to document actions and decisions in
the records and to dispose of obsolete records;
provision of framework for supporting appropriate standards, procedures and
guidelines;
provision of monitoring mechanisms to ascertain compliance with appropriate
standards, procedures and guidelines; and
review of policy at regular intervals (at least once every two years)
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The key elements of this strategy will be implemented as follows:
Target
Strategic Goal Objective Action Responsibility
Date
1.1 Establish a records management strategy Information Governance
with processes for ongoing monitoring and Manager Complete
review
Information Governance
1.2 Secure senior management ‘buy-in’ to Manager
improving records management, and the Link to senior management September
designation of a senior manager to be interests and responsibilities 2012
responsible for records management relating to CQC Outcome 21:
Records
1.3 Establish a Records Management
function (to manage all Trust records), with
clearly defined terms of reference and links Information Governance
to other Information Governance functions Steering Group Complete
1 Responsibility and To provide a clear system of
Accountability accountability and e.g. Freedom of Information, Data Protection,
responsibility for records Risk Management etc.
1.4 Appoint a qualified Records Manager / or
designate the Information Governance Information Governance
Manager Complete
Manager or another manager to have
responsibility for Records Management
1.5 Manage implementation of the records
management strategy, including provision of
advice on records management, Information Governance
Steering Group Ongoing
establishment of good practice guidelines
and of compliance with relevant legislation
and NHS guidance
1.12 Ensure inclusion of records
management and information issues and Information Governance
Manager Complete
practices in induction training programmes
for all new staff
To create and keep records 2.1 Develop guidance on good practice with
2 Record Quality Information Governance Complete
which are adequate, the aim of establishing common and
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Target
Strategic Goal Objective Action Responsibility
Date
consistent, and necessary for consistent standards of record creation and Manager
statutory, legal and business record keeping within the Trust, taking into
requirements account current Data Protection and
Freedom of Information legislation
Head of Information
Management and
2.2 Reduce the duplication of records to Governance
improve information sharing, reduce cost and Head of Patient Services Ongoing
save space
Information Governance
Manager
SIRO
Senior ICT Security
Specialist
2.4 Identify all records vital to the continuing
functioning of the activities of the Trust in the Information Governance
Manager September
event of disaster and make provision for their
2012
protection (to be cross-referenced with the Business Continuity Lead
Trust Risk Management Strategy) Link with relevant standards from
the IG Toolkit regarding business
continuity and Information Asset
Risk Assessments
3.1 Review existing records management
practices to establish what needs to be done Information Governance
To achieve systematic, orderly to comply with the ‘Records Management: Manager Ongoing
and consistent creation, NHS Code of Practice’
3 Management appraisal, retention and 3.3 Produce Trust records retention
Information Governance
disposal procedures for schedules consistent with the NHS Retention
Manager
records during their lifecycle and Disposal schedules detailed in the Complete
‘Records Management: NHS Code of Head of Patient Services
Practice’
3.6 Establish a system for managing records’ Information Governance Completed
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Target
Strategic Goal Objective Action Responsibility
Date
appraisal and for recording the disposal Manager
decisions made
3.8 Establish procedures for the closure of
records when no longer current, secure Information Governance
Manager Completed
storage of archived records, and effective
disposal, as soon as appropriate
3.9 Identify a secure and confidential method Director of FM (through
for the disposal of records, and organise its PFI) Completed
implementation
3.10 Maintain a log of records which have Information Governance
been destroyed showing their reference, Manager Completed
description and date of destruction
Head of Information
Management and
Governance
3.12 (Whilst electronic records are subject to
the same creation, appraisal, retention and Head of ICT Operations
disposal process as paper records) develop Information Governance December
guidance as appropriate to take into account Manager 2012
the particular technical requirements of
electronic media Consideration of increased used
of SharePoint for document
control or increase ‘manual’ audit
of electronic records
Senior ICT Security
Specialist
To provide systems which 4.1 Develop and promulgate policies and
maintain appropriate procedures to protect records from Information Governance
confidentiality, security and unauthorised alteration or erasure, to ensure Manager November
4 Security
integrity for records in their that access to records is properly controlled, Information Asset Owners 2012
storage and use and to maintain adequate audit trails to track
Link with System Security
the use and location of records held Policies and Information Asset
Risk Assessments
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Target
Strategic Goal Objective Action Responsibility
Date
Head of Patient Services
4.2 Implement secure storage arrangements
for information and documents, while Senior ICT Security Completed
allowing access by authorised personnel Specialist
4.3 Organise appropriate storage
accommodation for active paper records Head of Patient Services Completed
secure from fire, flood and theft, which is also
secure and safe from unauthorised access
4.4 Organise the relocation of paper records
into appropriately secure storage when they
are no longer required for the conduct of
current business, to await disposal and at the
same time meeting standards to ensure that Head of Patient Services Completed
no environmental damage is caused whilst
also providing security and having strictly
controlled access for authorised personnel
only
4.5 Develop appropriate Information Sharing
Protocols and Subject Specific Information Information Governance
Manager Ongoing
Sharing Agreements for the exchange of
confidential and personal information
Head of Information
Management and
Governance
4.6 Provide guidance on ‘back-up’, archiving Senior ICT Security
processes and audit trails for electronic Specialist
records, as well as on measures to prolong Information Asset Owners November
their access and use for as long as required, 2012
Information Governance
including migration across systems and onto
Manager
different types of media
Business Continuity Lead
Link with Information Asset
Business Continuity Plans.
Guidance re: data warehouse
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Target
Strategic Goal Objective Action Responsibility
Date
and Interoperability Toolkit
4.7 Develop and ensure that standards for
the safe and secure transportation of records Information Governance
Manager Completed
are strictly applied especially when
transported by users
4.8 Develop and implement a full and tested Senior ICT Security
Specialist Completed
contingency or business recovery plan
5.1 Implement effective tracking systems and Health Records Manager
audit trails, ensuring that information can be
Information Governance Completed
retrieved effectively and speedily when
Manager
required
To provide clear and efficient Information Governance
access for employees and Manager
5.2 Develop systems to determine any
others who have a legitimate Link with central guidance November
access restrictions at the point of records
5 Access right of access to Trust “Information Governance 2012
creation Baseline – 2012/13” re: systems
records, and ensure
development
compliance with current Data
Protection and Freedom of 5.3 Implement policies and procedures to
Information legislation address the particular requirements of
Freedom of Information in relation to agreed Information Governance
publication schemes and meeting requests Manager Complete
for information by the public that follow the
procedures established by the Trust’s
Freedom of Information Policy
6.1 Establish standards for records
To audit and measure the
management performance (e.g. response to
implementation of the Records IGSG
6 Audit subject access and Freedom of Information Completed
Management Strategy against
requests, record keeping, availability etc) and
agreed standards.
monitor the performance of the function
6.2 Provide advice and support for records Information Governance Completed
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Target
Strategic Goal Objective Action Responsibility
Date
departments in meeting agreed standards Manager
7.1 Provide (for all staff, departmental
Senior ICT Security
managers, and in particular for local record
Specialist
managers) procedure manuals and
instructions, guidance on good practice, and Head of Information
advice on procedural issues and Management and
requirements. These instructions should Governance Ongoing
cover all records management systems
To provide training and Information Governance
within the Trust, information quality and
guidance on responsibilities Manager
security, data protection, information
7 Training and good practice for all staff
handling, and legislative and statutory Health Records Manager
involved with records.
requirements
Information Governance
7.2 Raise the profile of records management
Manager
within the Trust through publicity about the Ongoing
issues involved and the staff responsible Head of Patient Services
7.4 Provide specific training and instruction Information Governance
on Data Protection and Freedom of Manager Completed
Information legislation
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7. TRAINING REQUIREMENTS
New staff will receive Records Management training on the Trust induction. The Information
Governance Manager is responsible for ongoing training and awareness sessions throughout
the Trust. Subsequent training needs will be identified through the appraisal process.
Information Governance (IG) training is mandatory and all new starters must receive IG training
within 3 months of commencing employment with the Trust. Ongoing IG training is provided
throughout the year for staff to access. Departmental training is also provided on request.
Individual training needs should be highlighted within the Trust Individual Performance Review
process.
8. REFERENCES AND ASSOCIATED DOCUMENTATION
NHS Care Record Guarantee
http://www.nigb.nhs.uk/guarantee/crs_guarantee.pdf
Trust Non-Clinical Records Management Policy
http://www.porthosp.nhs.uk/Management-
Policies/Non%20Clinical%20Records%20Management%20Policy.doc
Trust Clinical Records Management Policy
http://www.porthosp.nhs.uk/Clinical-
Policies/Clinical%20Records%20management%20policy.doc
Trust Records Retention and Disposal Policy
http://www.porthosp.nhs.uk/Management-
Policies/Records%20Retention%20and%20Disposal%20Policy.doc
Records Management: NHS Code of Practice
http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/
DH_4131747
Care Quality Commission – Essential Standards for Quality and Safety (Outcome 21: Records)
http://www.cqc.org.uk/sites/default/files/media/documents/gac_-_dec_2011_update.pdf
NHS Litigation Authority Risk Management Standards – Standard 1: Governance (1.7 and 1.8)
http://www.nhsla.com/NR/rdonlyres/6CBDEB8A-9F39-4A44-B04C-
2865FD89C683/0/NHSLARiskManagementStandards201213.pdf
NHS Connecting for Health – Information Governance Training Tool
https://www.igte-learning.connectingforhealth.nhs.uk/igte/index.cfm
9. MONITORING COMPLIANCE WITH THE STRATEGY
Compliance with this strategy will be primarily monitored with reference to the Key Elements
section (6.5), as well as through compliance monitoring of associated records management
policies that this strategy underpins.
Records Management Strategy
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