Digital Records Management Policy
1. Purpose
The purpose of this policy is to ensure that all care records, safeguarding documents, risk
assessments, and operational files are created, stored, maintained, and accessed digitally in a
way that complies with:
CQC Fundamental Standards
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
UK GDPR and Data Protection Act 2018
Data Use and Access Act 2025
Reasonable Adjustment Digital Flat 2026
NHS Records Management Code of Practice
Information Governance and cybersecurity best practice
This policy ensures digital records are safe, accurate, accessible, and person‑centred.
2. Scope
This policy applies to all staff, contractors, and professionals who access or manage the
agency’s digital systems and care records.
3. Policy Statement
The agency operates a digital‑first, paperless records system . As stated in the original
document:
“All care documentation is created, stored, and maintained electronically. Paper
copies are only produced when specifically requested by external professionals.”
Digital systems are the primary method for recording, storing, and retrieving information.
4. Standards
Updated Feb 2026 Fay Townsend-JacksonDigital Records Management Policy
4.1 Record Quality
The original policy states:
“Records must be accurate, contemporaneous, and complete.”
All digital entries must be factual, timely, person‑centred, and compliant with professional
standards.
4.2 Digital Security
Role‑based access controls
Multi‑factor authentication
Full audit trails
Encrypted storage and transmission
Automatic, monitored backups
Secure disposal of digital data
4.3 File Structure & Naming
Staff must follow the approved file structure and naming conventions to ensure consistency and
rapid retrieval.
4.4 Inspection Readiness
Your document states:
“Inspectors must be able to access required information quickly and without delay.”
Digital systems must remain organised, searchable, and accessible for regulatory inspections.
5. Legislative & Regulatory Compliance
5.1 CQC Regulations
This policy supports compliance with the Health and Social Care Act 2008 (Regulated Activities)
Regulations 2014, including:
Updated Feb 2026 Fay Townsend-JacksonDigital Records Management Policy
Regulation 9 – Person‑Centred Care
Regulation 12 – Safe Care and Treatment
Regulation 17 – Good Governance
(Supported by your policy requirement that
“Records must be accurate, contemporaneous, and complete.”)
5.2 Data Protection & Information Governance
UK GDPR & Data Protection Act 2018
All digital records must comply with:
Lawful bases for processing
Data minimisation
Accuracy
Retention
Security
Rights of the data subject
Data Use and Access Act 2025
The agency will:
Maintain transparent data‑sharing practices
Provide clear explanations of how data is used
Maintain detailed audit logs
Restrict and monitor third‑party access
Ensure data‑processing agreements with all digital providers
Data Security & Protection Toolkit (DSPT)
The agency will complete the DSPT annually.
Caldicott Principles
All digital recordkeeping must follow the seven Caldicott principles.
Updated Feb 2026 Fay Townsend-JacksonDigital Records Management Policy
5.3 Accessibility & Equality
Equality Act 2010
Requires reasonable adjustments for disabled staff and service users.
Reasonable Adjustment Digital Flat 2026
The agency will:
Ensure digital systems are accessible
Provide alternative formats and assistive technology
Make reasonable adjustments to digital workflows
Train staff in inclusive digital practice
5.4 Digital & Cybersecurity Standards
Compliance includes:
Network and Information Systems (NIS) Regulations 2018
Cyber Essentials / Cyber Essentials Plus
NHS Digital interoperability standards
ICO cybersecurity guidance
Your document already supports this by stating:
“Digital files must be secure, with role-based access and audit trails.”
5.5 Records Management & Retention
NHS Records Management Code of Practice 2021
Electronic Communications Act 2000
Freedom of Information Act 2000 (where applicable)
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5.6 Safeguarding & Duty of Candour
Care Act 2014
Children Act 1989 & 2004
Regulation 20 – Duty of Candour
Digital safeguarding records must be secure, accurate, and promptly updated.
6. Roles & Responsibilities
Registered Manager
Ensures compliance with legislation and CQC requirements
Oversees digital governance and audits
All Staff
Maintain accurate digital records
Follow security protocols
Report breaches or concerns
Use only approved systems
IT / System Administrators
Maintain secure system configuration
Monitor backups and access logs
Support accessibility and reasonable adjustments
7. Training
All staff must complete training on:
Digital recordkeeping
GDPR and data protection
Cybersecurity
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Accessibility and reasonable adjustments
CQC compliance
8. Monitoring & Audit
Regular audits of accuracy, completeness, and compliance
Review of access logs and permissions
Annual DSPT submission
Findings used to improve practice
9. Review
This policy will be reviewed annually or sooner if legislation, technology, or regulatory
requirements change.
Updated Feb 2026 Fay Townsend-Jackson