Personal information shared by refugees at registration is classified as confidential. An individual’s file (physical or electronic, or both) is the central repository of personal information related to them, and as such must be properly handled and safely stored according to filing SOPs that reflect established standards for data protection and record keeping. The Fraud Vulnerability checklist contains a number of good practices that should be referred to when developing file management SOPs. Principles and standards outlined in UNHCR’s policies on Data Protection and the Management of Records and Archives should also be reflected in filing practices. In addition, staff are recommended to consult UNHCR’s Operational Guidance on the Protection of Personal Data of Persons of Concern, in which there is detailed guidance on physical and electronic filing.
- In order to track the movement and location of physical files outside of the storage room, a file check-out/check-in procedure must be implemented through local SOPs, ensuring an up-to-date tracking history of each file.
- Individual files are permanent records and should be stored in the operation for up to 20 years before being transferred to UNHCR’s archives in Geneva.
- Access, transfer and storage of electronic files must be protected and carefully restricted.
In operations where individual case management is carried out, a physical file is normally created at registration. Where case management is not conducted for all individuals (e.g. in many camp settings), any documents submitted by or in relation to individual refugees may be received, copied and placed in a binder, sorted by date or other criteria.
Physical files should be:
Physical files must contain all documentation relevant to the individuals in a group, filed in chronological order, including:
- asylum application forms;
- protection needs assessments;
- registration forms;
- RSD application forms;
- signed consent and/or disclosure forms;
- interview transcripts and counselling notes;
- copies of documents produced by the individual and dependent family members;
- home visit requests and reports;
- medical documents (such as Medical Assessment Forms);
- assistance-related documents;
- copies of Best Interest Assessments and Best Interest Determinations and related procedural steps;
- Resettlement Registration Forms;
- All relevant correspondence created and received by UNHCR, including any email specifically pertaining to the case.
- A File Action Sheet on which staff record a brief description of any activity relating to the processing of the claim, the date of the action, and the staff member involved.
Copies of documentation submitted by an individual should be stamped with “copy” or “copy of copy” as appropriate. Copies of originals should be noted with “original seen”, where the person has presented an original document. UNHCR should not keep original documents belonging to individuals.
Access to individual physical files
Case workers (and reviewers) should have access to physical files for cases that have been assigned to them, in line with their duties and responsibilities. Interpreters should not have access to individual case files. Procedures should be set out according to which access to physical files can be requested as well as the level of access authorized, including access by partners or other third parties.
Tracking the movement of physical files in an Office
In order to track the movement and location of physical files outside of the storage room, a file check-out/check-in procedure must be implemented through local SOPs by which requests, releases, transfers and returns of files are recorded, ensuring an up-to-date tracking history of each file. The staff member responsible for the filing room or records centre should maintain a list of all existing files and their location. Staff working on individual files may be requested to regularly re-check their files (for example, at the end of each week) to ensure file ownership records are up to date. File movement logs should be stored electronically wherever possible. When files are returned to the filing room or records centre, the content of the file should be checked (referring to page numbers) to ensure that documents have not been removed, replaced or altered.
There is no corporate File Tracking System (FTS), but FST tools are used in most large operations and are increasingly integrated with proGres v4. IMRS maintains a stock of barcode readers and barcode printers in the registration stockpile.
Individual files should be stored in a lockable room or secure place designated for this purpose within (or near) UNHCR’s premises, safe from water, fire and temperature damage. It should be at or above ground level and constructed with non-combustible materials. The roof and walls should be waterproof, and windows securely barred against intrusion, with shades or shutters fitted to block sunlight.
Shelving should be made from steel or other non-combustible materials, and braced to prevent collapse. Hanging file systems are preferable in terms of maintaining file condition and have also proven to be effective in case of refugee influx where emergency storage capacity is needed.22 A number or letter should be assigned to each row of shelving, with each row end labeled with the number on the last file and with the type of records housed within the row. Records should be shelved from left to right and top to bottom in each section.
Access to the storage room or facility must be controlled, monitored or restricted (through, for example, access cards, physical control barriers, local or remote monitoring systems), with only authorized personnel granted access to enter. It is recommended that filing staff are present when cleaners, security personnel or others enter the room, and all individuals should be requested to sign in and sign out. The room must be kept locked when unattended, with keys/access cards kept by designated individuals only (for example, the Filing Assistants, the Data Protection Focal Point or the Data Controller ). Individual files are permanent records and should be stored in the operation for up to 20 years before being transferred to UNHCR’s archives in Geneva. Files that are at risk (security or environmental) or otherwise unable to be safely stored locally may be transferred to Geneva as and when necessary, in consultation with RAS.
Outside the designated storage facility, personnel must keep case files in a locked cabinet or drawer during the times when they themselves are not at their desk. Files should not be left in interviewing rooms while personnel are not present. Individuals should only have in their possession those files they are actively working on.
Periodically, and at least every five years, Offices should implement a procedure to ascertain which individual case files are no longer needed for operational purposes, and, in accordance with the retention periods established in the UNHCR Records Schedule, transfer them to RAS to be preserved in the UNHCR Archives.
22 RAS can provide guidance on optimal file storage system design and warehousing.
Personal data stored in electronic format is particularly vulnerable to accidental, unlawful or illegitimate destruction, loss, alteration, as well as unauthorized disclosure or access, due to the ease with which it can be copied, transferred. Access, transfer and storage of such data must therefore be protected and carefully restricted. Data Controllers are responsible for ensuring that infrastructure and databases are established and used according to required standards. In particular:
- with respect to access control, access to electronic files is tiered, so that personnel only have access to what they need to for the purposes of performing their duties and responsibilities, (i.e. a “need-to-know” basis). Access rights are normally defined by the Heads of Units, approved by the Data Controller, and updated by a database administrator. Access rights should be reviewed regularly;23
- with respect to secure transfer, security should be maintained when sharing the information: instead of sending files as email attachments, it is preferable to save the document in e-SAFE and send only the link, for example;
- with respect to secure storage, operations are recommended to only use corporate UNHCR tools, document management applications, and network drives with controlled accessibility, as the use of non-UNHCR approved tools can undermine data security. Offices with reliable internet access are recommended to store electronic files in e-SAFE, or alternatively, a restricted shared drive.
23 See user management guidance for proGres v4. For e-SAFE, access rights are updated by RAS.
Operations may initiate, in consultation with the Records and Archives Section, digitization of paper records, in order to address constraints in the physical file environment or to transition towards a paperless filing system. The digitized files should be saved in e-SAFE. If this is not available in the operation, RAS can be contacted to set it up for the purposes of the project. Refer to UNHCR’s Guidelines for digitization for further guidance on legacy digitization and ongoing business process digitization.
Operations may decide to embark on a digitization project where:
The final disposition of the physical record should be decided in consultation with RAS.