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.