ESF Information Memo 04/23 - Guidance on document retention

Dear Project Promoter,

Purpose

Although the 2014-2020 ESF Programme ended in March 2023, I would like to remind projects of their obligations in relation to document retention as outlined previously in ESF Memo 07/21 and ESF Memo 02/23.

In accordance with Article 140 of the Common Provisions Regulation (CPR), beneficiaries must ensure that all documents relating to each operation and its implementation and financing are retained until 31 December 2030. This requirement is clearly laid out in each project’s letter of offer and Section 3.5 (Audit Trail and Document Retention) of the Call 3 Operating Manual.

However, this requirement must also be carefully balanced with the GDPR principle of data minimisation, meaning that organisations should only retain personal data that is relevant and necessary to meet Article 140 of the CPR. Furthermore, should the department already hold certain pieces of information in our own records management system or on the ESIF database, there is no requirement for delivery organisations to continue to hold it.

To assist in identifying the types of documentation you are required to retain, Table A outlines the operations for which documents should be held, the caches of documents that the department already holds, and examples of what residual documents delivery organisations should therefore retain.

Please note the list of documentation at Table A is not exhaustive. If in doubt about whether documentation should be retained please contact the division at EuropeanFundManagement@economy-ni.gov.uk.

Organisations that will no longer exist post ESF

The Operating Manual states that In the event of the termination or closure of the operation, all documentation must be returned to the Managing Authority or relevant Intermediate Body.

If you anticipate that your organisation will no longer be in operation, you should inform us by emailing EuropeanFundManagement@economy-ni.gov.uk to discuss and progress arrangements for the retrieval of the documents to be retained by organisations. These documents must be converted to electronic versions which can be easily sent to PDB and stored on the department’s records management system.

I would be grateful if you would bring the contents of this memo to the attention of your staff and/or project partners.

Regards,

Kevin McVeigh
Head of ESF Managing Authority

Table A

Guide for document retention

Operation for which documents should be retained	Documents already held by DfE/ESIF database	Examples of documents to be retained by delivery organisations
Claims Processing	Timesheets (Calls 2&3) Annex As (Calls 2&3) Appendix 1s (Calls 2&3) Letters of Offer Contracts of Employment for Call 2 Confirmation of Role Forms for Call 3 Insurance Certificates	Timesheets for Call 1 Audit Trail in support of submission and approval of electronic/e-signature timesheets Payroll Records Bank Statements for period of grant Supporting evidence for nature and hours worked, e.g. Attendance sheets, Calendar entries etc
Procurement of contractors	None	All documentation relating to Procurement. Including, but not restricted to Procurement Specifications, Bids Received, Evidence of award decisions. Refer ESF Info ESF Memo 27/21
Eligibility of participants	List of verified participants from Call 1. Disability Declarations (Disability IP only) Prisoner Declarations Eligibility Document if not using NINO (Call 2+3) PTPs Participant Details Form	Call 1: Applications Forms Call 1: Evidence of outcomes Calls 2&3: Any Eligibility documents not uploaded onto ESIF. Any PTPs not uploaded to ESIF.
Participants’ outcomes	Immediate Result Indicator Evidence or Declaration (IRIs) Long Term Result Indicator Evidence or Declaration (LTRIs)	If ESIF is up to date, no further documents are required to be held by the project.
Publicity requirements	Evidence of delivery organisations meeting publicity requirements.	None