The RCR has issued the following statement following publication of a new Records Management Code of Practice by NHS Digital in 2021. Although the NHS Digital guidance appertains only to England, the principles of the information which should be retained apply throughout the UK four nations.
This statement will be reviewed in 2025.
Statement on the retention of oncology records
In 2017 The Royal College of Radiologists (RCR) published a statement on the retention of oncology records. This was released following publication by the Department of Health (DoH) in the previous year of a Records Management Code of Practice for Health and Social Care 2016 and sought to address issues specific to non-surgical treatment records.
The DoH guidance has been superseded by a Records Management Code of Practice 2021, issued by NHS Digital on 4 August 2021. This contains specific advice on the retention period for the oncology records of any patient. It advises that such records be retained for a minimum period of thirty years from diagnosis of cancer, or until eight years after death. Following this, oncology records should be reviewed and considered for transfer to a Place of Deposit. Where the oncology record is part of the main records, then the entire record must be retained.
The RCR commends the NHS Digital guidance and continues to advocate the view that premature destruction of relevant patient records may result in preventable death, inappropriate subsequent treatment or inadequate response to an inquiry during or after a patient’s lifetime. Many patients are now cured of their cancer but may develop further conditions where the information contained in their records remains relevant. This is especially true for radiotherapy treatments, for example, when a second malignancy develops in a geographically adjacent area of the body. Details of all previous systemic therapy and radiotherapy treatments delivered to patients are vital both for reliable diagnosis and to inform safe planning of subsequent therapies. The RCR also recommends that any review of oncology records must take into account any potential long-term research value which may require consent or anonymisation.
As a minimum, the RCR recommends the following records are retained until eight years after death:
- Planning CT information in DICOM image format
- Patient-specific photos and diagrams
- Patient-specific measurements
- Radiation dose and fractionation: both that prescribed and delivered
- Plan construction information - for example, field size, monitor units, etc.
- Three dimensional dose distribution information; dose / volume histogram information and dose to organs at risk
- Independent dose / monitor unit verification
- Imaging obtained during treatment verification
- Systemic anticancer therapy delivered - including drug name, dose prescribed and delivered, toxicities experienced and supporting medications delivered.
Technology continues to evolve rapidly. The RCR recognises the challenges of retaining electronic records of treatments in a manner which is sustainable and remains accessible over time periods which could span many decades. Increasing globalisation and migration may mean that patients may receive subsequent diagnosis and treatment through a different health service provider. Where it is possible, the RCR recommends that a copy of the above information should be provided to the patient, for them to retain and provide directly to future clinicians when required. This should occur in addition to and not instead of retention of records by the treatment provider in accordance with the above-mentioned NHS Digital guidance. This should reduce the likelihood that critical information is lost or becomes unrecoverable due to technological obsolescence.