Record Keeping Culture and Audit
RHI Inquiry · The Report of the Independent Public Inquiry into the Non-Domestic Renewable Heat Incentive (RHI) Scheme · Issued 13 March 2020 · Addressed to: Northern Ireland Executive
Government responseNorthern Ireland Executive: Accepted (Oct 2021)
DeliveryNorthern Ireland Executive says in progress (Feb 2025)Department of Finance says in progress (Nov 2024)The Executive Office says in progress (Oct 2024)
Recommendation, verbatim from the inquiry
●Inquiry recommendation
The culture and practice of record keeping and access to records within the Northern Ireland Civil Service needs to change so that staff responsible for a given area of work have easy access to the analysis and decisions underpinning the policy or initiative on which they are engaged. Regular audits of record keeping should be undertaken so as to ensure that important information is recorded, is easily identifiable, is readily accessible and remains so for as long as is necessary in respect of any policy or initiative. In addressing this recommendation, there should be a review of the NICS electronic information management system and how it is used by civil servants. Steps should be taken to ensure that the systems which civil servants are expected to use are fit for purpose and facilitate the easy saving, storage and subsequent location and use of relevant material.
RHI Inquiry, The Report of the Independent Public Inquiry into the Non-Domestic Renewable Heat Incentive (RHI) Scheme · 13 Mar 2020 Source PDF →
Published evidence summary
AI-generated evidence summary
The Inquiry called for civil service record keeping reform, regular audits, and information system reviews. In February 2025, the Northern Ireland Executive described action on regular audits and management monitoring, stating that internal audit routinely considers records management, while a proposal for a thematic review in 2026/27 remains subject to rolling out the governance framework across all departments (Northern Ireland Executive, Feb 2025). In October 2024, the Northern Ireland Audit Office found that the recommendation as a whole was not likely to be fully implemented based on planned action (Northern Ireland Audit Office, Oct 2024).
AI-generated summary of the record on this page, checked by a second model and automatic checks, 1 Oct 2026.
About this summary
Government response
●Northern Ireland Executive · Accepted · 7 Oct 2021
These recommendations can be accepted in full.
They have been addressed through work to date through:
• revisions to the NICS Code of Ethics and production of the Guidance for Ministers;
• new corporate guidance developed for Private Offices;
• the strengthening of Private Offices by the redefining and higher grading of the Private Secretary and Assistant Private Secretary roles;
• planned induction, training and ongoing support for Private Office staff;
• existing practices such as reviews of retention and disposal schedules and Information Asset Registers;
• the project to review how the NICS carries out its Records Management responsibilities and improving its current electronic storage system (HPRM) for all users;
• the launch of an NICS data-protection and information management hub.
• Completion of NICS reviews of records management and HPRM optimisation;
• upgrade of the current records management software;
Further work is required to
• review and update Private Office guidance in light of recent experience;
• further address the culture and behaviours surrounding record keeping in the NICS;
• Complete a reporting exercise to ensure that products designed to address these recommendations have been appropriately embedded within all Departments
Response document: Executive Response to the RHI Inquiry Report Recommendations and Action Plan: Annex A Summary of Recommendations and Response
Delivery
●Northern Ireland Executive says in progress · 19 Feb 2025
Internal Audit routinely considers records management within their specific audit exercises.
The Records Management Governance Framework sets out the arrangements for ongoing monitoring by management.
DoF shall bring forward a proposal to NICS Board to commission Internal Audit to conduct a thematic review of the Records Management Governance Framework in the 2026/27 year subject to the roll-out of the Records Management Governance Framework across all Departments.
From: Implementation of the Recommendations of the RHI Inquiry (publication page for three documents)
●Department of Finance says in progress · 5 Nov 2024
The inquiry recommended that regular audits of record-keeping should be undertaken. Significant work has taken place on record management, going beyond the recommendations of the RHI inquiry. That work includes a review of information management policies to identify and address any gaps, taking account of emerging findings from the COVID inquiry; a new mandatory records management e-learning training package being rolled out to all staff; and the reconstitution of the information governance board as the senior information risk owner (SIRO) forum.
The Audit Office report identifies one small element of just one of the recommendations on records management that it assesses as unlikely to be implemented. That is to commission internal audit to review the implementation of the new arrangements. It had always been the intention that internal audit should be commissioned to undertake a thematic review of information management, but no date had been set. Such a review will be of value only once the new arrangements have had a chance to be established and effected, so that we look not just at the implementation of the RHI inquiry recommendations but at further recommendations that have come through the COVID inquiry.
From: Official Report (Hansard), Tuesday 5 November 2024: RHI Inquiry Recommendations: Implementation, Dr Archibald, Minister of Finance
●The Executive Office says in progress · 23 Oct 2024
Recommendation 28(2) refers to the audit of record-keeping that we talked about: a thematic audit across record-keeping. The Audit Office acknowledged that two of the record-keeping requirements, on the substance of the ministerial meetings and the advice provided at them, have been delivered, but there was no audit to prove that that happened, and that is what we will undertake. I clarified that audits are taking place and that records management is a standard part of group internal audit that is raised —
Earlier statements on delivery (0)
●The Executive Office · 26 Jun 2024
There were specific instances with record management, particularly the non-disclosure of handwritten notes. The substantive notes for meetings were provided. That was one disclosure among the tens of thousands of documents that were provided, although that does not excuse the fact that there was no provision in that instance. Actions were taken immediately to address those issues at a function delivery level but also at a technology systems level. I know that one of the areas in the RHI inquiry was looking at the use of technologies and the content management systems, and that has been explored.
One of the areas that we have pursued is the reconstitution of our information governance board, which is led by the Department of Finance. I have met the Information Commissioner and our network of senior information risk owners (SIROs) on that so that we can reconstitute the board to address the learnings that we need to take forward.
I come from a technology background, so one of the key areas for me is that, sometimes, our technology platforms work against us. I know that that formed part of one the RHI inquiry's recommendations, including the use of systems such as Content Manager. We have now rolled out Office 365, which is a cloud-based system for modern-day record and content management. I have observed that we sometimes conflate official record management with document management, which should be two separate things. Office 365 allows us to do that and has been rolled out to 27,000 staff in the past two years. It is now available on mobile platforms where, again, some of those issues were identified. It is available on around 30% of mobile devices. We need to put in place technology and systems that act in line with the policies and processes that we have in place.
From: Official Report (Hansard), Minutes of Evidence: Committee for Finance, 26 June 2024 (Northern Ireland Civil Service Reform: Dr Jayne Brady, Head of the Civil Service), Dr Jayne Brady, Head of the Northern Ireland Civil Service
●Department of Finance · 7 May 2024
My Department developed new guidance for the Civil Service in June 2022 for official information that is held in non-corporate communication channels. That guidance sets out when non-corporate devices or communication channels may be used for official business and how any official information, including WhatsApp messages, should be handled. The guidance will be translated into policy and disseminated across Departments by 31 May 2024. As I mentioned, it is each individual's responsibility to ensure that all relevant information is retained on Content Manager, which is an official repository for Civil Service documents and record management. That is clearly set out in the overarching Civil Service record-management policy and NI Executive codes of conduct.
From: Official Report (Hansard), Tuesday 7 May 2024: topical question "RHI Inquiry: Implementation of Recommendations", Dr Archibald, Minister of Finance
●Department of Finance · 14 Mar 2024
Ongoing monitoring of compliance within departments in general would be the role of management; this is, in effect, what the Records Management Governance Framework is intended to achieve.
The option of NICS Internal Audit Services conducting a thematic review of compliance with the Records Management Governance Framework should be considered in the context of a wider exercise to address records management as a cultural and ethical matter.
The NICS has now migrated to Microsoft Office 365 (MS365) and is seeking to put in place a project team to explore how it meets its obligations for future retention, accessibility, utilisation and disposal of NICS information records. A programme of work is underway to enhance the performance of the current electronic document and record management system.
From: Implementation of the Recommendations of the RHI Inquiry (publication page for three documents)
●Department of Finance · 1 Sep 2023
Ongoing monitoring of compliance within departments in general would be the role of management; this is, in effect, what the Records Management Governance Framework is intended to achieve.
The option of GIAFIS conducting a thematic review of compliance with the Records Management Governance Framework should be considered in the context of a wider exercise to address records management as a cultural and ethical matter.
From: Implementation of the Recommendations of the RHI Inquiry (publication page for three documents)
What other bodies have found
●NI Audit Office · 15 Oct 2024
The recommendation as a whole is not likely to be fully implemented based on the planned action.
This specific aspect of the recommendation: Implemented.
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