As indicated in OP this is of wider application but it was in fact prompted by RCN guidance not to keep an electronic copy as this might impose a requirement to register as a DC.
Nurses are required to have periodic validation of fitness to practice which requires a portfolio of evidence. Whilst employers may facilitate this it is clearly not an employment record but a personal one.
I see it as being not dissimilar to a CV. Millions of people keep these electronically and they will usually have someone else's PD embedded - e.g. referees. If RCN warning is valid next question would be whether anyone keeping a CV electronically also needs to register as a DC....
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