Project Document Retention 1. Contractual Requirement... 2 2. Time Period for archiving Records... 2 3. Responsibility for record keeping... 2 4. Partnership Agreement... 2 5. Access and Audit Requirements... 2 6. Document Retention... 3 7. Information Categories to be Retained and Archived... 3 8. Closure of Partner Organisations or Sub-contractors... 6
1. Contractual Requirement SCY (Science City York) and partners are required to manage the project in accordance with relevant Department for Communities and Local Government (DCLG) and European Commission (EC) policies and the Offer Letter (Contract) issued by Yorkshire Forward (YF) for the Embedded Business Space and Technology Transfer Project (EBS&TTP). This includes keeping accessible records of required project documentation. The documents must facilitate audit of the project by DCLG and/or the EC auditors and should provide a complete audit trail of evidence that ERDF funds have been managed and expended compliant with EC rules and regulations. Project records must also demonstrate evidence of the progress and achievement of the contracted outputs. 2. Time Period for archiving Records The time period for archiving all project documentation is driven by the requirements of the European Commission (EC) and the timescales of the overall European Regional Development Fund (ERDF) programme 2007 to 2013. The programme expenditure ends in December 2013 and the EC is expected to close the overall ERDF Programme by 31 December 2025. All records should be kept until DCLG provides formal notification that the grant recipient may dispose of its records. 3. Responsibility for record keeping All the partners (SCY, UoY and Fera) are responsible for maintaining records related to their element of the project in accordance with the partnership agreement. Where sub-contractors are used, partners are responsible for quality assuring the record keeping of contractors and for ensuring adherence to document retention requirements. 4. Partnership Agreement SCY has a partnership agreement with the University of York and FERA for the delivery of the project. Each partner is responsible for maintaining the records relating to their strand of the project and for adhering to all the document retention requirements. 5. Access and Audit Requirements The project can be inspected at any time up to closure of the overall programme. DCLG or the EC are may request access to the project documentation at any time of their choosing. YF completed an Article 13 audit at the beginning of the project. DCLG will commission Article 16 project inspections or other national and EC audits as required. SCY are also required to commission independent audit of the financial claims each calendar year and must submit a Statement of Grant Expenditure (SOGE) signed by the independent auditor.
6. Document Retention The project records must clearly demonstrate: 6.1. Creation of and adherence to a document retention policy that conforms to EC regulations 6.2. Retention and availability of source documentation that supports claimed project expenditure 6.3. Agreed apportionment or overhead methodologies when not based on actual costs 6.4. Documentation to support adherence to EC rules and regulations such as publicity, state aid and procurement 6.5. Auditors will want to see original documentation such as receipts, activity records etc. If this is not possible a certified copy signed by a senior person in the project organisation is acceptable. If auditable evidence cannot be produced, the appropriate amount of grant will have to be repaid. This ruling applies for the complete time period through to programme closure i.e. 2025. 7. Information Categories to be Retained and Archived Evidence of any material correspondence related to any of the categories must be retained in addition to all the categories listed below. 7.1. Expenditure Procurement Policy and Procedures in adherence with EC guidelines Supplier selection processes including all documentation relating to the tender e.g. o Copies of quotations and all tender documents o Evidence of how decisions have been made and by whom Evidence of any agreed changes and contract variations Matched funding documentation Transaction lists Individual claims Working papers showing how claims are calculated Proof of defrayment e.g. bank statements Audits Income generation 7.2. Original Documentation in support of Expenditure Internal staff costs salary records, detailed time sheets (to show time allocated to the project) and any agreed apportionment methodologies Other costs: invoices, payment receipts, apportionment methodologies, depreciation methodology, copies of leasing/ hire agreements, source documentation for overheads For second hand equipment a declaration by the seller stating the origin of the equipment, and that it has not been purchased with the aid of national or EC grant and proof that it does not exceed market value or cost of similar new equipment.
7.3. Original Documentation in support of Expenditure For all assets over 2,500 which have been either bought, built or improved using ERDF grant, inventory must show: date of acquisition description of each asset price paid net or recoverable VAT amount of ERDF grant paid location of the asset location of the title deeds or ownership records (where relevant) serial or identification numbers date of disposal name and address of any person/ business to whom disposal is made sale of proceeds net of VAT 7.4. Evidence demonstrating completion of Milestones See milestone plan and offer letter for a detailed list of requirements. 7.5. Beneficiary Data Beneficiary data details the outputs which have been achieved and is submitted to DCLG as part of the monthly claim documentation. It is collated using a DCLG template Excel Spread sheet. The beneficiary data must clearly link to the individual output documentation. 7.6. Outputs Evidence of achievement of outcome Signed forms Auditable source data e.g. job advertisements Eligibility of the project beneficiaries 7.7. Governance documentation All documents related to the governance of the project must be retained e.g. agendas, minutes and papers Milestone Plans Risk Register Main Steering Group Heslington East Steering Group FERA Steering Group Biodemonstrators Steering Group Business Engagement Group Independent Project Evaluations General project interactions e.g. contact with partners such as Higher York
7.8. Marketing and Publicity Hard copy evidence of all marketing and publicity undertaken. This may comprise documents, brochures, screen capture and printing of online marketing, photographs of events or signage, digital evidence e.g. video or auditory recordings, transcripts etc 7.9. Outcomes and impacts Narrative evidence of success of the project. This is being developed utilising the recommendations of the Phase 1 Independent Evaluation completed by SQW Consulting. Evidence of achievement of delivery should also be provided e.g. photographs of events, event documentation and press coverage. 7.10. Matched Funding Full transaction listings (in support of claims) Details of match funding Details of any income received Bank statements (also to prove defrayment of expenditure) Audited accounts Any working papers used in calculations Agreed apportionment rationales 7.11. Electronic Only Records Where documents exist in electronic version only, the underlying computer system on which they are held must meet accepted security standards complying with national legal requirements and can be relied upon for audit purposes. COBIT (issued by the IT Governance Institute) or ISO standards on information security provide guidance on suitable standards for electronic systems. 7.12. Non Paper Storage Documents may also be held on commonly accepted data carriers which include; photocopies of original documents; microfiches of original documents; electronic versions of original documents on optical data carriers (such as CD-ROM, hard disk or magnetic disk); documents existing in electronic version only. Each document should be certified as conforming to the original using a declaration as per the example below. This is the minimum requirement but may be added to. I certify that this is a true copy of the original document Signed Date Position in organisation Name of organisation.
This certification procedure places the onus on the project applicant for ensuring the authenticity of the electronic copy. It may still be a requirement that the document can be retrieved and relied upon for audit purposes. Electronic copies of documents are to be retained for the same duration as required for paper copies. 8. Closure of Partner Organisations or Sub-contractors Please note if your organisation closes, goes into receivership or ceases to exist prior to the close of the Programme (estimated 2023) the Agency should be duly informed and all project records should be returned to DCLG in an accessible state, for archiving. Equally if a subcontractor or partner closes etc, you must ensure that all their records pertaining to your project are returned to your organisation for archiving thus ensuring you retain access to a complete audit trail for the project. Failure to evidence a complete audit trail will result in claw-back of funding.