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2.5 File management and record keeping

Management of digital files and records

Each UNHCR office is required to implement file management procedures in line with UNHCR’s Policy on Management of Records and Archives and the data protection and privacy principles set out by the General Policy on Personal Data Protection and Privacy. The Fraud Vulnerability checklist also contains key standards on file management procedures and controls.

ProGres is the primary tool for Resettlement Case management, including records of assessments completed, recommendations made, interviews conducted, decisions, reviews, withdrawals and departures. It is best practice to record all case information exclusively in the respective fields in proGres. Controlled user management for proGres and other PRIMES tools, as well as responsibilities and accountabilities associated with each of the various access levels, should be explained in SOPs. The Personal Data Controller in the country office is responsible for establishing tiered access to electronic files so that colleagues only have access to what they need for the purposes of performing their duties, including caseworkers, interpreters and other colleagues. Detailed guidance on access control is available in the Guidance on the Protection of Personal Data of Persons of Concern, the Administrative Instruction on Access Controls Management for ICT Systems, Applications and Services, and the guidance on Electronic Storage And Transfer Of Personal Data Of Persons Of Concern Outside Primes (internal).

Sharing and storing digital files

Active Resettlement Case files must be password-restricted and stored on a UNHCR corporate online platform e.g. SharePoint Team sites or eSAFE. When no longer in active use, digital Case files (including copies of personal documents, UNHCR work products and other documents that constitute the Case file) must be saved in eSAFE as permanent records. Information related to individual case files (whether active or inactive) must not be stored on personal network drives.

When sharing documents containing personal data, including RRFs, transcripts, notes, documents, assessments and other confidential information, whether internally among colleagues or externally to resettlement countries or partners, it is best practice to use the Secure File Sharing platform, available here. For sharing in the context of collaboration on Resettlement Cases, SharePoint Team sites can be used.

If communicating by email on individual cases, internally or externally, proGres individual/ case numbers should be used instead of individual names. It is good practice to use links to entities in proGres such as individuals, registration groups, referrals, RSD cases and resettlement cases, where recipients have appropriate proGres user profiles. In any event, names and other personal data must never appear in the subject line of any email.

File transfer and file tracking methods in the office should be set out in SOPs. See Cybersecurity tools, solutions & services on the UNHCR intranet page for more information. See also 2.3 Data protection in resettlement for further guidance on compliance with the principle of Security.

The Resettlement Module in proGres

The Resettlement Case entity in proGes v4 defines a standardized pre-submission and post-submission workflow and mandatory process steps. Other entities for Resettlement Interviews, Reviews and Audit History support good case management practices and promote integrity. User profiles for the Resettlement module in proGres should normally be limited to UNHCR colleagues. Baseline SOPs, User Guides and other guidance documents on the Resettlement Module can be found at PRIMES Support.

All Resettlement Case processing should be recorded, monitored and tracked in proGres.

ProGres is the primary source of personal data on refugees and asylum seekers and a critical tool for individual Resettlement Case management. This includes monitoring cases on hold and/or pending processing and ensuring adequate oversight and information sharing on the status of such cases (together with the regional bureau). In addition, data from proGres informs regional and global reporting, analysis and oversight.

The accountable officer for resettlement should ensure that resettlement audits are conducted using the dedicated PRIMES Audit Portal and/or the Audit History entity in proGres for specific queries. Parallel databases and offline Excel sheets are strongly discouraged since they increase the risk of inconsistent, incomplete and inaccurate case information. Inadequate reflection of the status of cases in proGres results in inaccurate reporting on resettlement and inadequate identification of cases at different processing stages for follow up.

As an online system, proGres allows for improved coordination within and between country offices, the regional bureau and headquarters. UNHCR colleagues in different offices with appropriate access to the Resettlement Module and other data in a proGres business unit, can enter, share and review information directly in proGres. 

Management of physical files and records

The information contained in individual physical files must be consistent with the information in digital files and the corresponding proGres record. All information kept in physical files must be digitally stored and recorded in proGres. Original documents of displaced of stateless persons should not be stored by UNHCR.

Physical case files require a centralized filing system with File Tracking System (FTS) used by all functional units. Requests, releases, transfers and returns of files are recorded on a File Action Sheet and file movement logs are stored electronically. If physical files and/or hard copies of documents are kept at the operational level, they must be securely handled in accordance with relevant UNHCR policy and guidance. Detailed guidance on physical file management of resettlement information, including contents, storage and access control is available in the Guidance on the Protection of Personal Data of Persons of Concern, Unit 2.2 of the RSD Procedural Standards (File Management and Recordkeeping Procedures) and UNHCR’s Guidance on Registration and Identity Management. See also 2.3 Data protection in resettlement for further guidance on compliance with the principle of Security.

Storage of audio and video recordings

Audio recordings of resettlement interviews must be stored securely (preferably in e-SAFE) with access restricted to authorized colleagues only. Recording devices should be kept in a secure location, and all electronic copies of videos/tapes should be clearly linked to an individual file and securely disposed of, in line with data protection and privacy principles.

Country offices considering introducing cameras in interview rooms and/or video recording for interviews are recommended to consult the Personal Data Controller in the country office, Field Security Service (FSS) and DIST in headquarters, in order to reach the best decision based on data security, data storage, data protection and case management considerations.