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[Important data protection stuff]

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University Records Disposal Policy: Manual Records

Summer 2005

Policy scope, overview and aims

The University of Essex recognises the importance of destroying all records effectively in order to ensure compliance with its various legal obligations and to protect the security of the information in its possession. This policy covers manual records managed in all parts of the University. Its fundamental aim is to ensure a rigorous and consistent approach to the secure destruction and disposal of such records.

The policy recognises the difficulty in determining the level of confidentiality for any specific record. The established definitions of "confidential” and "highly confidential” material contained in the policy may not fit all or every record in need of destruction. The policy is designed to provide a framework within which those involved in controlling destruction of records can operate. Individuals are able to use limited discretion when making the final decision on which category a particular record should fall into.

Specific legal obligations

The effective destruction of records is an important part of the University’s approach towards protecting the security of the information in its possession. In particular, there are two specific legal obligations that require effective adherence to this policy:
The provisions and principles of the Data Protection Act 1998 require the University to ensure that any record containing personal data, such as an individual’s name, address, or information relating to personal health, or financial or legal matters, is managed in a way that prevents the inadvertent disclosure or loss of information. In effect, this requires the University to destroy personal data under secure and confidential conditions.

The provisions of the Freedom of Information Act 2000 require effective destruction of a record at the end of its lifecycle in accordance with the established record retention schedule, to be able to guarantee that responses to requests for information made under the Act are lawful.

Manual Records: Destruction Process

It is the individual responsibility of all staff to ensure information they are handling is destroyed effectively, securely and in accordance with this policy. Manual records that have reached the end of their lifecycle, either in accordance with the relevant Records Retention Schedule or as usual paper waste, are divided into the following four categories, and are destroyed in accordance with the instructions relating to each category.

  1. Hexagonal Paper Recycle Bins

For non-confidential records and/or data, and those containing no personal information, hexagonal bins are provided for recycling purposes. All hexagonal recycle bins are emptied whenever necessary by the cleaner in each department or section. As paper collected in the bins is only ever recycled and never shredded, it is the responsibility of all those placing material in the bins to check that it has been identified correctly for recycling.

Additional hexagonal bins can be obtained by calling extension 2300 or 3144.

  1. Confidential Shredding

A record containing basic personal data, such as name, address, contact details, date of birth or similar, is shredded confidentially by a member of staff from the Estate Management Section. This type of record is not accompanied during transportation or the shredding process by a member of staff from the department or section wishing to destroy it.

To deal with the destruction of a record that requires "confidential shredding”, staff are required to email the Cleaning Section (faults@essex.ac.uk), explaining that there are confidential records ready for shredding. The records are then marked as ‘confidential’ and left in an agreed, secure place.

Records marked as confidential may not be shredded immediately. Any record in need of immediate shredding must be treated as "highly confidential” (see below).

  1. Highly Confidential Shredding

Any record containing the data described below is treated as highly confidential material, as is any record in need of immediate destruction.

A record is considered "highly confidential” if it contains the following material or similar, or is in need of immediate destruction:

  • data relating to confidential financial activities of the University;
  • data relating to policy decisions/future activities of the University;
  • payroll and pension data;
  • sensitive personal data, as defined by the Data Protection Act 1998, covering racial or ethnic origin, political opinions, religious beliefs, Trade Union activities, physical or mental health, sexual life, or details of criminal offences;
  • higher level personal data, such as information relating to student/staff disciplinary proceedings or harassment;
  • records containing "private” personal data, such as information relating to an individual’s home or family life, personal finances, or a personal reference;
  • records of a commercially sensitive nature, such as contracts, tenders, purchasing and maintenance records, or legal documents;
  • records concerning intellectual property rights, such as unpublished research data, draft papers, and manuscripts;
  • records containing personal or sensitive data about research subjects.

A "highly confidential” record is shredded confidentially by a member of staff from the Estate Management Section. The Cleaning Section is informed via email (faults@essex.ac.uk), stating that the material is highly confidential. To ensure a higher level of security, a member of the department or section wishing to destroy the record is present during both the transportation and shredding process.

Anyone in doubt about which category to use is advised to contact the Information Manager.

  1. Internal Shredding

Staff working in offices that have their own shredding equipment may destroy "confidential” or "highly confidential” manual records using that equipment. For records destroyed in this way, the Estate Management Section is not involved. Staff shredding their own records are responsible for ensuring that the records are destroyed adequately and in such a way that protects the security of the information contained within them.

Information already available in the public domain

Information already available in the public domain, for example via the University website, but which could fall potentially into a "confidential” or "highly confidential” category, such as decisions recorded in Senate, Council, or Committee minutes, is not normally considered to be "confidential” or "highly confidential” material. For records containing such information, destruction via the hexagonal recycling bins is adequate.

Policy review

In accordance with the University’s standard records management practice, the policy is reviewed every three years to ensure it meets effectively the University’s operational and legal requirements.

Policy Created: Summer 2005
Policy Effective From: October 2005
To be reviewed: Summer 2008