POL00448202
POL00448202
Chapter 06 Retention of Papers
Outline Process for filing and retaining Branch Assurance Working Papers
Contents
Introduction
Section 1- Standards for the Retention of Branch Assurance Visit Papers ....
Section 2 — Lead BAA Responsibilities
Section 3 — Branch Assurance Team Leader Responsi ies.
Document Admin..
Stakeholders
Responsibilities in change ..
AOA A MH BWwHN
Version control...
Author: David Nolan Version number: v5.0 Page 1of7 Internal Review Date: December 2025
POL00448202
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Chapter 06 Retention of Papers
Introduction
It is the responsibility of the Contract Advisor or Senior Investigation Manager to contact the Lead
Branch Assurance Advisor (BAA) they require the original paperwork from a BAV. In any event all
paperwork must be retained in accordance with the retention policy below.
It is often the case that a BAV is requested because there are concerns regarding operation of a
branch or there are concerns that POL funds are not being administrated/used correctly. Asa
result of a BAV POL have a number of resolution options available to them including but not limited
to acceptance that no issue has been found, writing off of a deficit, additional training or guidance
and support to the Postmaster and their staff, referral to a Contract Advisor which may in turn
result a suspension and/or termination of a Postmaster, or where there are grounds to suspect a
criminal offence may have been committed referral to the Central Investigations Unit.
Any kind of intervention which may culminate either immediately or future sanction action being
taken by the Contracts Team or an investigation into an alleged criminal offence, places certain
‘disclosure obligations’ on POL (see appendix ‘F’ of the Investigator’s Manual).
Section 31.2 of the Civil Procedure Rules 1998 applies to matters involving contractual issues and
requires POL to provide to the other a party a schedule of all documents stating whether ‘the
document exists or has existed’. If the matter were to proceed in a civil court the other party is
entitled to see all documents on the schedule unless the court rules otherwise and therefore, it is
essential that such documents are retained.
In matters relating to investigations into an alleged criminal offence the Criminal Procedure
Investigation Act (CPIA) 1996 requires POL to record, retain and reveal all ‘relevant material’.
Section 2.1 of CPIA defines material as:
‘Material of any kind, including information and objects, which is obtained or inspected in the
course of any investigation and which may be relevant to the investigation. This includes not only
material coming into the possession of the investigator but also material generated by him’.
It is clear from the above that all reports, BAA notes and any other items of significance (other than
cash, stock etc.) made or obtained during a BAV must be recorded and retained for possible future
reveal.
While ‘best evidence’ will always be the production of the original document, due to the volume of
work completed by BAAs it is acceptable to make a ‘true record’ of the original in electronic format
and retain the same on SharePoint. The paperwork will be stored for seven years in the Oasis
Archive.
The BART electronic Microsoft Excel form, when completed, holds most of the information that
needs to be retained following an BAV. They are stored on a SharePoint and this has therefore
considerably reduced the amount of manual paperwork.
‘Author: David Nolan Version number: v5.0 Page 2 of 7 Internal Review Date: December 2025
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Chapter 06 Retention of Papers
Original paperwork supporting an BAV will from time to time be required for a variety of purposes
(e.g. presentation at court during legal proceedings), and for this reason a policy of retaining such
paperwork has been introduced.
This policy covers the retention of manual documentation arising from BAV activity; stating periods
of retention, detailing storage arrangements, retrieval instructions, and destruction.
All BAV papers are to be retained by the lead BAA and held for a period of 60 days, within that 60
days the signed working papers must be scanned electronically and uploaded to the on-line
storage centre sensitive materials. This process is outlined below. This allows for any immediate
post-branch assurance visit queries to be raised and answered without delay.
Section 1- Standards for the Retention of Branch Assurance Visit Papers
1.1 All BART’s (electronic Microsoft Excel forms) to be retained on SharePoint for at least seven
financial years following the year in which the BAV was undertaken. Electronic files to be
deleted from laptops once confirmed on network server. However, in the event that sanction
action is envisaged all material must be retained until:
a) The decision is taken not to proceed against the individual (in a criminal court, seek civil
recovery or all appeal rights against a decision to terminate a contract have been
exhausted/or are time barred);
b) The individual is acquitted;
c) The individual is convicted;
d) The prosecutor decided not to proceed with the case;
e) The individual is released from custody (following conviction);
f) The individual is discharged from hospital (where the court imposes a custodial sentence or
a hospital order);
g) Six months from the date of conviction;
Whichever is the latter.
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1.2
1.4
1.5
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Chapter 06 Retention of Papers
Events requiring investigation may include:
e Suspension of Postmaster
Misuse of funds
Unexpected discrepancy greater than £1000
Admission of, or suspicion of, false accounting or theft
Irregular personal cheque on hand
Credit sales
Instances where unfamiliar circumstances are encountered. In these cases, a decision
to destroy or retain should be made following discussion with the Security Team.
The ‘material’ that must be retained should include but not limited to the following items:
«The signed working papers.
The documentation included in any Quality Assurance Review (QAR) must be retained by
the Branch Assurance Team Leader completing the QAR for a period of 7 years following
the completion of the QAR. This will ensure evidence is retained for possible use when
completing the Personal Development Review (PDR) or if QAR results are subsequently
questioned. It also allows documentation to be retained for external audit purposes, if
required.
Section 2 - Lead BAA Responsibilities
2.1
2.2
2.3
2.4
2.5
2.6
Ensure that all manual documentation is necessary and not excessive.
Ensure that standards outlined in Section 1 are adhered to.
Ensure the BART and CAT Tools are submitted, within 3 days for storage on SharePoint,
and deleted from laptop once transfer is confirmed.
Notify your Team Leader of any irregularities during BAV.
After 30 days and before 60 days the signed working papers must be scanned and stored
electronically for seven years. The documents will then be destroyed unless requested for
an investigation.
Record the BAV date, branch name, and branch code as the file name for these documents,
‘Author: David Nolan Version number: v5.0 Page 4 of 7 Internal Review Date: December 2025
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Section 3 —- Branch Assurance Team Leader Responsibilities
3.1
3.2
3.3
3.4
3.5
3.6
3.7
If a Branch Assurance Team Leader is designated as the lead, their responsibility is as
described above.
Monitor the supporting documentation retained using the QAR and 1-2-1 processes, and
ensure QAR’s are performed within 60 days of the date of the BAV.
BAV papers on which a QAR has been performed are to be retained by the Branch
Assurance Team Leader completing QAR for a period 7 years and then shredded.
Ensure that direct reports are aware of the standards and their responsibilities, and that
they are properly equipped (i.e. either be provided with, or have access to a shredder).
Monitor the supporting documentation retained using the Quality Assurance Review (QAR)
and 1-2-1 processes and ensure QAR’s are performed within 60 days of the date of the
BAV.
Ensure that expired documentation is destroyed using a shredder.
After 30 days and before 60 days the working papers are scanned and stored electronically
for seven years. The documents will then be destroyed unless requested for an
investigation.
‘Author: David Nolan Version number: v5.0 Page S of 7 Internal Review Date: December 2025
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Chapter 06 Retention of Papers
Document Admin
Location
Knowledge Centre — Branch Assurance Visit - Chapter 06 Retention of
Papers
Andrew R Morley
Subject Chapter 06 Retention of Papers
Version Control 5.0
Purpose Outline process for filing and retaining Branch Assurance Visit papers
Audience Branch Assurance Team
Next Review date December 2025
Stakeholders
Stakeholders Name Responsibility
Mike Lowe Head of Operational Excellance
Nayan Navik Branch Assurance Manager
Senior Investigations Manager
Responsibilities in change
Role Job Title(s) Date
Author David Nolan — Branch Assurance Team Leader
Assurance Mehl Singh - Branch Assurance Team Leader
Authorised Nayan Navik — Branch Assurance Manager
Communication Recorded in Knowledge Centre
Version control
Area Audit Manager
No Reason for issue Section No. Date Approval
441 Reference to Event capture form removed form I Introduction 27/10/2020
no longer used
Remove reference to Loss prevention All
2.0 Update with Service & Support Optimisation All 12/1/2021
3.0 Removed Audits, auditors, A & SA & National All 05/06/2023
Team Leader
3.1 Change Security Manager to Contract Advisor I All 9/6/2023
and amend reference to Security Team to
Act 1996.
4.0 Amendments made to reflect obligations as All 13/06/2023
set out in s31 of the Civil Procedures Rules
1998 and Criminal Procedures Investigation
‘Author: David Nolan
Version number: v5.0 Page 6 of 7 Internal Review Date: December 2025
Chapter 06 Retention of Papers
POL00448202
POL00448202
5.0
Retention of paperwork process updated
15/5/2024
Author: David Nolan Version number: v5.0 Page 7 of 7
Internal
Review Date: December 2025