FOIMan recalls the impact a flood can have on an organisation’s information – especially if it chooses to store it in a basement.
It’s a terrible sight seeing people wading through their own homes. Those who live along the Thames, in Somerset, and elsewhere are having a terrible time and most of us can’t imagine what that must be like.
Floods can cause significant problems for information managers and their employers. Back in 2000, the south of England was suffering from a similar surfeit of wet weather. At the time, I was records manager for a council on the south coast. Many if not most organisations use basements as storage for their physical records (and often servers containing their digital records too).
And why not? These spaces are convenient and often very large. They’re otherwise wasted space – too dark and gloomy to accommodate human beings (unless they’re records managers or trogladytes).
Well, I’ll tell you why not. They’re also often damp. Many boxes were starting to show signs of mould. The plaster was peeling away from the wall. After 18 months of buttering up the Facilities Manager I finally got our office replastered and painted. We even got a plush(ish – it was local government after all) new carpet to replace the bare threads and occasional tufts of fabric which I had been assured were once a carpet about 15 years before. Which brings me to the other reason why it’s often a bad idea to store records in the basement.
Because when, like this year, there is so much rain that streets start to look like tributaries of a major river system, the sewers overflow. And the sewers in the area that I worked ran just beneath…you guessed it, the basement of the council offices. So in early 2000, you could find me wading ankle deep around a vast storeroom trying to move boxes of records above an ever-rising flood. It was like a not very exciting Indiana Jones film.
Eventually the waters subsided, and the dehumidifiers begged from the Museums Service chugged away at their heroic (and probably futile) task. A few building plans and housing files that had sunk beneath the waves were collected by a company, Harwell Document Restoration Services, that specialises in rescuing waterlogged papers. A few weeks later they would return, looking better than they had before (which wasn’t saying much). The tiles in the storeroom had lifted under the pressure of water gushing from beneath, and needed replacing. Records were sent off-site temporarily to a commercial storage company in rotation so that the floor could be repaired and retiled. And we got a (slightly less plush) carpet fitted in the office. And things returned to normal. Well, not quite. I’m sure it wasn’t entirely unconnected, but later that year I decided to climb out of the basement and found a job in London as Parliamentary Records Manager. Being based in the Victoria Tower, I figured there was much less chance that I would face another flooded records store.
Shortly after that, in early 2001, I received an email from my successor. The basement had flooded again.
If you are a facilities person, or a chief executive, and you think that you can save money by putting your records (and information managers, come to that) in the basement, you might want to think again. Aside from the fact that waterlogged records tend to make a mess of your lovely leather-embossed desk when you need to access them, there is a very good chance that your organisation will fail to meet its legal obligations. Aside from the many statutory requirements to retain information – auditors are probably going to be less than impressed if they have to don waders to check your receipts – failure to properly protect records will most likely be a breach of information law these days.
Section 46 of the Freedom of Information Act requires the Lord Chancellor to issue a Code of Practice on the management of records. The Code is written by the experts of The National Archives, and one of the requirements of the Code is that:
“Authorities should know what records they hold and where they are, and should ensure that they remain usable for as long as they are required.”
That Code is not statutory (though the Information Commissioner can take it into account in working out whether to take action against a particular authority), so perhaps more important to note is that retaining records – especially those relating to living individuals – in a basement that is prone to flooding is likely to constitute a breach of principle 7 of the Data Protection Act.
It is common knowledge that losing personal data on an unencrypted memory stick or a social worker leaving a file relating to a vulnerable child on a train can land an organisation with a fine of up to half a million pounds. But principle 7 also requires data controllers to take “appropriate technical and organisational measures” against “accidental loss or destruction of, or damage to, personal data”.
Businesses and public authorities in flood-hit parts of the country will have other – and perhaps more urgent – things on their minds at present. But all organisations should think very carefully about whether bargain basement storage really is the opportunity it appears.
Image by Keith Moseley (Drybridge Street Flooded, Monmouth) [CC-BY-SA-2.0 (http://creativecommons.org/licenses/by-sa/2.0)], via Wikimedia Commons.