Data Retention

High School of Dundee Data Retention Policy

The purpose of this policy is to regulate the management and retention of data by The High School of Dundee (the School). It also serves as a notice and a guide to data subjects (including pupils, parents, staff, volunteers, visitors to the School and members of the public) regarding their rights in relation to personal data held by the School.

Schools will generally seek to balance the benefits of keeping detailed and complete records – for the purposes of good practice, archives, of general reference – with the practical considerations of storage, space and accessibility. The School must be mindful of legal considerations in respect of retention of records and documents which must be borne in mind. These include:

• statutory duties and government guidance relating to schools, including child protection;
• disclosure requirement for future litigation;
• contractual obligations;
• the law of Confidentiality and Privacy;
• the Data Protection Act 1998 (DPA), soon to be replaced on 25 May 2018 with the General Data Protection Regulation (GDPR) incorporated within the DPA 2018, see below.

Under Data Protection Law, we are prohibited from retaining personal data for longer than necessary for the purpose or purposes for which it was obtained. This legal requirement is reflected in Principle 6 (Retention) of the Data Protection Policy. Appendix 1 to this policy is the detailed Data Retention Schedule across all departments of the School. Personal data is deemed to be that which a living individual can be identified from.

Child Protection and Document Retention

In light of the Scottish Child Abuse Inquiry, all independent schools will be aware of the emphasis currently being placed on long-term, lifetime, or even indefinite keeping of full records relating to incident reporting. The School are extending this to include all staff and pupil files. This does not extinguish the School’s obligation to keep this data accurately and securely.

Archiving and Destruction or Erasure of Records

All records containing personal data, or sensitive policy or management information should be made unreadable or unreconstructable, eg.

• CDs/DVDs/Floppy disks should be cut into pieces
• Paper records shredded or disposed of in the confidential waste bins
• Hard disks/USB pens dismantled and sanded

Any records containing personal data must not be disposed of in a conventional waste bin or skip.

Appendix 1 - Data Retention Schedule

1) Governing Body

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
1.1	Agendas for Board / Committee meetings	No		One copy retained - 6 years plus current	Confidential waste
1.2	Board / Committee minutes	Possible confidential issues raised		Permanent record
1.3	Reports presented to Board	Possible confidential issues raised		One copy retained - 6 years plus current	Confidential waste
1.4	Constitution	No		Permanent
1.5	Trusts & Endowments managed by the School	No		Permanent
1.6	Records relating to complaints dealt with by the Board	Yes		6 years then reviewed to see if still area of contention	Confidential waste

2) Rector and Senior Leadership Team

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
2.1	Agendas for SLT meetings	Possibly		3 years at end of session	Confidential waste
2.2	SLT minutes	Possible confidential issues raised		3 years at end of session then review	Confidential waste
2.3	Reports created by the Rector / SLT	Possible confidential issues raised		3 years at end of session then review	Confidential waste
2.4	Correspondence created by the Rector / SLT / HoDs	Possibly		If in relation to pupil, 2 years after leaving school	Confidential waste
2.5	Professional Development Plans	Yes		2 years after staff member leaving	Confidential waste
2.6	School Development Plans	No		Life of plan + 10 years	Confidential waste

3) Admissions Process

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
3.1	Admissions policy	No		Life of policy + 3 years	Confidential waste
3.2	Initial enquiry	Yes		Date of expected entry + 1 year	Deletion
3.3	Admissions paperwork - unsuccessful	Yes		Date of admission + 1 year	Confidential waste
3.4	Admissions paperwork - successful	Yes		Added to pupil file, therefore date of disposal of pupil file	Confidential waste
3.5	Proof of address / identity	Yes		Added to pupil file	Confidential waste
3.6	Event registration	Yes		Current year	Confidential waste

4) Operational Administration

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
4.1	Visitors book	Yes		Current year + 3 years	Confidential waste
4.2	Consents	Yes		5 years after pupil leaving school	Confidential waste

5) Human Resources

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
5.1	Recruitment records - unsuccessful	Yes	Discrimination claims - 3 months	1 year	Confidential waste
5.2	Recruitment records - successful	Yes		Added to staff file, see below	Confidential waste
5.3	Pre-employment PVG checks	Yes	Disclosure Scotland guidance	Certificate kept for 6 months	Confidential waste
5.4	Proof of identity / right to work in the UK checks	Yes	Home Office guidance - date staff leaves + 2 years	Placed on staff file	Confidential waste
5.5	Staff file*	Yes		Staff leave + 6 years	Confidential waste
5.6	Timesheets	Yes		Current year + 6 years	Confidential waste
5.7	Maternity Pay Records	Yes	SMP regulations	Current year + 6 years	Confidential waste
5.8	Professional Review	Yes		Current year + 6 years	Confidential waste
5.9	Child protection allegation - unfounded*	Yes		Until pupil concerned is 26 years old	Confidential waste
5.10	Disciplinary proceedings*	Yes		Per disciplinary policy dependent on type of warning	Confidential waste

6) Health and Safety

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
6.1	Policy Statements	No		Life of policy + 3 years	Confidential waste
6.2	Risk Assessments (DSE, COSHH, PEWER, general / whole school risk assessment)	No		Life of assessment + 3 years	Confidential waste
6.3 A	Records relating to accident at work / injury: RIDDOR reportable	Yes	HSE guidance	a) Date of incident + 25 years	Confidential waste
6.3 B	Records relating to accident at work / injury: Non-Reportable	Yes	HSE Guidance	Date of incident + 3 years	Confidential waste
6.4 A	COSHH Records	No	Control of Substances Hazardous to Health Regulations 2002.	Life of assessment + 3 years	Disposal
6.4 B	Reports monitoring PPE / fume cupboards	No	Control of Substances Hazardous to Health Regulations 2002.	Life of report + 5 years	Disposal
6.5	Asbestos registers	No	Control of Asbestos at Work Regulations 2012.	Life of document + 3 years	Confidential waste
6.6	Fire Log Book / Fire Risk Assessment	No		Current year + 6 years	Confidential waste
6.7	Water testing	No		Current year + 5 years	Confidential waste
6.8	Working at height testing	No		Life of assessment + 3 years	Confidential waste

7) Financial Management

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
7.1	Employer Liability Insurance certificate	No		Closure of school + 40 years	Disposal
7.2	Asset register	No		Current year + 6 years	Confidential waste
7.3	Annual accounts - signed	No		Indefinitely
7.4	Working papers of annual accounts	No		Current year + 6 years	Confidential waste
7.5	Loan documentation	No		End of loan + 6 years	Confidential waste
7.6	Annual budget and papers	No		Current year + 6 years	Confidential waste
7.7	Purchase invoices, statements, purchase orders, credit card statements	No		Current year + 6 years	Confidential waste
7.8	Sales invoices, DD collection prints	Yes		Current year + 6 years	Confidential waste
7.9	Pupil financial record	Yes		Upon leaving the school, provided no debt	Confidential waste
7.10	Direct debit mandates	Yes	Indemnity Scheme	Indefinitely
7.11	Bank records	No		Current year + 6 years	Confidential waste
7.12	Trip payment records	Yes		Current year + 2 years	Confidential waste
7.13	Staff expenses	Yes		Current year + 6 years	Confidential waste
7.14	Contract arrangements	No	Limitation Act 1980	Last payment + 6 years	Confidential waste

 8) Property Management

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
8.1	Title deeds of property	No		Permanent
8.2	Plans	No		Until sold / superseded	Confidential waste
8.3	Letting of premises	No		Current year + 6 years	Confidential waste
8.4	Maintenance logs	No		Current year + 6 years	Confidential waste

9) Pupil Management

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
9.1	Pupil record*	Yes		School age - should follow pupil if they leave to go to another school, or if they finish school career at HSD - 7 years after leaving	Confidential waste / deletion
9.2A	Child Protection Information* Not placed on CP register	Yes	GIRFEC	Until 26 years old then reviewed	Confidential waste / deletion
9.2B	Child Protection Information* Placed on CP register	Yes	GIRFEC	Until 35 years old then reviewed	Confidential waste / deletion
9.2C	Child Protection Information* Placed on CP / LAC register	Yes	GIRFEC	Retain 100 years	Confidential waste / deletion
9.3	Attendance register	Yes		Current year + 3 years	Deletion
9.4	Correspondence relating to absence	Yes		Current year	Confidential waste
9.5	Special Educational Needs files	Yes		Until 26 years old	Confidential waste

 10) Curriculum Management

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
10.1	Curriculum choices	Yes		Current year + 2 years	Confidential waste
10.2	School copy of exam results	Yes		Current year + 10 years	Confidential waste / deletion
10.3	Class work supporting exams	Yes		One year from exam diet	Confidential waste
10.4	Timetable	Yes		Current year + 1 year	Deletion
10.5	Mark books, homework, pupil work etc.	Yes		Current year + 3 years	Confidential waste / deletion

11) Co-curriculum Management

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
11.1	Parental consents - no incidents	Yes		1 year from trip completion	Confidential waste
11.2	Parental consents - major incident	Yes	Limitation Act 1980	Until pupil 25 years old	Confidential waste

12) ICT Management

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
12.1	Monitoring logs	Yes		12 months	Deletion
12.2	Active directory accounts	Yes		Deleted within 30 days of notification	Deletion
12.3	Email accounts	Yes		30 days of termination (unless requested to keep)	Deletion
12.4	Personal document folder (N drive)	Yes		30 days of notification	Deletion
12.5	PC and iPad	Yes		Wiped prior to reallocation	Deletion

13) Marketing / Publications

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
13.1	Photographs - events, achievements (where consent obtained)	Yes		Current year + 3 years unless published	Deletion
13.2	Electronic copy of published material	Yes		Retained to become historical archive

14) Bursary Management

	Basic Description	DP Issues	Statutory Provisions	Retention Period	End of Life Action
14.1	Bursary application form	Yes		Pupil school life + 1 year	Confidential waste
14.2	Information provided to support bursary application	Yes		End of academic year in which application was made	Confidential waste
14.3	Financial assessments	Yes		Pupil school life + 1 year	Confidential waste / deletion

*In light of the Scottish Child Abuse Inquiry, all independent schools will be aware of the emphasis currently being placed on long-term, lifetime, or even indefinite keeping of full records relating to incident reporting. The School are extending this to include all personnel and pupil files. This does not extinguish the School’s obligation to keep this data accurately and securely.