Archives and records management policy

Approved by the Board of Trustees: 13 May 2020
Date of Next Review by the Board: 2025

1) Introduction

The National Portrait Gallery recognises that its records are an essential business resource; and that their efficient management is necessary to support its core functions, to comply with its legal and regulatory obligations and to contribute to the effective overall management of the institution.

This paper sets out the policy with regard to all records created and managed by the Gallery as part of its everyday business. This policy document can be found on the Gallery’s network and is available to the public through the Gallery’s website.

2) Scope

The aim of this policy is to provide a framework for managing the Gallery’s records, to support the development of a Records Management programme and thereby minimising the risk of breaching relevant legislation (see 4. Legal Basis).

This policy applies to all records created, received, maintained and accessed by National Portrait Gallery employees, workers, contractors and volunteers in the course of their work.

3) Definitions

A record is a document in any format that has been generated or received by the National Portrait Gallery in the course of its activities and has been, or may be, used by the Gallery as evidence of its actions and decisions, or because of its information content. This does not include works in the primary, photographs, reference or library collections. Records can be held in any format including, but not limited to, paper documents, photographs, electronic files, e-mails, other messaging applications, videos, slides, audio recordings, databases or any multimedia formats.

Records Management is the strategic and systematic control of the creation, receipt, maintenance, use and disposal or preservation of records.

Archives are records selected for permanent preservation which ensure that the Gallery meets its statutory record keeping requirements as a Non-Departmental Government Body and Nominated Place of Deposit for public records by capturing and managing authentic and reliable records to demonstrate evidence, accountability and information about its decisions, activities and collections. Archives also protect the Gallery’s corporate memory, and are available as a resource for research.

Electronic Archive Drive (I) is a space on the Gallery network exclusively for records in electronic format that have been identified as having permanent historical value. Records can only be added by archive staff using appropriate procedures, access is provided to Gallery staff by request to the Archive team through the Reading Room folder.

4) Legal Basis

The records of the National Portrait Gallery are subject to, and therefore will be managed in accordance with legislation, such as:

  • The Public Records Acts, 1958 and 1967
  • The Museums and Galleries Act, 1992
  • The Data Protection Act, 2018
  • The General Data Protection Regulation (GDPR), 2016
  • The Freedom of Information Act, 2000
  • The Requirements of HM Customs & Revenue

The Gallery is, therefore, committed and undertakes all effort to comply with, the Secretary of State’s Code of Practice on the management of records issued under part 1 of section 46 of the Freedom of Information Act 2000. Selected born digital records will be maintained electronically in the Electronic Archive Drive (I) and catalogued as part of the Gallery Records sequence of the archive. While issues relating to the management and long-term preservation of electronic records are addressed, some significant electronic records will be maintained in both paper and electronic formats according to agreed retention schedules.

In addition, the NPG Archive as a nominated place for public deposit is required to hold accredited status by the National Archives, this ensures standards are being maintained and records looked after appropriately. The NPG Archive was awarded accredited status and received confirmation of place of deposit status in March 2018. Accredited Archive Service Status is granted for up to six years, with a light review of the service midway through this period.

5) Statement of Principles


  • The National Portrait Gallery is committed to creating, keeping and managing its records in a manner that accurately documents its principal activities.
  • It is committed to maintaining essential paper and electronic records in the long term and to preserve their authenticity, reliability, integrity and usability for future generations.
  • It is committed to a culture of openness and access to information wherever possible, in accordance with statutory requirements. Access to records is provided to the public through the Public Study Room according to review.
  • It fully supports a centralised and Gallery-wide Records Management programme that is based on national and international standards in the field (e.g.BS ISO 15489-1:2016).

Ownership of Records

  • All records created and received by the National Portrait Gallery in the course of its business are owned by the National Portrait Gallery, and not by the individuals, departments or teams that create the records.
  • Records should not be removed from the offices or networks of the National Portrait Gallery or used for any activity or purpose other than the Gallery’s official business.
  • Access to records is granted by the Records Manager and the Archivist in accordance with approved procedures. Records should be logged out and remain on National Portrait Gallery premises at all times (an exception to this is records approved for exhibition loan).
  • See 8. Breach of Policy for action taken by the Gallery for any unauthorised or malicious use or removal of records.

Purpose of Records Management

Records Management will help ensure that the Gallery:

  • Achieves its objectives to promote through the medium of portraits the appreciation and understanding of the men and women who have made and are making British history and culture; and to promote the understanding and appreciation of portraiture in all media.
  • Creates and captures authentic and reliable records to demonstrate evidence, accountability and information about its decisions, activities and collections.
  • Maintains securely, and preserves access to, those records as long as they are required to support Gallery operations, including audit purposes.
  • Identifies and protects the Gallery’s vital records (i.e. those records which need to be retained to meet statutory record keeping requirements or which would be needed to re-establish the business of the Gallery in the event of a disaster, and without which it could not operate).
  • Identifies and preserves securely those records deemed worthy of permanent preservation, thus protecting the Gallery’s corporate memory.
  • Destroys records once they are no longer required according to agreed retention schedules, thus ensuring the efficient use of Gallery accommodation, electronic storage systems and compliance with legislation.
  • Meets relevant record-keeping requirements, including the Public Records Acts 1958 and 1967, the Freedom of Information Act 2000 etc.

6) Responsibilities

Effective Records Management is a shared responsibility.

Senior Management is responsible for approving and promoting compliance with Records Management policies and procedures, and supporting the implementation of a Records Management programme, throughout the Gallery.

The Records Manager is responsible for delivering the operational activities of a Records Management programme, and for the development and implementation of related procedures and guidance.

The Archivist is responsible for the capture and management of records for permanent preservation, and for the development and implementation of related procedures and guidance.

Heads of Departments are responsible for the ongoing maintenance and compliance with record keeping procedures in their departments.

Individual employees, workers, contractors and volunteers are responsible for creating and maintaining records in accordance with best practice.

7) Procedures

Relevant best practice procedures can be found on the Gallery’s network. For advice on specific issues staff should contact the Records Manager or the Archivist. Mandatory records management and information access legislation training is provided to new starters in relevant roles.

8) Breach of Policy

Knowingly and maliciously breaching the Gallery’s Records Management procedures or any relevant governing legislation will be dealt with in accordance with the Gallery’s disciplinary procedure.

9) Review

The Archives & Records Management Policy will be reviewed at least every five years (with interim reviews where necessary). The next scheduled review is 2025.

10) Date of Approval

Approved at the meeting of the Board of Trustees on 13 May 2020.

11) Related Policies

All policies should respect and reflect the Archives and Records Management Policy. The following have particular relevance:

  • Information Security Policy
  • IT Acceptable Use Policy
  • Data Protection Policy
  • Employee Handbook