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The Keeper of the Records of Scotland (the Keeper) expects that the public records of an authority are known and are identified within a structure.
COPFS recognise this. It is the policy of COPFS that “All staff have a responsibility to manage records effectively throughout their lifecycle, including access, tracking and storage of records; the timely review of records, whether this be for permanent preservation, or confidential destruction or recycling and, where appropriate, their ultimate disposal” (Records Management Manual – see element 3 - section 1.9).
COPFS staff are instructed in the Records Management Manual (section 3.5) that "Records should be arranged in a logical filing system, so that files and documents can be quickly located and retrieved and easily identified when the time comes for review or destruction."
Identification of the public records of the authority
COPFS divide their public records into two categories. The records of the authority are described as being either ‘case-related’ or ‘non-case-related’.
Both record types appear in a combined fileplan/retention schedule which forms the Business Classification Scheme. The Keeper has been provided with a copy of this document and notes that it follows a functional pattern. This must remain a business decision for the authority, but the Keeper acknowledges that a functional system, as demonstrated here, is currently considered best-practice.
Records are arranged by:
Function/Activity/Transaction/Record Type/Description of Records/Retention period/Disposal Action/Rationale/Vital Status/Owner
For example:
Office Services/In House Printing/Administrative/IHP Stats - log in of all workload which calculates the amount of prints/Retain for 3 years and destroy thereafter/Confidential Destruction/Operational Requirement/Vital/OFS Staff.
(see element 5 for more around retention).
The Keeper agrees that the Business Classification Scheme considers all record types in all formats (although the format is not stipulated in the scheme).
Records-Keeping Structure
COPFS manage records in a hybrid system: Public records are held digitally in a cloud-based document management system and on bespoke line-of-business systems. There are also public records managed in hard-copy format although this is being phased out.
COPFS have provided a Covering Letter from Anthony McGeehan, Deputy Crown Agent Operational Support (see element 1) in which he states: “As we emerge from COVID, COPFS is on a journey from being a paper-based to a digital service, with the aim of improving the quality of our services, optimising resources and delivering efficiencies to meet the needs and expectations of our stakeholders, customers and our people. The RMP focuses on these planned developments and maximising the benefit to our new Records Management processes.” The Keeper recognises that COPFS are following a ‘digital first where possible’ principle in record keeping.
Digital: The COPFS non-case-related records are managed on the M365 cloud platform. The authority states “COPFS has now fully migrated to Microsoft 365, making use of their packages to allow for a more structured and seamless way of working online and managing our non-case related files.” (RMP 'further developments' under Element 3).
Digital Line of Business Systems: The COPFS case-related records are managed on specialised line-of-business systems “The vast majority of case work is now completed online with all offices moving to Full Electronic Record compliance.” (RMP statement against element 11). COPFS operate several stand-alone systems for example in a case management system, a ministerial correspondence system and a 'Respond' system. These line-of-business systems sit outside eDRM, but the Keeper can agree that they are likely to allow the appropriate management of records within a structure as required. The use of these is explained to staff in detail in the Records Management Manual (for example throughout section 5).
Digital shared drives –COPFS currently use the M365 platform, as noted above, but maintain a some public records on networked drives. The authority’s Records Management Group has reviewed these drives and is clear what records are held in this system. They commit to “ensure consistency in retentions and metadata, naming conventions”. COPFS have had initial engagement with a third-party consultant as part of a discovery and analysis exercise into the functionality of M365 and further discussions are ongoing to establish the most appropriate approach to using M365 to manage record currently held on network drives. However, the Keeper recognises that it is likely that certain record formats will not easily transfer to M365 and the use of network drives may be required, in a limited extent, going forward. It is noted that COPFS clearly recognise that importance on ensuring that the records management provision imposed on the main system should also be replicated in network drives.
Physical In-House: Including Audio/Video/DVD recordings and photographs (Records Management Manual 6.39). Although the majority of COPFS’s records are now created digitally (see statement from the Deputy Crown Agent noted above) the authority is still required to manage legacy hard-copy records. The Keeper acknowledges that these are listed in the Business Classification Scheme (for example the print log example given above). The Keeper has been provided with details of the systems in place to ensure that COPFS can be confident that these records can be stored, retrieved and destroyed/archived when appropriate. For example, details of how staff should manage hard-copy records, both in offices and in a COPFS outstore, is included in the Records Management Manual (for example section 6).
The Keeper notes that COPFS are currently engaged in a scanning project to convert some hard-copy records to digital (see RMP compliance statement against element 13). On this matter COPFS have provided the following statement (September 2024): “COPFS have are in the process of migrating to fully electronic online working to support CMIC (Case Management In Court). Previously, files received by COPFS are born digital but through the investigation process, cases are printed from the system and hard copy papers are pulled together to create a case file and amendments then made to the hard copy papers. Since 2018, all summary cases have been fully electronic to support CMIC. To achieve this, we worked with staff to ensure all paper files were scanned into the system and named appropriately to ensure consistency. This was monitored by management. Present day, we are working with Sheriff and Jury and High Court & Specialist teams to assist them in converting to working fully electronic, however this is more difficult due to the size of their cases. COPFS are currently working alongside NRS to pilot an Electronic transfer of closed cases.”
Physical Third-Party Record Store: COPFS no longer manage physical records through a third-party record store.
E-mail: COPFS clearly recognise the risks inherent in e-mail and the importance of ensuring that records created in Outlook are done so securely and can be properly located and identified by consistent naming practices and by saving to the central, accessible, records management system (SharePoint). For example, section 8 of the Records Management Manual clearly recognizes the risk of e-mail (particularly the temptation to store in personal storage areas rather than in a way the offers appropriate access to those who need it). This is quite detail guidance including 8.5 which gives advice around auto-destruction of e-mail (see element 6) and 8.8 which sets out the dangers of using e-mail to send sensitive or confidential information (see element 8). Staff are given guidance on the dos and don’ts of using e-mail in a simple bullet-point style (also Manual section 8). This is a clever way of laying out ‘at a glance’ guidance particularly in a large document.
The Keeper notes that the compliance statement against element 14 states "COPFS is signed up to Criminal Justice Secure Mail (CJSM), a secure email system set up by the Ministry of Justice in London to provide a mechanism for secure electronic communication between criminal justice agencies in England and Wales. It is now widely used in Scotland and Ireland and enables members to communicate securely with anyone who has a .gov .pnn.gsx .gcsx and .nhs.net email address."
At several points in the Records Management Manual staff are instructed to ensure that corporate records are not managed in personal workspaces (such as mailboxes). For example Manual section 3.6 "Adequate shared record keeping systems must be developed to ensure that documents are not stored in personal files or mailboxes, but can be located and retrieved when required.” There are risks associated with staff storing records in ‘hidden’ personal areas and it clear that COPFS recognise this and strongly encourage staff to avoid this. Although, as noted elsewhere, being a 2017 document it does not highlight the availabity of shared, controlled, SharePoint spaces.
The Keeper agrees that The Lord Advocate and Procurators fiscal retains all its public records in controlled systems which are structured in a clear manner and which can be used by staff to manage public records where appropriate.
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