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roselyn house school / THE rhise SERVICE
DATA RETENTION POLICY
Roselyn House School / The RHISE Service has a responsibility to maintain its records and record keeping systems. When doing this, Roselyn House School / The RHISE Service will take account of the following factors: -
- The most efficient and effective way of storing records and information;
- The confidential nature of the records and information stored;
- The security of the record systems used;
- Privacy and disclosure; and
- Accessibility of records and record keeping systems.
This policy does not form part of any employee's contract of employment and is not intended to have contractual effect. It does, however, reflect Roselyn House School / The RHISE Service’s current practice, the requirements of current legislation and best practice and guidance. It may be amended by us from time to time and any changes will be notified to employees within one month of the date on which the change is intended to take effect. Roselyn House School / The RHISE Service may also vary any parts of this procedure, including any time limits, as appropriate in any case.
DATA PROTECTION
This policy sets out how long employment-related and pupil data will normally be held by us and when that information will be confidentially destroyed in compliance with the terms of the UK General Data Protection Regulation (UK GDPR) and the Freedom of Information Act 2000.
Data will be stored and processed to allow for the efficient operation of Roselyn House School / The RHISE Service. The School’s Data Protection Policy outlines its duties and obligations under the UK GDPR.
RETENTION SCHEDULE
Information (hard copy and electronic) will be retained for at least the period specified in the attached retention schedule. When managing records, Roselyn House School / The RHISE Service will adhere to the standard retention times listed within that schedule.
The retention schedule refers to all records regardless of the media (e.g. paper, electronic, microfilm, photographic etc.) in/on which they are stored. All records will be regularly monitored by Rachel Smith.
DESTRUCTION OF RECORDS
The schedule is a relatively lengthy document listing the many types of records used by the school and the applicable retention periods for each record type. The retention periods are based on business needs and legal requirements.
Where records have been identified for destruction they should be disposed of in an appropriate way. All information must be reviewed before destruction to determine whether there are special factors that mean destruction should be delayed, such as potential litigation, complaints or grievances.
All paper records containing personal information, or sensitive policy information should be shredded before disposal where possible. All other paper records should be disposed of by an appropriate waste paper merchant. All electronic information will be deleted.
Roselyn House School / The RHISE Service maintains a database of records which have been destroyed and who authorised their destruction. When destroying documents, the appropriate staff member should record in this list at least: -
- File reference (or other unique identifier);
- File title/description;
- Number of files;
- Name of the authorising officer;
- Date destroyed or deleted from system; and
- Person(s) who undertook destruction.
RECORD KEEPING OF SAFEGUARDING
Any allegations made that are found to be malicious must not be part of the personnel records.
For any other allegations made, Roselyn House School / The RHISE Service must keep a comprehensive summary of the allegation made, details of how the investigation was looked into and resolved and any decisions reached. This should be kept on the personnel files of the accused.
Any allegations made of sexual abuse should be preserved by Roselyn House School / The RHISE Service for the term of an inquiry by the Independent Inquiry into Child Sexual Abuse. All other records (for example, the personnel file of the accused) should be retained until the accused has reached normal pension age or for a period of 10 years from the date of the allegation if that is longer. Guidance from the Independent Inquiry Child Sexual Abuse states that prolonged retention of personal data at the request of an Inquiry would not contravene data protection regulation provided the information is restricted to that necessary to fulfil potential legal duties that a School may have in relation to an Inquiry.
Whilst the Independent Inquiry into Child Sexual Abuse is ongoing, it is an offence to destroy any records relating to it. At the conclusion of the Inquiry, it is likely that an indication regarding the appropriate retention periods of the records will be made.
ARCHIVING
Where records have been identified as being worthy of preservation over the longer term, arrangements should be made to transfer the records to the archives. A database of the records sent to the archives is maintained by Rachel Smith. The appropriate staff member, when archiving documents should record in this list the following information: -
- File reference (or other unique identifier);
- File title/description;
- Number of files; and
- Name of the authorising officer.
TRANSFERRING INFORMATION TO OTHER MEDIA
Where lengthy retention periods have been allocated to records, members of staff may wish to consider converting paper records to other media such as digital media or virtual storage centres (such as cloud storage). The lifespan of the media and the ability to migrate data where necessary should always be considered.
RESPONSIBILITY AND MONITORING
Rachel Smith has primary and day-to-day responsibility for implementing this Policy. The Data Protection Officer, in conjunction with Roselyn House School / The RHISE Service, is responsible for monitoring its use and effectiveness and dealing with any queries on its interpretation. The Data Protection Officer will consider the suitability and adequacy of this policy and report improvements directly to management.
Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in creating, maintaining and removing records.
Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this Policy and are given adequate and regular training on it.
EMAILS
Emails accounts are not a case management tool in itself. Generally emails may need to fall under different retention periods (for example, an email regarding a health and safety report will be subject to a different time frame to an email which forms part of a pupil record). It is important to note that the retention period will depend on the content of the email and it is important that staff file those emails in the relevant areas to avoid the data becoming lost.
PUPIL RECORDS
All Schools with the exception of independent schools, are under a duty to maintain a pupil record for each pupil. If a child changes schools, the responsibility for maintaining the pupil record moves to the next school. We retain the file for a year following transfer in case any issues arise as a result of the transfer.
Retention Schedule
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FILE DESCRIPTION |
RETENTION PERIOD |
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Employment Records |
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Job applications and interview records of unsuccessful candidates |
Six months after notifying unsuccessful candidates, unless the school has applicants’ consent to keep their CVs for future reference. In this case, application forms will give applicants the opportunity to object to their details being retained |
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Job applications and interview records of successful candidates |
6 years after employment ceases |
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Written particulars of employment, contracts of employment and changes to terms and conditions |
6 years after employment ceases |
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Right to work documentation including identification documents |
6 years after employment ceases |
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Immigration checks |
Two years after the termination of employment |
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DBS checks and disclosures of criminal records forms |
As soon as practicable after the check has been completed and the outcome recorded (i.e. whether it is satisfactory or not) unless in exceptional circumstances (for example to allow for consideration and resolution of any disputes or complaints) in which case, for no longer than 6 months. |
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Change of personal details notifications |
No longer than 6 months after receiving this notification |
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Emergency contact details |
Destroyed on termination |
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Personnel records |
While employment continues and up to six years after employment ceases (Limitation Act 1980) |
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Annual leave records |
Six years after the end of tax year they relate to or possibly longer if leave can be carried over from year to year |
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Consents for the processing of personal and sensitive data |
For as long as the data is being processed and up to 6 years afterwards |
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Working Time Regulations:
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Disciplinary records |
6 years after employment ceases |
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Training |
6 years after employment ceases or length of time required by the professional body |
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Staff training where it relates to safeguarding or other child related training |
Date of the training plus 40 years (This retention period reflects that the IICSA may wish to see training records as part of an investigation) |
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Annual appraisal/assessment records |
Current year plus 6 years |
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Professional Development Plans |
6 years from the life of the plan |
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Allegations of a child protection nature against a member of staff including where the allegation is founded |
10 years from the date of the allegation or the person’s normal retirement age (whichever is longer). This should be kept under review. Malicious allegations should be removed. |
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Financial and Payroll Records |
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Pension records |
12 years |
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Retirement benefits schemes – notifiable events (for example, relating to incapacity) |
6 years from the end of the scheme year in which the event took place |
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Payroll and wage records |
6 years after end of tax year they relate to (Taxes Management Act 1970; Income and Corporation Taxes 1988) |
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Maternity/Adoption/Paternity Leave records |
3 years after end of tax year they relate to |
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Statutory Sick Pay |
3 years after the end of the tax year they relate to |
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Current bank details |
Until updated plus 3 years |
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Bonus Sheets |
Current year plus 3 years |
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Time sheets/clock cards/flexitime |
Current year plus 3 years |
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Pupil Premium Fund records |
Date pupil leaves the provision plus 6 years |
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National Insurance (schedule of payments) |
Current year plus 6 years (Taxes Management Act 1970; Income and Corporation Taxes 1988) |
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Insurance |
Current year plus 6 years (Taxes Management Act 1970; Income and Corporation Taxes 1988) |
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Overtime |
Current year plus 3 years (Taxes Management Act 1970; Income and Corporation Taxes 1988) |
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Annual accounts |
Current year plus 6 years |
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Loans and grants managed by the School |
Date of last payment on the loan plus 12 years |
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All records relating to the creation and management of budgets |
Life of the budget plus 3 years |
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Invoices, receipts, order books and requisitions, delivery notices |
Current financial year plus 6 years |
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Student Grant applications |
Current year plus 3 years |
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Pupil Premium Fund records |
Date pupil leaves the school plus 6 years
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School fund documentation (including but not limited to invoices, cheque books, receipts, bank statements etc). |
Current year plus 6 years |
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Free school meals registers (where the register is used as a basis for funding) |
Current year plus 6 years |
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School meal registers and summary sheets |
Current year plus 3 years |
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Agreements and Administration Paperwork |
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Collective workforce agreements and past agreements that could affect present employees |
Permanently |
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Trade union agreements |
10 yeas after ceasing to be effective |
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School Development Plans |
3 years from the life of the plan |
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Visitors Book and Signing In Sheets |
6 years |
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Newsletters and circulars to staff, parents and pupils |
1 year (and the School may decide to archive one copy) |
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Minutes of Senior Management Team meetings |
Date of the meeting plus 3 years or as required |
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Reports created by the Head Teacher or the Senior Management Team. |
Date of the report plus a minimum of 3 years or as required
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Records relating to the creation and publication of the school prospectus |
Current academic year plus 3 years |
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Health and Safety Records |
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Health and Safety consultations |
Permanently |
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Health and Safety Risk Assessments |
Life of the risk assessment plus 3 years |
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Health and Safety Policy Statements |
Life of policy plus 3 years |
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Any records relating to any reportable death, injury, disease or dangerous occurrence |
Date of incident plus 3 years provided that all records relating to the incident are held on personnel file |
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Accident reporting records relating to individuals who are under 18 years of age at the time of the incident |
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Accident reporting records relating to individuals who are over 18 years of age at the time of the incident |
Accident book should be retained 3 years after last entry in the book. (Social Security (Claims and Payments) Regulations 1979; Social Security Administration Act 1992; Limitation Act 1980) |
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Fire precaution log books |
Current year plus 3 years |
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Medical records and details of: -
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40 years from the date of the last entry made in the record (Control of Substances Hazardous to Health Regulations (COSHH); Control of Asbestos at Work Regulations) |
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Records of tests and examinations of control systems and protection equipment under COSHH |
5 years from the date on which the record was made |
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Temporary and Casual Workers |
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Records relating to hours worked and payments made to workers |
3 years |
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Governing Body Documents |
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Instruments of government |
For the life of the School |
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Meetings schedule |
Current year |
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Minutes – principal set (signed) |
Generally kept for the life of the organisation |
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Agendas – principal copy |
Where possible the agenda should be stored with the principal set of the minutes |
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Agendas – additional copies |
Date of meeting |
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Policy documents created and administered by the governing body |
Until replaced |
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Register of attendance at full governing board meetings |
Date of last meeting in the book plus 6 years |
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Annual reports required by the Department of Education |
Date of report plus 10 years |
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Records relating to complaints made to and investigated by the governing body or head teacher |
Major complaints: current year plus 6 years. If negligence involved: current year plus 15 years. If child protection or safeguarding issues are involved then: current year plus 40 years. |
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Correspondence sent and received by the governing body or head teacher |
General correspondence should be retained for current year plus 3 years |
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Records relating to the terms of office of serving governors, including evidence of appointment |
Date appointment ceases plus 6 years |
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Register of business interests |
Date appointment ceases plus 6 years |
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Records relating to the training required and received by governors |
Date appointment ceases plus 6 years |
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Records relating to the appointment of a clerk to the governing body |
Date on which clerk appointment ceases plus 6 years |
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Governor personnel files |
Date appointment ceases plus 6 years |
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Pupil Records |
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Details of whether admission is successful/unsuccessful |
1 year from the date of admission/non-admission |
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Proof of address supplied by parents as part of the admissions process |
Current year plus 1 year |
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Admissions register |
Entries to be preserved for three years from date of entry |
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Pupil Record |
Secondary – until the child reaches the age of 25 (Limitation Act 1980) |
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Attendance Registers |
3 years from the date of entry |
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Correspondence relating to any absence (authorised or unauthorised) |
Current academic year plus 2 years (Education Act 1996) |
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Special Educational Needs files, reviews and Education, Health and Care Plan, including advice and information provided to parents regarding educational needs and accessibility strategy |
Date of birth of the pupil plus 31 years (Education, Health and Care Plan is valid until the individual reaches the age of 25 years – the retention period adds an additional 6 years from the end of the plan). (Children and Family’s Act 2014; Special Educational Needs and Disability Act 2001)
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Child protection information (to be held in a separate file). |
DOB of the child plus 25 years then review Note: These records will be subject to any instruction given by IICSA |
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Exam results (pupil copy) |
1-3 years from the date the results are released |
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Examination results (school’s copy) |
Current year plus 6 years |
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Allegations of sexual abuse |
For the time period of an inquiry by the Independent Inquiry into Child Sexual Abuse |
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Records relating to any allegation of a child protection nature against a member of staff |
Until the accused normal retirement age or 10 years from the date of the allegation (whichever is the longer) |
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Consents relating to school activities as part of UK GDPR compliance (for example, consent to be sent circulars or mailings) |
Consent will last whilst the pupil attends the school. |
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Pupil’s work |
Where possible, returned to pupil at the end of the academic year (provided the School have their own internal policy to this effect). Otherwise, the work should be retained for the current year plus 1 year. |
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Mark books |
Current year plus 1 year |
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Schemes of work |
Current year plus 1 year |
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Timetable |
Current year plus 1 year |
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Class record books |
Current year plus 1 year |
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Record of homework set |
Current year plus 1 year |
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Photographs of pupils |
For the time the child is at the School and for a short while after. Please note select images may also be kept for longer (for example to illustrate history of the school). |
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Parental consent forms for school trips where there has been no major incident |
End of the trip or end of the academic year (subject to a risk assessment carried out by the School) |
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Parental permission slips for school trips where there has been a major incident |
Date of birth of the pupil involved in the incident plus 25 years. Permission slips for all the pupils on the trip should be retained to demonstrate the rules had been followed for all pupils |
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Other Records |
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Emails |
Auto-deleted after 2 years |
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Privacy notices |
Until replaced plus 6 years |
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Inventories of furniture and equipment |
Current year plus 6 years |
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All records relating to the maintenance of the School carried out by contractors or employees of the school |
Whilst the building belongs to the school |
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Records relating to the letting of school premises |
Current financial year plus 6 years |
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Records relating to the creation and management of Parent Teacher Associations and/or Old Pupils Associations |
Current year plus 6 years then review |
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Referral forms |
While the referral is current |
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Contact data sheets |
Current year then review, if contact is no longer active then destroy |
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May 2024
[CS1]The official guidance states that this data should be kept for 3 years from the date of entry in the book but we advise keeping until 21 (3 years from when they turn 18) as this covers the limitation period of making a claim once the child turns 18.
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