What is the Golden Thread?
The Building Safety Act (BSA) requirement for a golden thread of information seeks to remedy a historic lack of complete and up to date information about high rise residential buildings which can make it difficult to manage safety. This is done by creating a core record keeping process which begins before any building works start, and is maintained throughout the design and construction phase of a Higher Risk Building (as defined by the regulations to the BSA) (HRB), as well as once occupied and any subsequent works to an HRB.
Regulation 31 of The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 (the Regulations) provides that the following information is required to be stored as part of the golden thread:
- Information and documents to be submitted to the Building Safety Regulator as part of the building control approval at the gateway 2 stage (Regulation 31(4));
- Any controlled changes and associated documents (Regulation 31(7) and (8));
- Any mandatory occurrence reports (Regulation 31(10)); and
- Information and documents to be submitted to the Building Safety Regulator when applying for a completion certificate, as well as the completion certificate if issued (Regulation 31(11)).
This information has to be stored electronically and maintained in line with certain principles as discussed below.
Principles of the Golden Thread
The Building Regulations Advisory Committee produced a set of golden principles to inform further how the golden thread should be managed, stored and shared, some of which appear at Regulation 31 of the Regulations, with key principles set out below:
- Shareability (Regulation 31(2)(b)) – A variety of different systems can be used to produce and store building safety information and as the golden thread of information will typically be handed over many times throughout the lifecycle of a building, interoperability is key. This requires parties who use different software, being able to access the information without issue;
- Accurate and trusted (Regulation 31(2)(c)) – The information stored will be relied on by various parties as evidence of how building safety risks are understood and managed. This does not require that ALL information must be updated as some information will only need to be accurate at the point it was created e.g. documents submitted for building control approval as part of Gateway 2. Other information will need to be updated and reviewed regularly so it can fulfil its purpose;
- Readable format (Regulation 31(2)(d)) – In order to fulfil its purpose, the information needs to be in a readable format which is intelligible to the intended user. This may require technical documents to be simplified so that an intelligent non-expert may understand the contents bearing in mind who the end user may be eventually. If a key is required to understand the data, this must also be provided;
- Single source of truth – The golden thread will aim to bring all the relevant information together in a single place, however in response to the statutory consultation, the Department for Levelling Up, Housing and Communities clarified that this does not mean that the golden thread needs to be stored on a single system. It stated that “The government is committed to ensuring the golden thread of information is kept up to date, can be effectively used to deliver safe outcomes and can be transferred. It is for industry to ensure the approaches taken, including where accountable persons use more than one system, deliver this, so that residents are, and feel, safe in their homes.“;
- Secure(Regulation 31(2)(f)) – Access to the golden thread must be secure, with sufficient protocols in place to protect personal information and comply with GDPR legislation when required;
- Accountable – A key principle which will require a record of who is inputting information into the golden thread and any changes (updates, additions etc.) that are made as well as when these are made; and
- Understandable/ consistency (Regulation 31(2)(h)) – The information will be looked at by various parties, meaning it has to be clear and structured in a way which allows the relevant party to manage building safety. This could mean consistent terminology and standard processes/ methods is used throughout.
Who does this affect?
During the construction phase, the main dutyholders will be the following:
- Client/Employer – Regulation 31(1) places a responsibility on the client to arrange for an electronic facility to hold the golden thread information and so the client is ultimately responsible for the creation and management of the golden thread. The client is also responsible for ensuring that there is a record of any controlled changes as well as who makes this change and when. In addition, the client must accept the golden thread upon completion from the principal contractor and hand it over to the relevant person or a new incoming client.
- Principal Designer – The Principal Designer will develop and finalise the golden thread throughout the design phase. This will include liaising with the principal contractor to ensure that design work throughout the construction phase is included within the golden thread, as well as final handover to the principal contractor upon completion of the design phase; and
- Principal Contractor – The Principal Contractor will maintain the golden thread throughout the construction phase and eventual handover to the client upon practical completion.
Completion
Regulation 40(1)(f) requires that any application for a completion certificate be accompanied by (among other things) a statement, signed by both the client and the relevant person (being the accountable person for the part of the building to which the work relates and the responsible person (as defined in article 3 of the Regulatory Reform (Fire Safety) Order 2005) (if any) for the building)). This statement must confirm that the information required under regulation 38(1)(being the BFLO information (as defined at regulation 38 (5) and the “specified golden thread information”) has been given to the relevant person, and that the relevant person has received this information. “Specified golden thread information” is defined as
- The completion certificate application in relation to the HRB work, the stage of the HRB work or, as the case may be, work to existing HRB which the client proposes to make; and
- Each document which under regulation 40 (completion certificate applications) is required to accompany the application.
If this statement is not included with the application for completion certificate, the Building Safety Regulator is likely to refuse the application.
Conclusion
The golden thread seeks to enable various dutyholders and accountable persons to work together and maintain a database of information which can be used to effectively manage risks throughout a building’s lifecycle. Parties should consider which digital tools and platforms to use (if they are not already) which can aid in the recording and storage of the golden thread information. The use of existing approaches such as the UK Building Information Modelling (BIM) Framework can be of use in this regard as an established method of managing and sharing information about a building throughout its lifecycle, but use of BIM is not mandatory as long as whatever system is used complies with the regulations.