Progress Update Review - Scottish Futures Trust - National Records of Scotland (NRS)

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Contents

Public Records (Scotland) Act 2011
Progress Update Review (PUR) Mechanism
Executive Summary
Authority Background
Assessment Process
Progress Update Review (PUR): Scottish Futures Trust
The Public Records (Scotland) Act Assessment Team’s Summary
The Public Records (Scotland) Act Assessment Team’s Evaluation

1. Public Records (Scotland) Act 2011

The Public Records (Scotland) Act 2011 (the Act) received Royal Assent on 20 April 2011. It is the first new public records legislation in Scotland since 1937 and came into force on 1 January 2013. Its primary aim is to promote efficient and accountable record keeping by named Scottish public authorities.

The Act has its origins in The Historical Abuse Systemic Review: Residential Schools and Children’s Homes in Scotland 1950-1995 (The Shaw Report) published in 2007. The Shaw Report recorded how its investigations were hampered by poor recordkeeping and found that thousands of records had been created, but were then lost due to an inadequate legislative framework and poor records management. Crucially, it demonstrated how former residents of children’s homes were denied access to information about their formative years. The Shaw Report demonstrated that management of records in all formats (paper and electronic) is not just a bureaucratic process, but central to good governance and should not be ignored. A follow-up review of public records legislation by the Keeper of the Records of Scotland (the Keeper) found further evidence of poor records management across the public sector. This resulted in the passage of the Act by the Scottish Parliament in March 2011.

The Act requires a named authority to prepare and implement a records management plan (RMP) which must set out proper arrangements for the management of its records. A plan must clearly describe the way the authority cares for the records that it creates, in any format, whilst carrying out its business activities. The RMP must be agreed with the Keeper and regularly reviewed.

2. Progress Update Review (PUR) Mechanism

Under section 5(1) & (2) of the Act the Keeper may only require a review of an authority’s agreed RMP to be undertaken not earlier than five years after the date on which the authority’s RMP was last agreed. Regardless of whether an authority has successfully achieved its goals identified in its RMP or continues to work towards them, the minimum period of five years before the Keeper can require a review of a RMP does not allow for continuous progress to be captured and recognised.

The success of the Act to date is attributable to a large degree to meaningful communication between the Keeper, the Assessment Team, and named public authorities. Consultation with Key Contacts has highlighted the desirability of a mechanism to facilitate regular, constructive dialogue between stakeholders and the Assessment Team. Many authorities have themselves recognised that such regular communication is necessary to keep their agreed plans up to date following inevitable organisational change. Following meetings between authorities and the Assessment Team, a reporting mechanism through which progress and local initiatives can be acknowledged and reviewed by the Assessment Team was proposed. Key Contacts have expressed the hope that through submission of regular updates, the momentum generated by the Act can continue to be sustained at all levels within authorities.

The PUR self-assessment review mechanism was developed in collaboration with stakeholders and was formally announced in the Keeper’s Annual Report published on 12 August 2016. The completion of the PUR process enables authorities to be credited for the progress they are effecting and to receive constructive advice concerning on-going developments. Engaging with this mechanism will not only maintain the spirit of the Act by encouraging senior management to recognise the need for good records management practices, but will also help authorities comply with their statutory obligation under section 5(1)(a) of the Act to keep their RMP under review.

3. Executive Summary

This Report sets out the findings of the Public Records (Scotland) Act 2011 (the Act) Assessment Team’s consideration of the Progress Update template submitted for Scottish Futures Trust. The outcome of the assessment and relevant feedback can be found under sections 6 – 8.

4. Authority Background

Scottish Futures Trust (SFT) was incorporated and launched in the Scottish Parliament by the Cabinet Secretary for Finance and Sustainable Growth on 10th September 2008. Scottish Futures Trust is a company limited by shares incorporated under the Companies Act 2006 and is wholly owned by the Scottish Ministers although operates independently of the Scottish Government (SG). The shareholder relationship is defined in a Management Statement & Financial Memorandum (MSFM) which is published on Scottish Futures Trust’s website. Scottish Futures Trust works closely with the public sector to seek and deliver improved value for taxpayers and has responsibility for delivering value for money across public sector infrastructure investment.

https://www.scottishfuturestrust.org.uk/

5. Assessment Process

A PUR submission is evaluated by the Act’s Assessment Team. The self-assessment process invites authorities to complete a template and send it to the Assessment Team one year after the date of agreement of its RMP and every year thereafter. The self-assessment template highlights where an authority’s plan achieved agreement on an improvement basis and invites updates under those ‘Amber’ elements. However, it also provides an opportunity for authorities not simply to report on progress against improvements, but to comment on any new initiatives, highlight innovations, or record changes to existing arrangements under those elements that had attracted an initial ‘Green’ score in their original RMP submission.

The assessment report considers statements made by an authority under the elements of its agreed Plan that included improvement models. It reflects any changes and/or progress made towards achieving full compliance in those areas where agreement under improvement was made in the Keeper’s Assessment Report of their RMP. The PUR assessment report also considers statements of further progress made in elements already compliant under the Act.

Engagement with the PUR mechanism for assessment cannot alter the Keeper’s Assessment Report of an authority’s agreed RMP or any RAG assessment within it. Instead the PUR Final Report records the Assessment Team’s evaluation of the submission and its opinion on the progress being made by the authority since agreeing its RMP. The team’s assessment provides an informal indication of what marking an authority could expect should it submit a revised RMP to the Keeper under the Act, although such assessment is made without prejudice to the Keeper’s right to adopt a different marking at that stage.

Key

Green

The Assessment Team agrees this element of an authority’s plan.

Amber

The Assessment Team agrees this element of an authority’s progress update submission as an ‘improvement model’. This means that they are convinced of the authority’s commitment to closing a gap in provision. They will request that they are updated as work on this element progresses.

Red

There is a serious gap in provision for this element with no clear explanation of how this will be addressed. The Assessment Team may choose to notify the Keeper on this basis.

6. Progress Update Review (PUR): Scottish Futures Trust

Element 1: Senior Officer

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Update required on any change.

Since our last update job titles have changed to reflect some minor changes in responsibilities and structure within SFT.

Caroline Whyteside the Senior Officer Responsible’ s job title is now Director – Corporate Services & Investments

Wendy Ross the Records Manager’s job title is now Information & Business Support Manager

These have been updated in the Records Management Plan and are enclosed as Evidence for Element 1 and 2.

The Assessment Team thanks you for this update which has been noted.

Thank you also for providing the Team with the updated Records Management Plan.

Since our last update, there has been no change to the Senior Officer.

Please note that the Plan will be updated as part of the full submission in January 2025.

No immediate action required. Update required on any future change.

The Keeper’s Assessment Team acknowledge receipt of v1.7 of Scottish Futures Trust’s Records Management Plan. This will be kept on file to keep the submission up-to-date.

Element 2: Records Manager

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Update required on any change.

See Element 1 for details of change.

Update required on any change.

The Records Manager changed from Wendy Ross, with Joanne MacConnell responsible from 1 May 2024.

This has been reflected in our Records Management Policy (copy provided under Element 3).

Thank you. The Keeper’s PRSA Assessment Team can confirm that this change has been recorded.

Element 3: Policy

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Update required on any change.

No change.

Update required on any change.

As stated in Element 2, the Policy was updated to reflect the change in our Records Manager.

Thank you for this update.

The Keeper’s PRSA Assessment Team acknowledges receipt of the new version of the Records Management Policy. This document will be added to the Scottish Futures Trust case file in order that it may be kept up-to-date.

Element 4: Business Classification

Status:

1 February 2017 - agreed plan - Amber
29 September 2022 - review - Amber
17 December 2024 - review - Green

The RMP states that SharePoint has now been implemented across SFT and is being used as a document repository. The Records Management Centre has still to be implemented although SFT has contracted a third party, Brightwire Technology Services Ltd, to implement this solution on SharePoint. The estimated timetable for the completion of this work is given as April 2017. The transfer of records from the current document library will take place with the accompanying metadata and due to the number of records being transferred it is not feasible to add detailed information for these legacy records. Classification of records for addition to the Records Management Centre will take place once this system goes live.

The Keeper would remind SFT that SharePoint is not in itself a records management system and for full functionality, particularly relating to ensuring that metadata travels with the record when extracted from the system – for the purposes of archiving electronic records, for example – a records management bolt-on may be required.

The Keeper can agree this Element on an ‘improvement model’ basis. This means that the authority has identified a gap in provision (the electronic systems currently used to create and manage records need to be structured in line with the BCS). The solution and the timescales to close this gap have been identified. The Keeper requests that he is informed once the project has been completed.

The SharePoint migration of data from Classic to Modern SharePoint, is due for completion by the 31st May 2022. Following that a strategy for SharePoint will be presented to the SFT Leadership Team in July 2022. This strategy is expected to include ongoing implementation of IAO’s (Information Asset Owners), knowledge share, training and review of all business areas on the SharePoint site.

The Information Governance group approved the Business Classification, Retention, Destruction and Asset Register in November 2021. A copy is provided as Evidence under this element, however due to the extension to the SharePoint Migration project to end May 2022, this will be reviewed in line with that deadline rather than February 2022.

EL04_Evidence_Business Classification, Retention, Destruction and Asset Register v2.1_Nov2021

The Assessment Team thanks you for this update on Modern SharePoint migration completion. This is positive news, and it is hoped that the new SharePoint Strategy will further embed the new records management suite into SFT’s day-to-day business operations.

Thank you also for providing the Team with SFT’s Business Classification, Retention, Destruction and Asset Register v2.1. The receipt of this has been noted with thanks.

This Element remains at Amber while this work is ongoing. The Assessment Team looks forward to updates in subsequent PURs.

The full SharePoint migration from classic to modern was completed in May 2022.

A paper was presented to the Leadership Team in August 2022 regarding the retention and destruction of documents. Due to the complexity of the paper presented, the Leadership Team requested further research prior to any implementation: research into how other public sector bodies handle external sharing of documents.

A new IT Manager is now in place and the timeframe for the agreed SharePoint has been reviewed and is under discussion.

EL04_LT_OverallPaper

EL04_2208_O365_UseAdoptionStrategy_UpdatePaper

EL04_Microsoft
365_UseandAdoptionSrategy_Update_Nov23

We had several changes within the team, evidence below asking the Keeper for an extension to the full submission due to the changes.

EL04_FW_Public Records (Scotland) Act – Scottish Futures Trust – Postponement of invitation

Thank you for this update.

It appears from the text against this element that the M365 transition is now complete and, while consideration of how to use the various solutions on the platform from the point of view of information sharing (element 14) continues, the ’gap’ in provision identified against element 4 (“the electronic systems currently used to create and manage records need to be structured in line with the BCS”) has now been closed. In their original agreement the Keeper asked to be “informed once the project has been completed.” This PUR seems to satisfy that requirement.

The achievement of this objective marks a measurable improvement in the records management provision in the authority.

If this were a formal re-submission it is likely that this element of the Plan would turn from Amber to Green.

The Keeper’s PRSA Assessment Team acknowledges receipt of Strategy papers around the use of M365 as an information sharing tool. These documents will be added to the Scottish Futures Trust case file in order that it may be kept up-to-date.

SFT should be aware that, in the case of your formal resubmission, the Keeper will be investigating the use of legacy line-of-business systems in more detail than in the initial agreement. These are systems that will sit outside the main records management structure and may not be compliant with the authority’s own Records Management Policy. For the purposes of this PUR it is not required that SFT provides a statement on this issue.

Element 5: Retention schedule

Status:

1 February 2017 - agreed plan - Amber
29 September 2022 - review - Green
17 December 2024 - review - Green

SFT has submitted its current Retention and Destruction Schedule. The schedule identifies the record types, the periods for which these should be retained, the reason for the retention period and any additional information such as the legislative requirements relating to the records. It is currently still ‘Draft’ as SFT is seeking legal advice on the retention periods for certain financial and company records. SFT have undertaken to send the Keeper the final agreed Schedule when it becomes available.

The RMP states that staff awareness sessions will be developed around retention and disposal and that training in the use of retention schedules will be included in future SharePoint training for new staff. The Keeper requests that he is kept informed of the progress in developing this training.

The Keeper can agree this Element on an ‘Improvement Model’ basis. This means that the authority has identified a gap in provision (the lack of an operational retention schedule and the application of this to records managed using SharePoint) and has described how it intends to close this gap. As part of this agreement, the Keeper requests he is sent the finalised Schedule when it becomes operational and is kept informed of the project to apply the retention schedule to SharePoint in the longer term.

As noted under Element 4, the review of the Business Classification, Retention, Destruction and Asset Register will now be carried out in line with the SharePoint Migration project.

SFT’s Information Governance group are reviewing Best Practice for use of our storage space in SFT:

EL05_Evidence_ODSPbestpractice_LT_Nov2021

On completion of the SharePoint Migration project the recommendations will be scheduled for implementation to allow us to achieve a consistent and secure use of our electronic storage spaces across Microsoft Office 365.

Many thanks for this update on retention arrangements.

It is noted that the document detailing business classification, information assets, retention, and destruction will be regularly reviewed (this has been provided under Element 4). Thank you also for sharing the ‘Best Practice for use of our storage space in SFT’ document as an example of best practice, and how best practice is communicated to staff.

Based on this update, it is clear that SFT has given consideration to retention decisions and their practical implementation in its ongoing embedding of modern SharePoint.

The Legal team are liaising with workstreams to agree a retention period. Legal will also liaise with IT to put processes in place to ensure that records are deleted / archived at the end of the relevant retention period. The Legal team are considering whether training is required for information asset owners.

EL05_Records Management Plan

Thank you for this update. A retention schedule is a living document liable to alter in response to changing business needs. It therefore requires periodic review to address this. It is clear that SFT recognise this.

Engagement with local business areas is commended as liable to highlight discrepancies and to encourage buy-in.

Element 6: Destruction arrangements

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Update required on any change.

SFT have recently changed the provider of our Backups for the SFT Office 365 tenant (full Office365 suite) from CyberFort to SkyKick. SkyKick provide an immutable (cannot be altered) backup of the SFT Office tenant (Outlook, SharePoint, OneDrive, Teams). The data will be retained in a UK West Microsoft cloud location for one year, after which it will be destroyed.

EL06_Evidence_Skykick Backup Information

Thank you for this update on new backup provider arrangements, and the accompanying document, which have been noted. Update required on any future change.

There is no change to this from the last update.

No immediate action required. Update required on any future change.

Element 7: Archiving and transfer

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Amber
17 December 2024 - review - Amber

Update required on any change.

SFT have been working with the NRS on the New Agreement documentation. Communication is ongoing to reach agreement on the final wording of this documentation.

EL07_Evidence_Hard Drive for NRS

Once finalised this will be signed and documents transferred for archiving as per the Business Classification, Retention, Destruction and Asset Register.

It is reassuring to hear that discussions are ongoing regarding the final wording of the Deposit Agreement with NRS’ Client Management Team.

As deposits cannot currently be delivered to NRS, this Element will remain at Amber. It is clear, however, from the update and evidence provided, that SFT is making commendable progress in rectifying this matter.

Joanne MacConnell (SFT) liaising with Laura Gould (NRS) in relation to this.

Thanks you for this update.

The Keeper’s PRSA Assessment Team acknowledge that negotiations around a formal deposit agreement are ongoing. Until this is approved and in place this element remains at amber.

The Assessment Team looks forward to updates in subsequent PURs.

Element 8: Information security

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

SFT has stated that as part of the move to a new IT Managed Service Provider early in 2017 the ICT Policy will be reviewed and updated. SFT has committed to providing the Keeper with an updated version of the Policy as soon as practicably possible, which the Keeper can accept.

The Keeper can agree that there are appropriate mechanisms in place to ensure the security of the information created and managed by SFT. As part of this agreement, the Keeper requests that he is sent a copy of the updated ICT Policy when it becomes available.

SFT has retained Cyber Essentials Plus Certification in April 2022, copy of Certificate is included as evidence

EL08_Evidence_CE Plus Certificate2022

Due to the implementation of Cloud First programme, the decision has been taken to delay the review of the ICT Policy once this is completed later in 2022. A copy of the updated ICT Policy can be made available for The Keeper as soon as this is approved.

Many kind thanks for providing the Assessment Team with a copy of SFT’s Cyber Essential Plus Certificate. This has been noted.

The Assessment Team also thank you for the update regarding planned ICT Policy review. The delay, in this case, seems justifiable. We look forward to receiving the updated document when it becomes available, possibly included in the next PUR.

SFT has retained the Cyber Essentials Plus certification in November 2023. Recertification due in November 2024.

EL08_Cyber Essentials Plus Certificate

The IT Policy has been updated following the required review date. A copy is included for The Keeper. A link to our weekly newsletter on 14 August 2023 and 1 April 2024 is also included which provides evidence that the policy was shared with all staff.

EL08_IT Policy V3_Final_Aug2

EL08_In the Loop – Monday 14 August 2023

EL08_In the Loop – Monday 1 April 2024

SFT became a Cloud First organisation in January 2023, link to weekly newsletter as evidence.

EL08_In the Loop – Monday 16 January 2023

EL08_IT Communication – New Software Requests & Updated Password Policy

No immediate action required. Update required on any future change.

The Keeper’s PRSA Assessment Team acknowledges receipt of the new IT Policy and staff guidance documents. These documents will be added to the SFT case file in order that it may be kept up-to-date.

Element 9: Data protection

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

…Also submitted as evidence is SFT’s draft Data Protection Policy. The Policy is currently going through SFT’s internal governance process and is waiting to be signed off by the Leadership Team. SFT has stated that the final agreed version will be sent to the Keeper when it becomes available.

The Keeper can agree that SFT is aware of its responsibilities under the Data Protection Act 1998 and has procedures in place to comply with it. As part of this agreement, the Keeper requests that he is sent a copy of the updated Data Protection Policy when it becomes available.

The review and update of the Data Protection Policy was completed in May 2021:

EL09_Evidence_Data Protection Policy v3.0.

The next annual review is currently underway and an updated copy can be provided to The Keeper once this has been approved.

We continue to communicate with staff regarding all Policy updates, a copy of an All staff communication is included as evidence.

EL09_Evidence_AllStaffCommunication_In the Loop – Monday 15 November 2021

The Assessment Team thanks you for this update on Data Protection Policy document review and update.

The receipt of this policy, and staff communication excerpt, is also acknowledged with thanks.

The Data Protection Policy has been reviewed and updated and sent to all staff on 11 April 2024. Policy and email provided as evidence. The next review will be April 2025.

EL_09 Data Protection Policy v4.0

EL_09 Data Protection Policy and Personal Data Breach Management Policy

Scottish Futures Trust is registered with the Information Commissioner as a data controller:
Information Commissioner's Office - Register of data protection fee payers - Entry details (ico.org.uk)

They publish a Privacy policy online:
privacy-policy-infrastructure-survey (scottishfuturestrust.org.uk)This includes details of service user's rights as a data subject.

SFT have a Data protection officer. This is Joanne MacConnell (see element 2).

This element retains its Green RAG status.

The Keeper’s PRSA Assessment Team acknowledges receipt of the new DP Policy and Breach Management documents. These will be added to the SFT case file in order that it may be kept up-to-date.

Element 10: Business continuity and vital records

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Update required on any change.

The Business Continuity Policy was updated and approved in October 2021, a copy is included as Evidence.

EL10_Evidence_Business Continuity Plan_v2.4_FinalAllStaff_Oct21

The review and updates followed an Internal Audit carried out on our IT Service Continuity Management, Disaster Recovery and Business Continuity Planning where recommendations were made. Alongside recommendations, key stakeholders and other contact details were reviewed for accuracy.

A copy of the Internal Auditors recommendations document is included as evidence

EL10_Evidence_IT Service Cont Mgmt Disaster Recovery (DR) Business Continuity Planning (BCP)

SFT will consider The Keepers request for feedback on Business Continuity arrangements during the COVID pandemic now that all restrictions have been lifted and provide in a separate document.

Thank you for this update on business continuity and vital records, including the scheduled review of key documentation. The update provided on an Internal Audit is also positive news, and will positively impact SFT’s overall disaster preparedness.

The Assessment Team notes that new Business Continuity Policy and the document detailing Internal Audit recommendations are available, and acknowledges with thanks that copies have been supplied.

Should SFT still wish to prode the Keeper’s Assessment Team with evidence regarding arrangements during the COVID-19 pandemic, we are happy to receive these alongside the next PUR.

The Business Continuity Plan was updated and approved in November 2023 to reflect the changes in contact information / job titles. It was also updated to include the Cyber Security Response Plan and an update of the IT onsite detail following the move to Cloud First solution. A copy of the final approved version is included as evidence. Along with an email communication to all staff.

EL10_Busines Continuity Plan minus EMT v2.6

EL10_Business Continuity Plan

The Emergency Management Team also took part in training provided by our IT provider, Waterstons, as to how the team would deal with an emergency situation. Slides from the training included as evidence.

EL10_ SFT – Scenario Desktop Exercise – SLIDES

Changes in circumstance and new threats to the operation of an authority should be routinely considered with a mind to recovery from an unexpected situation. This should include testing the efficiency of back-up record-recovery processes. t seems clear from the authority’s previously agreed RMP and from the statement in this PUR that the Scottish Futures Trust recognises this and have procedures in place to ensure their business continuity arrangements are up-to-date.

The Keeper’s PRSA Assessment Team acknowledges receipt of the new Business Continuity Plan, management authorisation and training materials. These will be added to the SFT case file in order that it may be kept up-to-date.

Element 11: Audit trail

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

The RMP states that guidance on version control will be provided to staff in the second half of 2016. The Keeper would welcome sight of this guidance once it has been developed.

SFT recognises the importance of maintaining accurate records both onsite and in offsite archive. During the COVID pandemic the regular review of paper storage both onsite and offsite have been delayed. An objective has been agreed to ensure all paper storage files are reviewed during 2022/23 and updates, reviews and destructions will be recorded and brought up to date.

EL11_Evidence_ScreenshotHRPPDSystem_Objective2022-23

The Keeper expects authority’s RMP to provide evidence that a complete and accurate representation of all changes that occur in relation to a particular record is maintained. The Assessment Team is happy to hear that audit train information with regard to paper storage is due to be reviewed. Thank you also for providing an excerpt of a planned business objective.

With the establishment of the modern SharePoint environment, audit trail information with regard to digital records will hopefully become easier to establish and maintain. It is acknowledged that this may take time to get bedded in properly, and the Assessment Team encourage SFT to make sure this Element is adequately catered for following the reported record migration to modern SharePoint.

Update required on any change.

Our on-site and off-site storage had a complete overhaul as part of our office move last year. We now only have 64 boxes in storage. Invoice included as evidence. We also had several bags of confidential waste destroyed by ChangeWaste – certificates of destruction included as evidence.

EL11_Invoicec_2812255_20240403142102 (1)

EL11_Scottish_Futures_Trust_Cod_20230827

EL11_Scottish_Futures_Trust_Cod_20231010

Our Document Naming Guidance & Version Control documents have been reviewed and circulated in our weekly newsletter to all staff in April 24.

EL11_In the Loop – Monday 29 April 2024

The Keeper’s PRSA Assessment Team acknowledges receipt of the new Naming Conventions staff communications and evidence of destruction. These will be added to the SFT case file in order that it may be kept up-to-date.

This element retains its Green RAG status.

Element 12: Competency framework

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Section 7 of the Policy refers to the training of staff in records management issues at induction and on an on-going basis. This training will supplement that given in regard to Data Protection and Freedom of Information. The practical staff training in records management has not yet been finalised and that SFT is waiting for the implementation of the SharePoint Records Management Centre to take place so that the procedures for using this can be incorporated into any training. Discussions are underway with its corporate training provider with a view to developing records management training at induction and as part of a refresher programme. The Keeper requests that he is sent a sample of the training once it has been developed and rolled out.

The Keeper can agree that SFT recognises the importance of records management and endeavours to ensure that staff have access to appropriate training. As part of this agreement, the Keeper requests that he is sent a sample of the training when it becomes available.

No change.

Ongoing communication to existing members of staff as per Evidence

EL12_Evidence_AllStaffCommunication_In the Loop – Monday 15 November 2021

On completion of the migration of data from SharePoint classic to modern (deadline 31st May 2022) a strategy for SharePoint will be detailed, this will include recommendations for ongoing delivery of training for the use of SharePoint and the best practice for management of digital records within SFT. SFT are happy to share a copy of this strategy document once it is approved.

Thank you for letting us know there have been no major changes to staff competency framework. The excerpt from staff communications is noted with thanks.

It is reassuring to see that it is recognised that SFT’s recently-concluded SharePoint migration will be followed up with staff training to ensure systems are used as intended, and that organisational naming conventions are being followed.

At the end of 2022 / early 2023, Office365 training was rolled out to all staff, this included on demand training, virtual training and in-person training (half day course).

EL12_MS365TrainingPlan

EL12_In the Loop – Monday 3 April 2023

EL12_O365 training

We have a section on Records Management in our Staff Induction Pack which all new staff receive and are asked to confirm that they have read and understood the plan / policy.

EL12_sft Induction – Master updated

HR are reviewing regular training and are planning to implement a training calendar, which would include compliance training such as this.

Thank you for this update.

The Assessment Team acknowledge that SFT have correctly identified the importance of appropriate polices, governance and staff training in making the M365 implementation project a success.

The Assessment Team also acknowledge receipt of the updated training plan, examples of staff communication and evidence that their new-staff induction includes information governance elements. These will be added to the SFT case file in order that it may be kept up-to-date.

Element 13: Assessment and review

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Update required on any change.

Due to a change in reporting line for the Records Manager it has been agreed to put in place actions for 2022 following this PUR. This objective is the responsibility of the Records Manager (Information & Business Support Manager) which will be reviewed and supported by the Head of HR and Support Services who reports directly to the Senior Officer Responsible (Director – Corporate Services & Investments)

EL13_Evidence_Screenshot_HRPPDSystem_Objective2022-23

Thank you for this update. SFT’s regular participation in the PUR process should be commended. It is great to hear that this is recorded as a records management business objective (the screenshot has been received and retained with thanks). It is also apparent from updates under other Elements that SFT aims to keep all relevant policies and plans under regular review as scheduled.

Update required on any future change.

This objective is currently the responsibility of the Office & Business Support Manager which will be reviewed and supported by the Interim Head of HR and Support Services who reports directly to the Senior Officer Responsible (Director – Corporate Services & Investments). This responsibility will then fall to the Manager – Legal & Procurement from 1 May 24. Evidence showing the PUR submission as an objective.

EL13_Screenshot 2024-04-30 095533

Section 1(5)(i)(a) of the Act says that an authority must keep its RMP under review.

Statements in the PUR, and the completion of the PUR itself, are clear indications that SFT are complying with this requirement.

The assessment Team looks forward to any updates resulting from the next review in the formal resubmission which is scheduled for 2025.

Element 14: Shared information

Status:

1 February 2017 - agreed plan - Green
29 September 2022 - review - Green
17 December 2024 - review - Green

Update required on any change.

SFTs Information Governance Team are reviewing the External Sharing in line with the SharePoint Migration project and Best Practice Paper (see Element 5). This will then be presented to SFTs Leadership Team for approval.

EL14_Evidence_ExtSharingPaper

Thank you for this positive update, and the provided draft on approach to external file sharing. SFT approach seems very reasonable with regard to the implications of the SharePoint data migration project.

Update required on any change.

All external sharing is now done through MS Teams with guest access closely monitored and reviewed. This is referenced in appendix 4.

EL14_LT_OverallPaper

Element 14: Shared
Information Under element 4, above, SFT explain that discussions around how best to use M365 functionality in information sharing going forward are ongoing. However, the Keeper’s Assessment Team are satisfied that the current arrangements properly consider information governance issues. Therefore, although a change in information sharing methodology may be forthcoming, this element retains its green RAG status.

Element 15: Public records created or held by third parties

As this Element was not assessed separately in 2017, no RMP baseline RAG-status exists. However, the Keeper’s Assessment Team can agree that SFT, is aware of their responsibilities under this element.

If you would like more information around this please contact public_records@nrscotland.gov.uk.

7. The Public Records (Scotland) Act Assessment Team’s Summary

Version

The progress update submission which has been assessed is the one received by the Assessment Team on 30th April 2024. The progress update was submitted by Andrea Mason, Office & Business Support Manager.

The progress update submission makes it clear that it is a submission for Scottish Futures Trust.

The Assessment Team has reviewed Scottish Futures Trust’s Progress Update submission and agrees that the proper record management arrangements outlined by the various elements in the authority’s plan continue to be properly considered. The Assessment Team commends this authority’s efforts to keep its Records Management Plan under review.

General Comments

Scottish Futures Trust continues to take its records management obligations seriously and is working to bring all elements into full compliance.

Section 5(2) of the Public Records (Scotland) Act 2011 provides the Keeper of the Records of Scotland (the Keeper) with authority to revisit an agreed plan only after five years has elapsed since the date of agreement. Section 5(6) allows authorities to revise their agreed plan at any time and resubmit this for the Keeper’s agreement. The Act does not require authorities to provide regular updates against progress. The Keeper, however, encourages such updates.

The Keeper cannot change the status of elements formally agreed under a voluntary submission, but he can use such submissions to indicate how he might now regard this status should the authority choose to resubmit its plan under section (5)(6) of the Act.

8. The Public Records (Scotland) Act Assessment Team’s Evaluation

Based on the progress update assessment the Assessment Team considers that Scottish Futures Trust continue to take their statutory obligations seriously and are working hard to bring all the elements of their records management arrangements into full compliance with the Act and fulfil the Keeper’s expectations.

The Assessment Team recommends authorities consider publishing PUR assessment reports on their websites as an example of continued good practice both within individual authorities and across the sector.

This report follows the Public Records (Scotland) Act Assessment Team’s review carried out by

Pete Wadley
Public Records Officer

File downloads

NRS Public Records (Scotland) Act (PRSA) Scottish Futures Trust Progress Update Review (PUR) 2024 Final Report Web Version 17 December 2024

File type: PDF,
File size: 292.04 KB

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