Matt Hodges-Long 25/05/2021
Last week, the Building Regulations Advisory Committee (BRAC) Golden Thread Working Group published a document approved for release by the MHCLG Golden Thread policy unit. This gives us a clearer insight into the Government’s intent about digital management of Building Safety information.
This post summarises the 9 Golden Thread principles published in that document and gives our insight into each one. Please note, this could be subject to change as MHCLG move towards a formal policy position and guidance.
We also note the overlapping building safety data management and sharing requirements of the Fire Safety Act are not mentioned here. Please look at our recent blog on the Fire Safety Act 2021
Draft golden thread principles
1. Accurate and trusted
The dutyholder/Accountable Person/Building Safety Managers (BSM) and other relevant persons (e.g. contractors) must be able to use the golden thread to maintain and manage building safety. The Regulator should also be able to use this information as part of their work to assess the safety of the building and the operator’s safety case report, including supportive evidence, and to hold people to account. The golden thread will be a source of evidence to show how building safety risks are understood and how they are being managed on an ongoing basis. The golden thread must be accurate and trusted – it will not be used unless people trust that the information in the golden thread is accurate and up to date. The information produced will therefore have to be accurate, structured and verified, requiring a clear change control process that sets out how and when information is updated and who should update and check the information.
We have always advocated the need for a single record that uses granular access permissions to serve the correct view of the information. This includes any metadata and behavioral information. The TrackMyRisks platform complies with this principle.
2. Residents feeling secure in their homes
Residents will be provided information from the golden thread – so that they have accurate and trusted information about their home. This will also support residents in holding Accountable Persons and Building Safety Managers to account for building safety. A properly maintained golden thread should support accountable persons in providing residents the assurance that their building is being managed safely.
Residents should definitely feel and be secure in their homes. Providing a real-time window into aspects of the Golden Thread will reassure residents that safety is not being overlooked. The TrackMyRisks platform complies with this principle.
3. Culture change
The golden thread will support culture change within the industry as it will require increased competence and capability, different working practices, updated processes and a focus on information management and control. The golden thread should be considered an enabler for better and more collaborative working.
The main cultural change will come from the introduction of transparency with Building Safety management. Transparency in terms of actions, responsibility, timeliness and competence. The TrackMyRisks platform complies with this principle.
4. Single point of truth
The golden thread will bring all information together in a single place (potentially a Common Data Environment) meaning there is always a ‘single point of truth’. It will record changes (i.e. updates to information/plans), including the reason for change, evaluation of change, date of change, and the decision-making process. This will reduce the duplication of information (email updates and multiple documents) and help drive improved accountability, responsibility and a new working culture.
In a rapidly moving environment with a diverse supply chain, a ‘single source of truth’ is vitally important. If duty holders adopt a culture of an item only becoming a reality when it is published as an immutable log, they will drive a high level of consistency and compliance. The TrackMyRisks platform complies with this principle.
The golden thread must be secure, with sufficient protocols in place to protect personal information and control access to maintain the security of the building or residents. It should also comply with current GDPR legislation where required.
Granular security permissions are essential, especially if a wide range of stakeholders are permissioned into aspects of the Golden Thread. Permissions are required at both the account and object levels. In addition, we would specify encryption, virus scanning and full immutable activity logging. The TrackMyRisks platform complies with this principle.
The golden thread will record changes (i.e. updates to information), when these changes were made and by who. This will help drive improved accountability. The new regime is setting out clear duties for the duty holders and the Accountable Person for maintaining the golden thread information to meet the required standards. Therefore, there is accountability at every level – from the Client/Accountable Person to those designing, building or maintaining a building. This will mean that changes can more easily be tracked, and this will support better building safety.
Evidential activity tracking and version control recorded within an immutable log will drive accountability as well as aiding regulatory investigation. This concept can be further enhanced by linking permissions to competence registers. The TrackMyRisks platform complies with this principle.
7. Understandable / simple to access (accessible) / consistent
The golden thread needs to support the user in their task of managing building safety. The information in the golden thread must be clear, understandable and focused on the needs of the user. It should be presented in a way that can be understood and used by users. This also should consider that users have different needs. The information should be accessible so that people can easily find the right information at the right time. This means that the information needs to be stored in a structured way (i.e. like a library) so people can easily find, update and extract the right information. The Government will set out the digital standards which will apply to the golden thread. Storing information to digital standards would mean the information is stored in a structured way. To support this dutyholders/Accountable person should where possible make sure the golden thread uses standard methods, processes and consistent terminology so that those working with multiple buildings can more easily access, understand and use the information consistently and effectively.
Policymakers need to ensure that the market is afforded sufficient flexibility to adapt and evolve the Golden Thread approach over time. All of the answers are not known now and these will become more obvious as more Golden Threads are compiled. The needs of all stakeholders should be considered and simplicity should be paramount. The TrackMyRisks platform complies with this principle.
8. Longevity / durability of information
The golden thread information needs to be formatted in a way that can be easily handed over and maintained over the entire lifetime of a building. In practical terms this is likely to mean that it needs to align with the rules around open source data – so that information can be handed over in the future and still be accessed. Information should be able to be shared and accessed by contractors who use different software and if the building is sold the golden thread information must be accessible to the new owner. This does not mean everything about a building and its history needs to be kept, the golden thread must be reviewed to ensure that the information within it is still relevant and useful.
Data longevity is essential and in an ideal world would not be exported from one system and imported into another. We would advocate a transfer of access permissions between Accountable Persons to maintain a log of user activity in addition to building data. The TrackMyRisks platform complies with this principle.
9. Relevant / proportionate
Preserving the golden thread does not mean everything about a building and its history needs to be kept and updated from inception to disposal. The objective of the golden thread is building safety and therefore if information is no longer relevant to building safety it does not need to be kept. The golden thread, the changes to it and processes related to it must be reviewed periodically to ensure that the information comprising it remains relevant and useful.
Regulators need to be very careful about the permanent deletion of data, as historical decisions may need to be investigated at a future date. As a minimum, the decision to delete should be captured in the immutable activity log. We prefer the concept of archiving data that can be retrieved at a later date if required. The TrackMyRisks platform complies with this principle.
TrackMyRisks and Golden Thread
The TrackMyRisks approach to Golden Thread provides a simple, flexible, low-cost, and scalable cloud-based solution. This not only meets the requirements of the new Building Safety Regulator but fully supports the information-sharing requirements of the Fire Safety Act.
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