‘Golden Thread’ Information for Higher Risk Buildings – What are Accountable Persons’ Responsibilities?

Following Dame Judith Hackitt’s Report on building safety, the Government committed to implementing the ‘Golden Thread’ in the construction industry. This term refers to a new method of gathering, storing and maintaining key information about a Higher Risk Building (“HRB”) during its lifecycle.

Under the Building Safety Act 2022 (“BSA”) there are now legal duties imposed on ‘duty holders’ to create, obtain, store and share information about their building in a prescribed manner. Duty holders include those who have responsibilities under the Construction (Design and Management) Regulations 2015 and Accountable Persons (“APs”), who are duty holders during the occupation phase of a building’s life cycle.

What is ‘Golden Thread Information’?

Golden Thread Information is information which allows people to understand the building safety aspects of a HRB and the steps needed to keep the HRB and the people who use it safe. More specifically, it is information which:

• shows that the building was compliant with building regulations during construction;
• evidences that the HRB meets the requirements of the new building control regime; and
• enables those responsible for the HRB to identify, understand, manage and mitigate building safety risks.

What counts as Golden Thread Information will vary from building to building and will depend on numerous factors as adjudged by the Building Safety Regulator. However, it will generally include documents such as fire risk assessments, designs, as-built drawings and evacuation strategies.

Collating Golden Thread Information is not a one-off process. The relevant information will change over a HRB’s lifespan and therefore needs to be continuously updated.

What are APs’ duties?

APs are responsible for keeping, maintaining and updating Golden Thread Information during the occupation phase of the HRB. Under the BSA, a HRB is ‘occupied’ if there are residents of more than one residential unit present in the HRB. Where an AP does not have the required information, it must obtain it where it is practicable to do so. Additionally, APs may be required to provide copies of Golden Thread Information to the Building Safety Regulator, other APs, residents, owners and other prescribed persons.

Golden Thread Information must be stored and presented in an appropriate way. The Building Safety Regulator’s guidance says that information must be:

• kept digitally;
• kept securely;
• a HRB’s “single source of truth”;
• available to people who need the information to do a job;
• available when a person needs the information; and
• presented in a way a prescribed person can use.

APs should therefore ensure they have an appropriate electronic filing system to maintain the required information.

The Golden Thread principles set out in a report from the Building Regulations Advisory Committee stress that storing the required information does not mean all information about a HRB and its history needs to be kept and updated. Given the objective of the Golden Thread is to improve building safety, information which is no longer relevant to the safety of the HRB does not need to be retained. Rather, Golden Thread Information must be proportionate and, as noted above, kept under review to ensure that it is sufficiently streamlined so as to be useful for the relevant stage of a HRB’s life cycle.

If you have any questions regarding Golden Thread Information, the duties of APs or any other building safety matters, please contact our Construction Team.

If you aren’t receiving our legal updates directly to your mailbox, please sign up now