Scottish Government response to harassment reviews

Scottish Government response to the reports by Laura Dunlop QC, James Hamilton, Independent Adviser on the Scottish Ministerial Code, and the Scottish Parliament Committee on the Scottish Government Handling of Harassment Complaints.

Record keeping and information management

The Committee report included a number of comments related to record keeping and information management. This included a recommendation that the Permanent Secretary should publish a statement setting out the requirements for record keeping under the Civil Service Code, and how the Scottish Government will improve its performance in meeting these requirements.

The Civil Service Code applies to governments across the United Kingdom and its statutory basis is set out in Part 1 of the Constitutional Reform and Governance Act 2010.

It sets out four civil service core values which civil servants are expected to uphold in supporting the Government of the day: integrity, honesty, objectivity and impartiality. It is part of the contractual relationship between an individual civil servant and their employer.

As part of the “integrity” core value, the Code states that civil servants must “keep accurate official records and handle information as openly as possible within the legal framework”[1]. The Code does not require that all meetings and conversations should be minuted.

Scottish Government officials have upheld the Code both during the period under scrutiny by the Committee and in the work to support the Committee’s inquiry.

Like many governments and large organisations across the world, the Scottish Government currently has a significant programme of work in train to evaluate and improve its information management processes across the range of its corporate activities.

The Committee specifically called for the Scottish Government review of information management to be published and also for the Scottish Government to review its compliance with its duty of candour and reflect on how a Commission and Diligence came to be required, how the Government responded to it and its governance arrangements.

The review of information management in the Scottish Government, which was commissioned by the Permanent Secretary in August 2020, is published alongside this response. The report makes clear that, like many organisations and institutions in this digital age, Scottish Government has reached a strategic tipping point in its approach to information management.

The review’s findings included:

  • There is a compelling case for the Scottish Government to re-evaluate and reset its approach to information management, to take advantage of new technology in order to support its business and minimise risk.
  • Information should be afforded equal strategic priority to other corporate assets such as people, infrastructure and finances.
  • The organisation’s information includes its record of work and should be protected by disciplined information and records management. Further action is required to ensure that policies and guidance, in compliance with information law, are fully implemented.
  • Whilst the eRDM (electronic records and documents management) system is used widely as the corporate solution for managing documents and records, there is also widespread use of alternative processes and systems for creating, storing and managing information. A change in culture is required in order to address this.
  • The Scottish Government has recently invested in its information management infrastructure by upgrading the eRDM system, acquiring new digital information management tools and developing a new model of blended training resources. These are strong foundations upon which to improve information management capability and reduce risk but they must be backed up by best practice and the right behaviours at all levels in the organisation.

The review also highlighted the need for improved information governance to enhance the Scottish Government’s capability and performance around compliance with information law, creating a more consistent and corporate approach to managing information and records, enhancing the security of information, reducing inefficiency and unnecessary costs and enabling future business and technology strategies.  

The key recommendations of the review were to:

  • Raise the corporate priority and strategic profile of information and records management to better reflect its business value and encourage improved behaviours and culture;
  • Implement a corporate whole-of-government information management strategy;
  • Establish a corporate information governance model;
  • Implement a corporate information management performance framework;
  • Manage down the availability and use of unstructured information repositories and develop clear criteria, guidance and policy for the management of information outside of the corporate eRDM system;
  • Deliver a corporate improvement programme to address key risks and gaps in the short to medium term whilst building a sustainable and responsive business model for best practice digital information management in the future;
  • Embed lessons learned in the implementation of new digital information systems; and
  • Review resourcing of information management within local, directorate and corporate functions.

The internal review reported its findings and recommendations to the Scottish Government Executive Team in January 2021. The Executive Team accepted the findings in full and a programme has been established to take forward the review’s eight recommendations. Work on each of the recommendations has already commenced.

In 2017, a major programme to modernise and transform our information infrastructure and systems began. This three-year programme has delivered significant benefits and implemented a number of improvements:

  • Modernising the infrastructure supporting corporate information systems;
  • Modernising the electronic records and documents management system (eRDM), increasing automation and reducing inefficiency improved training offered to staff;
  • Introducing an eDiscovery solution, which can search information across digital storage platforms and systems;
  • Introducing a new corporate cloud collaboration platform to enable safe and controlled sharing of documents with stakeholders and partners;
  • Digitising and preserving over 200,000 legacy paper records and files both created and inherited by the Scottish Government and its predecessors over many years; and
  • Strengthening the leadership and management in information governance.

Record keeping and information management: Scottish Government actions

We will:

  • Make changes to implement the recommendations in ‘A Review of Information Management in the Scottish Government’ including:
  • The setting up of a new Information Management Governance structure (already delivered);
  • New roles and responsibilities, dedicated to enhancing information governance at DG, Directorate and Divisional level;
  • A review of all information and records management training, guidance & policy;
  • Information Management Strategy in progress; and
  • Strategy for eDiscovery and legacy data management under development.




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