Data Retention Policy

Contents                 

 

  1. Aims. 2
  2. Agreed Retention Periods…………………………………………………………………………2
  3. Safe Destruction of Data. 2
  4. Data Protection Officers…………………………………………………………………………...2
  5. Management of the School 3
  6. Human Resources. 6
  7. Financial Management of the School 9
  8. Property Management 11
  9. Pupil Management 12

Appendix A – List of School Records and Data safely destroyed. 15

 

A.           Aims

This policy has been produced based on the information management toolkit for schools dated 1st February 2016 and considers the GDPR toolkit for schools – however some of the timeframes differ slightly ensure we simplify the retention periods to avoid confusion and complexity.

This is a checklist developed to enable School Business Managers, Clerks, SENCO and other School Staff to carry out an efficient annual review and safe destruction of school records and information. 

This document should be completed once a year and shared with governors.

 

B.           School Agreed Retention Periods

 

As a school we have agreed the following retention periods:

            Governors related material – 6 Years (or permanent as required)

            Senior Leadership material – 6 Years

            General Administration material – 3 Years

Human Resources – Still staff member leaves + 2 Years (6 Years if HR matters pending)

            Health and Safety – 6 years (when it will be checked for longer retention dates)

            Finance – 6 years

Property Management – 6 years

Children’s information – till the child reaches 18 / or for safeguarding 25

 

 

 

 

C.           Safe Destruction of Data

As a school we have decided that we will ensure that we securely dispose of all data that comes to the end of its retention period.

 

We will do this by having the data destroyed whilst on site and witnessed by a member of the team, who will be record this on this policy.

 

 

D.           School Data Protection Officers

Global Policing support the school with the management of data retention and secure deletion. Should you have any questions or queries, you can contact them directly:

 

            Global Policing Limited

            601 Piccadilly House

            49 Piccadilly

            Manchester

            M1 2AP

 

            Email: datarequestions@globalpolicing.co.uk

            Tel:      0161 212 1682

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1.    Management of the School

1.1   Governing Body – Agreed retention date 6 Years

 

Where possible all Governor minutes will be anonimised and therefore data protection risks will be decreased.

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 1.1.1

Agendas for Governing Body meetings

There may be data protection issues if the meeting is dealing with confidential issues relating to staff

One copy should be retained with the master set of minutes. All other copies can be disposed of

SECURE DISPOSAL

 

  1.1.2

Minutes of Governing Body meetings

There may be data protection issues if the meeting is dealing with confidential issues relating to staff

 

 

 

 

Principal Set (signed)

 

PERMANENT

County Archives Service

 

 

Inspection Copies[1]

 

6 Years

SECURE DISPOSAL

 

 

  1.1.3

Reports presented to the Governing Body

There may be data protection issues if the report deals with confidential issues relating to staff

6 Years

SECURE DISPOSAL

 

 

  1.1.4

Meeting papers relating to the annual parents’ meeting held under section 33 of the Education Act 2002

No

6 Years

SECURE DISPOSAL

 

 1.1.5

Instruments of Government including Articles of Association

No

PERMANENT

County Archives Service.

 

1.1.6

Trusts and Endowments managed by the Governing Body

No

PERMANENT

County Archives Service.

 

1.1.7

Action plans created and administered by the Governing Body

No

6 Years

SECURE DISPOSAL

 

1.1.8

Policy documents created and administered by the Governing Body

No

Life of the policy

SECURE DISPOSAL

 

1.1.9

Records relating to complaints dealt with by the Governing Body

Yes

6 Years

SECURE DISPOSAL

 

 

 1.2 Head Teacher and Senior Management Team - Agreed retention date 6 Years

 

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 

1.2.1

Log books of activity in the school maintained by the Head Teacher

There may be data protection issues if the log book refers to individual pupils or members of staff

6 Years

These could be of permanent historical value and should be offered to the County Archives Service if appropriate

 

1.2.2

Minutes of Senior Management Team meetings and the meetings of other internal administrative bodies

There may be data protection issues if the minutes refers to individual pupils or members of staff

6 Years

SECURE DISPOSAL

 

1.2.3

Reports created by the Head Teacher or the Management Team

There may be data protection issues if the report refers to individual pupils or members of staff

6 Years

SECURE DISPOSAL

 

1.2.4

Records created by head teachers, deputy head teachers, heads of year and other members of staff with administrative responsibilities

There may be data protection issues if the records refer to individual pupils or members of staff

6 Years

SECURE DISPOSAL

 

1.2.5

Correspondence created by head teachers, deputy head teachers, heads of year and other members of staff with administrative responsibilities

There may be data protection issues if the correspondence refers to individual pupils or members of staff

6 Years

SECURE DISPOSAL

 

1.2.6

Professional Development Plans

Yes

6 Years

SECURE DISPOSAL

 

1.2.7

School Development Plans

No

6 Years

SECURE DISPOSAL

 

 

 

 

 

1.3 Operational Administration - Agreed retention date 3 Years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

1.3.1

General file series

No

3 Years

SECURE DISPOSAL

 

1.3.2

Records relating to the creation and publication of the school brochure or prospectus

No

3 Years

SECURE DISPOSAL

 

1.3.3

Records relating to the creation and distribution of circulars to staff, parents or pupils

No

3 Years

SECURE DISPOSAL

 

1.3.4

Newsletters and other items with a short operational use

No

3 Years

SECURE DISPOSAL

 

1.3.5

Visitors’ Books and Signing in Sheets

Yes

3 Years

SECURE DISPOSAL

 

 

7.2 Walking Bus - Agreed retention date 3 Years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

  1.4.1

Walking Bus Registers

Yes

Date of register + 3 years

This takes into account the fact that if there is an incident requiring an accident report the register will be submitted with the accident report and kept for the period of time required for accident reporting

SECURE DISPOSAL

[If these records are retained electronically any back up copies should be destroyed at the same time]

 

 

 

2.    Human Resources

2.1 Recruitment - Agreed retention date Employment + 2 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 2.1.1

All records leading up to the appointment of a new headteacher

Yes

Whilst Staff member is employed + 2 years

SECURE DISPOSAL

 

2.1.2

All records leading up to the appointment of a new member of staff – unsuccessful candidates

Yes

Whilst Staff member is employed + 2 years

SECURE DISPOSAL

 

2.13

All records leading up to the appointment of a new member of staff – successful candidate

Yes

Whilst Staff member is employed + 2 years

SECURE DISPOSAL

 

2.1.4

Pre-employment vetting information – DBS Checks

No

Whilst Staff member is employed + 2 years

 

 

2.1.5

Proofs of identity collected as part of the process of checking

“portable” enhanced DBS disclosure

Yes

Whilst Staff member is employed + 2 years

 

 

2.1.6

Pre-employment vetting information – Evidence proving the right to work in the United Kingdom4

Yes

Whilst Staff member is employed + 2 years

 

 

 

 

2.2 Operational Staff Management - Agreed retention date Employment + 2 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 2.2.1

Staff Personal File

Yes

Whilst Staff member is employed + 2 years

SECURE DISPOSAL

 

2.2.2

Timesheets

Yes

Whilst Staff member is employed + 2 years

SECURE DISPOSAL

 

2.2.3

Annual appraisal/ assessment records

Yes

Whilst Staff member is employed + 2 years

SECURE DISPOSAL

 

 

2.3 Management of Disciplinary and Grievance Processes - Agreed retention date Employment + 6 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 2.3.1

Allegation of a child protection nature against a member of staff including where the allegation is unfounded5

Yes

Whilst Staff member is employed + 6 years

SECURE DISPOSAL

 

 

2.3.2

Disciplinary Proceedings

Yes

Whilst Staff member is employed + 6 years

 

 

 

oral warning

 

Whilst Staff member is employed + 6 years

SECURE DISPOSAL

 

 

 

written warning – level 1

 

Whilst Staff member is employed + 6 years

 

 

 

written warning – level 2

 

Whilst Staff member is employed + 6 years

 

 

 

final warning

 

Whilst Staff member is employed + 6 years

 

 

 

case not found

 

Whilst Staff member is employed + 6 years

SECURE DISPOSAL

 

 

2.4 Payroll and Pensions - Agreed retention date 6 years (Finance)

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

  2.4.1

Maternity pay records

Yes

Current year + 3 years

SECURE DISPOSAL

 

2.4.2

Records held under Retirement Benefits Schemes (Information Powers) Regulations 1995

Yes

Current year + 6 years

SECURE DISPOSAL

 

 

 

2.5 Health and Safety - Agreed retention date 6 years (check for longer periods)

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

2.5.1

Health and Safety Policy Statements

No

6 Years

SECURE DISPOSAL

 

2.5.2

Health and Safety Risk Assessments

No

6 Years

SECURE DISPOSAL

 

2.5.3

Records relating to accident/ injury at work

Yes

12 Years

SECURE DISPOSAL

 

2.5.4

Accident Reporting

Yes

 

 

 

 

Adults

 

6 Years

SECURE DISPOSAL

 

 

Children

 

Age of child 25

SECURE DISPOSAL

 

2.5.5

Control of Substances Hazardous to Health (COSHH)

No

Current year + 40 years

SECURE DISPOSAL

 

2.5.6

Process of monitoring of areas where employees and persons are likely to have become in contact with asbestos

No

Last action + 40 years

SECURE DISPOSAL

 

2.5.7

Process of monitoring of areas where employees and persons are likely to have become in contact with radiation

No

Last action + 50 years

SECURE DISPOSAL

 

2.5.8

Fire Precautions log books

No

6 Years

SECURE DISPOSAL

 

 

 

 

 

3.    Financial Management of the School

3.1 Asset Management - Agreed retention date 6 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 3.1.1

Inventories of furniture and equipment

No

Current year + 6 years

SECURE DISPOSAL

 

3.1 .2

Burglary, theft and vandalism report forms

No

Current year + 6 years

SECURE DISPOSAL

 

 

3.2 Accounts and Statements including Budget Management - Agreed retention date 6 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

3.2.1

Annual Accounts

No

Current year + 6 years

STANDARD DISPOSAL

 

3.2.2

Loans and grants managed by the school

No

Date of last payment on the loan + 12 years then REVIEW

SECURE DISPOSAL

 

3.2.3

Student Grant applications

Yes

Current year + 3 years

SECURE DISPOSAL

 

3.2.4

All records relating to the creation and management of budgets including the Annual Budget statement and background papers

No

Life of the budget + 3 years

SECURE DISPOSAL

 

3.2.5

Invoices, receipts, order books and requisitions, delivery notices

No

Current financial year + 6 years

SECURE DISPOSAL

 

3.2.6

Records relating to the collection and banking of monies

No

Current financial year + 6 years

SECURE DISPOSAL

 

3.2.7

Records relating to the identification and collection of debt

No

Current financial year + 6 years

SECURE DISPOSAL

 

 

3.3 Contract Management - Agreed retention date 6 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

3.3.1

All records relating to the management of contracts under seal

No

Last payment on the contract + 12 years

SECURE DISPOSAL

 

3.3.2

All records relating to the management of contracts under signature

No

Last payment on the contract + 6 years

SECURE DISPOSAL

 

3.3.3

Records relating to the monitoring of contracts

No

Current year + 2 years

SECURE DISPOSAL

 

 

3.4 School Meals - Agreed retention date 6 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

3.4.1

Free School Meals Registers

Yes

Current year + 6 years

SECURE DISPOSAL

 

3.4.2

School Meals Registers

Yes

Current year + 3 years

SECURE DISPOSAL

 

3.4.3

School Meals Summary Sheets

No

Current year + 3 years

SECURE DISPOSAL

 

 

 

 

4.    Property Management

4.1 Property Management - Agreed retention date 6 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 4.1.1

Title deeds of properties belonging to the school

No

PERMANENT

These should follow the property unless the property has been registered with the Land Registry

 

 

4.1.2

Plans of property belong to the school

No

These should be retained whilst the building belongs to the school and should be passed onto any new owners if the building is leased or sold.

 

 

4.1.3

Leases of property leased by or to the school

No

 6 years

SECURE DISPOSAL

 

4.1.4

Records relating to the letting of school premises

No

6 years

SECURE DISPOSAL

 

 

4.2 Maintenance - Agreed retention date 6 years

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 4.2.1

All records relating to the maintenance of the school carried out by contractors

No

6 years

SECURE DISPOSAL

 

4.2.2

All records relating to the maintenance of the school carried out by school employees including maintenance log books

No

6 years

SECURE DISPOSAL

 

 

 

 

5.    Pupil Management

At this school we have decided to retain pupil information until the end of the set age of education, so until the child reaches the age of 18.

 

5.1 Pupil’s Educational Record - Agreed retention date when the child reaches 18 / Safeguarding 25

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 5.1.1

Pupil’s Educational Record required by The Education (Pupil Information) (England) Regulations 2005

Yes

 

 

 

 

Primary

 

Until the child reaches 18

There is an option for the file to follow the child to high school.

 

5.1.2

Examination Results – Pupil Copies

Yes

 

 

 

 

Public

 

Until the child reaches 18

All uncollected certificates should be returned to the examination board.

 

 

Internal

 

Until the child reaches 18

 

 

5.1.3

Child Protection information held on pupil file

 

Until the child reaches 25

SECURE DISPOSAL

 

5.1.4

Child protection information held in separate files

 

Until the child reaches 25

SECURE DISPOSAL

 

5.2 Attendance - Agreed retention date when the child reaches 18

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

5.2.1

Attendance Registers

Yes

Every entry in the attendance register must be preserved for a period of three years after the date on which the entry was made.

SECURE DISPOSAL

 

5.2.2

Correspondence relating to authorized absence

 

Current academic year + 2 years

SECURE DISPOSAL

 

 

 

 

5.3 Special Educational Needs - Agreed retention date when the child reaches 25

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

5.3.1

Special Educational Needs files, reviews and Individual Education Plans

Yes

Until the child reaches 25

Secure DISPOSAL

 

5.3.2

Statement maintained under section 234 of the Education Act 1990 and any amendments made to the statement

Yes

Until the child reaches 25

SECURE DISPOSAL

 

 

 

 

Until the child reaches 25

SECURE DISPOSAL

 

 

 

 

Until the child reaches 25

SECURE DISPOSAL

 

 

5.4 Educational Visits outside the Classroom - Agreed retention date when the child reaches 25

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 

5.4.1

Records created by schools to obtain approval to run an Educational Visit outside the Classroom – Primary Schools

No

Until the child reaches 25

SECURE DISPOSAL

 

5.4.2

Records created by schools to obtain approval to run an Educational Visit outside the

Classroom – Secondary Schools

No

Until the child reaches 25

SECURE DISPOSAL

 

5.4.3

Parental consent forms for school trips where there has been no major incident

Yes

Until the child reaches 25

SECURE DISPOSAL

 

5.4.4

Parental permission slips for school trips – where there has been a major incident

Yes

Until the child reaches 25

 

 

 

 

5.5 Those working in safeguarding roles - Agreed retention date when the child reaches 25

  Ref

Basic file description

Data Protection Issues

Retention Period [Operational]

Action at the end of the administrative life of the record

Annual Review Completed

Tick (√)

 5.5.1

Day Books

Yes

Current year + 2 years then review

 

 

5.5.2

Reports for outside agencies - where the report has been included on the case file created by the outside agency

Yes

Whilst child is attending school and then destroy

 

 

5.5.3

Referral forms

Yes

While the referral is current

 

 

5.5.4

Contact data sheets

Yes

Current year then review, if contact is no longer active then destroy

 

 

5.5.5

Contact database entries

Yes

Current year then review, if contact is no longer active then destroy

 

 

5.5.6

Group Registers

Yes

Current year + 2 years

 

 

 

 

 

 

 

 

Appendix A – List of School Records and Data safely destroyed

School name:

 

Review completed by:

 

Date:

 

Approved by Headteacher:

 

Date:

 

 

The following sheet can be completed or alternatively documented in a spreadsheet.

Ref Number

File/Record Title

Description

Reference or Cataloguing Information

Number of Files Destroyed

Method of destruction

Confirm

(i) Safely destroyed

(ii) In accordance with Data Retention Guidelines

Tick (√)

e.g.

School Invoices

Copies of purchase invoices dated 2011/12

Folders marked Purchase Invoices 2011/12 1 to 3

3 Folders

Shredding

1

 

 

 

 

 

 

2

 

 

 

 

 

 

3

 

 

 

 

 

 

4

 

 

 

 

 

 

5

 

 

 

 

 

 

6

 

 

 

 

 

 

7

 

 

 

 

 

 

8

 

 

 

 

 

 

9

 

 

 

 

 

 

10

 

 

 

 

 

 

11

 

 

 

 

 

 

12

 

 

 

 

 

 

13

 

 

 

 

 

 

14

 

 

 

 

 

 

 

 

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