Audit Evidence Retention Policy¶
Policy version: clinical-security-v1
Status: technical default awaiting deployment-specific records-manager and DPO approval.
Schedule¶
The default minimum retention period for clinical/security audit evidence is ten years from the recorded event. Evidence inherits a longer period when the related clinical record, contract, statutory inquiry, litigation requirement, or approved local schedule requires it.
Every ledger envelope stores the policy version and calculated retain_until.
Later policy changes create a new version. They do not rewrite past decisions.
End-of-period review¶
retain_until means eligible for review, not automatic deletion. The reviewer
must confirm the governing record category and current law or policy. The
review must also cover open incidents, inquiries, litigation, complaints, and
legal holds. Continued retention needs a reason and review date.
No automated disposal is enabled. A future disposal workflow must produce an immutable manifest identifying the approved scope, policy, approvers, time, and resulting Object Lock/database disposition.
Legal holds¶
When a hold is issued:
- Record its authority, scope, owner, start date, and review date in the organisation's records system.
- Stop disposal for every matching chain/export.
- Extend Object Lock retention where required. Never shorten existing retention.
- Record the change/incident reference in the signed evidence manifest.
- Require records-manager or legal approval to release the hold.
Database-owner changes made to apply a hold require a separate external change record.
Reference: NHS Records Management Code of Practice 2021.