open to criticism from members of the public and the media. Furthermore, under Section 65 of the Freedom of Information (Scotland) Act 2002, any member of staff who alters, erases or conceals records with the intention of preventing them from being disclosed, could be found guilty of a criminal offence which carries a maximum fine of £5000. 7.2 Managers and Supervisors Managers are responsible for information held within their area (both paper and electronic). Managers and supervisors must ensure that their staff have understood their obligations under this Policy and other information management policies. Managers should support their staff in this regard by highlighting relevant parts of policies that apply to the roles being performed by a member of staff. Managers and supervisors must ensure that Records are not disposed of unless this has been approved by the Information Asset Owner, follows the Disposal Authority Process and is in accordance with the retention period as set out in the current Corporate Retention Schedules. 7.3 Information Asset Owners & System Owners An Information Asset Owner (IAO) is a senior manager (head of service or equivalent) who has been identified as being accountable for a Council Information Asset. A System Owner is a person who has been identified as being accountable for a Highland Council ICT System. The IAO is supported by an Information Asset Manager (IAM), who has responsibility for management of the information within that Information Asset. IAO and System Owners must ensure that the management of their Information Asset is consistent with this policy, the Records Management Policy and the other information management policies. IAO and System Owners must ensure they comply with this policy when making a decision on the disposal of Council records. Role descriptions for IAO and IAM have been developed and approved by IMGB. An online learning module has also been provided for Information Asset Owners and Information Asset Managers that provides further explanation on their role and this must be completed by them. 7.4 Information & Records Manager The Information & Records Manager is responsible for ensuring all Highland Council records are held within appropriate records management systems and structures. Page 12 of 14