Further document retention considerations and requirements
4.1. When deciding on the most appropriate document format, please remember that records may need to be retained for a longer period than your normal organisation records retention policy requires.
4.2. You may need to label and store EU project records to prevent their premature destruction.
4.3. You will also need to consider practical issues such as storage space and the risk of damage or technological obsolescence.
4.4. You should give particular consideration to the risk of technical obsolescence of digital records, both the ICT hardware or software applications used to access the records.
4.5. Organisations holding records will need to ensure that original records are retrieved from all electronic records systems that risk becoming obsolete or no longer accessible.
4.6. To be clear, there is no expectation or requirement by the Managing Authority or the European Commission (EC) that hard-copy documents or ‘wet signatures’ must be used or are preferable to digital records. Indeed, the EC and the Scottish Government fully encourage beneficiaries to maximise the opportunities to embrace the benefits of paperless administration, where appropriate certification, as outlined previously is followed. Where electronic signatures and documentation are used and submitted via the EUMIS system, this is acceptable. Where documentation is not submitted via EUMIS, it must be received from an official email address within the Lead Partner organisation, and copied to a designated signatory.
4.7. Lead Partners should therefore note the guidance in Section 2 above and consider how technology can provide suitable methods to, for example, identity and authenticate a document, or demonstrate the authorisation of a transaction, information or decisions.
4.8. All records must be readily accessible for audits, verifications and any related investigations.
4.9. We will aim to provide you with as much notice as possible when we need to examine project records but, particularly as the EC is only required to provide 12 working days’ notice for their audits, you should ensure that arrangements are sufficiently robust to cater for such requests.
4.10. If records are unavailable during visits, related expenditure could immediately be declared as ineligible.
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