Records Retention Policy

SHRED/DELETE or delete copies and including back-ups and copies

SHRED/DELETE including back-ups and copies

SHRED/DELETE

Notes

1                     Child protection information must be copied and sent under separate cover to the new school whilst the child is still under 18.  Federations should ensure secure transit and confirmation of receipt should be obtained

2                     Where a child is removed from roll to be educated at home, the file should be copied to the Local Authority (LA)

3                    In accordance with the terms of reference of the Independent Inquiry into Child Sexual Abuse all schools are required to retain information which relates to allegations (substantiated or not) of organisations and individuals who may have been involved in, or have knowledge of child sexual abuse or child sexual exploitation; allegations (substantiated or not) of individuals having engaged in sexual activity with, or having a sexual interest in, children; institutional failures to protect children from sexual abuse or other exploitation.  50 years from the date of birth of the pupil involved should be a sufficient period of retention but this should be kept under review

Six years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

Whichever is the longer

The 25 year period is based on the fact that once the child turns 18 years old they have a certain amount of time (known as a limitation period) in which to bring claims against the Federation.  The longest of these limitation periods is six years, albeit that some periods can be extended by the courts

SHRED/DELETE

Six years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

Whichever is the longer

SHRED/DELETE

Six years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

Whichever is the longer

SHRED/DELETE

Notes

1                     When reviewing pupil files, the Federation should have regard to other applicable sections of this policy

2                     Any examination certificates left unclaimed should be returned to the appropriate Examination Board

Scripts from weekly or monthly tests: Keep until the end of the next term.

Whichever is the longer

Scripts from termly or yearly tests: Keep until the end of the next academic year.

Marks & results:

If the purpose of the test is to progress the child (either internally or externally) then keep marks & results in accordance with the retention periods and guidance set out in row 2.1 above.

If the purpose of the test is for general internal assessment of academic performance then keep marks & results for the same period as the scripts themselves.

Six years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

Whichever is the longer

SHRED/DELETE

The Statement / Plan belongs to the LA which makes and maintains the Statement / Plan

Six years from the date of the incident if the pupil was 18 years old at the date of the incident

Whichever is the longer

The permission slips for all pupils on the trip may need to be retained to show that the rules had been followed for all pupils

SHRED/DELETE

SHRED/DELETE

The documents can be kept for as long as the Federation considers that they are required, subject to the Federation’s obligation not to keep the documents for longer than is necessary

SHRED / DELETE

For at least 12 years after date of termination if any of the documents were signed as a deed

If any concerns are/have been raised by social services or other agencies see 5.5 below.

If none, SHRED/DELETE

If none, SHRED/DELETE

These include records of:

•Details on overtime.

•Bonuses.

•Expenses.

•Benefits in kind.

These include:

•Records regarding Maternity payments made save for where those include payroll records.

•Maternity certificates showing the expected week of confinement

For consent to be valid it must be “freely given”.  This is often difficult to evidence in an employment context owing to the imbalance in the relationship between the Federation and the employee.  Therefore, the Federation should be very careful before asking employees to consent to their data being used in a particular way.  In the vast majority of cases it is not necessary to obtain the employee’s consent before using their personal data.

The DBS information – certificate, date, initials, will be recorded on the Single Central Register.

If the DBS is completed by the CLF and is clear the snapshot from protocol will be kept on employee personnel file or volunteer/visitor file.

If the DBS is not completed by CLF and is clear the details will be recorded on a form which will be stored in volunteer/visitor file.

If there are convictions on the DBS, this information will be recorded in a file note along with the rationale to proceed with recruitment. This will be recorded on employee personnel file or volunteer/visitor file.

Candidates applying for roles will be asked to declare any relevant convictions. Details of these will be recorded in the application form and any interview notes.

As per above for Single Central Register (5.2)

This will be destroyed when file is destroyed as per this retention policy.

This will be destroyed when file is destroyed as per this retention policy.

This will be destroyed when file is destroyed as per this retention policy.

This will be destroyed when file is destroyed as per this retention policy.

These directories should not include personal information about the staff member or pupils so should not form part of their employment record or details relating to safe guarding or pupil management.

If disease – indefinitely (recommended)

SHRED/DELETE

If disease – indefinitely

SHRED/DELETE

SHRED/DELETE

In other cases at least five years from the date of the last entry

SHRED/DELETE

SHRED/DELETE

Three years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

SHRED/DELETE

Three years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

SHRED/DELETE

Three years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

SHRED/DELETE

General records of health and safety auditing and monitoring including fire risk assessments, electrical testing, PAT testing and gas appliance testing

Training records and copies of instructions or information

Maintenance logs and / or records of plant and / or equipment plus safety manuals  / notices / instructions

Records of emergency evacuations and fire drills, fire safety risk assessments and fire safety policy / fire arrangements

SHRED/DELETE

If the incident involved a pupil – DOB of the pupil involved in the incident + 21 years; or

Three years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident

Disease claims or where there have been allegations of abuse – indefinitely

SHRED/DELETE

Copies of reports submitted to external agencies / regulators such as Ofsted, Health and Safety Executive, Local Authority, Education and Skills Funding Agency etc

External reports, reviews, investigations and inquiries for example inquests and public inquiries

Where the investigation / inquiry / report has been necessitated as a result of a specific incident, we recommend that these documents are stored centrally for at least three years where there is a risk of enforcement action and / or criminal prosecution and / or a civil claim.  Where this relates to pupil DOB +21 years); or

Three years from the date of an incident which may become contentious if the pupil was 18 years old at the date of the incident.

This is subject to any longer retention period set out above or below.  For example, records relating to a reportable disease should be kept indefinitely.

Review for further retention if the recording may be required for any reason such as in relation to an incident or accident involving any person.

CCTV footage may also be needed in relation to parental complaints, disciplinary matters, pupil exclusions, bullying incidents or health and safety matters.

If a subject access request has been made for the footage it must be retained.

The Federation should consider the relevant limitation periods for claims being brought against the Federation and seek advice as necessary.

Review for further retention in the case of relevance to contentious disputes.

If the Federation would like to retain the images for archiving reasons please see the comments at paragraph Error! Reference source not found. of the introduction above.

Review for further retention in the case of relevance to contentious disputes.

If the Federation would like to retain the images for archiving reasons please see the comments at paragraph Error! Reference source not found. of the introduction above.

Review for further retention in the case of relevance to contentious disputes.

Downloaded content, held in a secure storage location, should be retained for 30 days unless the content needs to be retained for evidential purposes (See below).

Content which is retained for evidential purposes should be deleted after 6 months unless there are clear legal reasons to continue to hold it.

Review for further retention in the case of relevance to contentious disputes.

There is a requirement for meeting minutes to be signed (approved) before being stored. Typically, approval may be documented by virtue of the chair signing a copy of the minutes. Alternatively, minutes can be approved via email or by obtaining a digital signature. If either of the latter apply (minutes being approved via email or use of a digital signature) then the requirement has been met.

Review for further retention if the recording may be required for any reason such as in relation to the sponsor or conversion of an academy.

Review for further retention in the case of relevance to reported conflicts of interest and related party transactions.

Bank reconciliations

Bank statements

Petty cash records

Creditor’s invoices/credit notes – paper files

Creditor’s statements

Refunds

Requisition records

Creditor’s records and invoices/credit notes – electronic copies

Barclaycard statements

Journals

Trial balances

Reconciliations

Receipt books

Cash register records and reconciliations

Revenue records

Debtor’s records and invoices/credit notes – electronic copies

Debts written off

Purchase order records

Asset registers

Depreciation registers

Financial statements

ParentPay, Tucasi etc. statements

Bursary payment records

Remittance advice

Subsidiaries

Nominal ledger payments

See ICO Guidance – https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace