Evening all,
Given the number of regional procurements occurring I have received an unusually large number of questions about image retention recently so just wished to draw attention to the College’s new (March 2025) guidance document on the subject of image retention plus provide my opinion for colleagues who would like one more widely.
Application of the records management code of practice to radiology record retention protocols
RCR Publications Record Management Code.pdf (147.7 KB)
This document was authored by the specialist RCR RIC SIG with input from PACS Managers, Radiographers and other personnel and was released following a consultation period earlier this year.
The summary of the guidance is: all radiological images and reports are best retained for 30 years from when the patient was last seen (in any form, including non-Radiographically in clinics) or 10 years after the death of the patient, except when an ongoing statutory bar on destruction exists.
Longer reasoning: under the standing NHS Records Management Code of Practice all adult radiological images are required to be retained for a minimum of 8 years from when the patient was last seen. Paediatric images are retained until the patient is aged 25 (or the 26th birthday if a patient was last seen at age 17).
However - there are exceptions required by various existing laws, statutes and practices. Gathered together:
- Cancer diagnosis: 30 years from diagnosis, or 8 years after the death of the patient, whichever is later.
- Creutzfeldt-Jakob disease (CJD) diagnosis: 30 years from when the patient was last seen or 10 years after the death of the patient, whichever is later.
- Transplantation: 30 years from the date of transplant.
- Continuity of care purposes (chronic diseases or illness that may reoccur): 20 years from when the patient was last seen or 10 years after the death of the patient, whichever is later.
- Screening (including mammography): 10 years from the study acquisition date.
- Obstetric ultrasound (mother’s record): 25 years from when the patient was last seen.
- Public inquiry: (eg, COVID, historic abuse, infected blood) - indefinite (requires legal release).
- Subject access request record (SAR): indefinite (requires legal release).
- Freedom of Information Act (FOIA) record request: indefinite (requires legal release) (less likely to be regularly found in our work, but still mentionable)
- Legal proceedings: indefinite (requires legal release).
- Coroner’s inquest: indefinite (requires legal release).
- Selected for permanent preservation under the Public Records Act: indefinite (requires legal release). Likely to only apply to Trusts servicing members of the monarchy.
Opinion - in practice this will likely mean ongoing retention of images unless ‘film library’ clerks are reemployed or existing implementations of Image Lifecycle Management in PACS become far more sophisticated to recognise the various exceptions (at present, none of the major vendors in the UK offer an ILM solution which would be able to apply these rules without significant manual intervention or verification, plus no major RIS vendor offers a working retention duration flagging system).
As the storage of individual studies is practically cost negligible it is unlikely costly human effort will be engaged to manually sift or manually delete. Undertaking such a task for the first time during a (for example) cloud migration in an attempt to reduce storage space would not be ideal.
However, to manage the ever growing volume of imaging, offsite or archival storage should be considered for long-term storage along with the creation of a process for periodically verifying the archived data and culling duplicated data. Historic metadata migration when RIS/PACS vendors are changed should also be noted as something ‘bigger than we think’ during reprocurement or renewal projects.
Adding an additional question into tender specifications similar to “how many records can your x database reliably index given the long-term storage of images / patient history at this facility, plus merger of x y z Trusts into one system” (i.e. what is the table size limit!) may also be helpful to avoid surprises mid-contract. In addition enquiring over different tiers of cloud storage (near, far, offline etc.) and how a PACS utilises them to manage ongoing storage costs may be useful during a cloud procurement.
Hope this helps, the question over image retention periods crops up every few years and always generates debate as there is no simple answer!
Have a good evening all,
Al.