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Data Retention

The School has a responsibility to maintain its records and record keeping systems.

When doing this, the School 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

• Their accessibility.

 

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 the School’s current practice, the requirements of current legislation and best practice and guidance. It may be amended by the School 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. The School 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 General Data Protection Regulation (GDPR) and the Freedom of Information Act 2000.

Data will be stored and processed to allow for the efficient operation of the School.

The School’s Data Protection Policy outlines its duties and obligations under the 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, the School will adhere to the standard retention times listed within that schedule.

Paper records for staff, health and safety, school development will be regularly monitored by Lorraine Stock (school finance and business manager) and paper records for pupils (including accidents and risk assessments for off site visits) and administration will be regularly monitored by Rita Giles (Admin) or Christopher Giles (Admin / EVC)

 

Electronic records for staff, health and safety, school development will be regularly monitored by Lorraine Stock (school finance and business manager) and Electronic records for pupils (including accidents and risk assessments for off site visits) and administration will be regularly monitored by Rita Giles (Admin) or Christopher Giles (Admin / EVC)

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.

 

Destruction of Records

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.

The School 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; and

• Name of the authorising officer.

 

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 Lorraine Stock (school finance and business manager).

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

Marina Kennedy (Head Teacher) has primary and day-to-day responsibility for implementing this Policy. The Data Protection Officer, in conjunction with the School 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.

 

Retention Schedule

Employment Records

Job applications and interview records 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

 

Job applications and interview records of successful candidates

  • 6 years after employment ceases

 

Written particulars of employment, contracts of employment and changes to terms and conditions

  • 6 years after employment ceases

 

Right to work documentation including identification documents

  • 2 years after employment ceases

 

 Immigration checks

  • Two years after the termination of employment

 

DBS checks and disclosures of criminal records

  • As soon as practicable after the check has been forms 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.

 

Change of personal details notifications

  • No longer than 6 months after receiving this notification

 

Emergency contact details

  • Destroyed on termination

 

Personnel and training records

  • While employment continues and up to six years after employment ceases

 

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

 

Consents for the processing of personal

  •  For as long as the data is being processed and sensitive data up to 6 years afterwards

 

Working Time Regulations:

Opt out forms

• Two years from the date on which they

 

Records of compliance with WTR were entered into

• Two years after the relevant period

 

Disciplinary and training records

  • 6 years after employment ceases
  •  

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 persons normal retirement age (whichever is longer) This should be kept under review
  • Malicious allegations should be removed.

 

 

 

Financial and Payroll Records

Pension records

  • Pension records 12 years

 

Retirement benefits schemes – (for example, relating to incapacity)  

  • 6 years from the end of the scheme year in which the event took place

 

Payroll and wage records

  • 6 years after end of tax year they relate to

 

Maternity/Adoption/Paternity Leave records

  • 3 years after end of tax year they relate to

 

Statutory Sick Pay

  • 3 years after the end of the tax year they relate to

 

Current bank details

  • No longer than necessary

 

Agreements and Administration Paperwork

Collective workforce agreements and past agreements that could affect present Employees

  • Permanently

Trade union agreements

  • 10 years after ceasing to be effective

School Development Plans

  • 3 years from the life of the plan

Professional Development Plans

  • 6 years from the life of the plan

Visitors Book and Signing In Sheets

  • 6 years

Newsletters and circulars to staff, parents and pupils

  • 1 year

 

Health and Safety Records

Health and Safety consultations

  • Permanently

 

Health and Safety Risk Assessments

  • 3 years from the life of the risk assessment

 

Any reportable accident, death or injury in connection with work

  • For at least twelve years from the date the connection with work report was made

 

Accident reporting

  • Adults - 6 years from the date of the incident
  • Children – when the child attains 25 years of age.

 

Fire precaution log books

  • 6 years

 

Medical records and details of:

  • Control of lead at work 
  • Employees exposed to asbestos dust
  • Records specified by the Control of Substances Hazardous to Health Regulations (COSHH)
  • 40 years from the date of the last entry made in the record

 

Records of tests and examinations of control systems and protection equipment under made COSHH

  • 5 years from the date on which the record was made

 

 

Temporary and Casual Workers

Records relating to hours worked and payments made to workers

  • 3 years

 

 

Pupil Records

Admissions records

  • 1 year from the date of admission

 

Admissions register Entries

  • to be preserved for three years from date of entry

 

School Meals Registers

  • 3 years

 

Free School Meals Registers

  • 6 years

 

Pupil Reports

  • 1 year after the child leaves the school

 

Attendance Registers

  • 3 years from the date of entry

 

Special Educational Needs files, reviews and individual education plans (this includes any statement and all advice and information shared regarding educational needs)

  • Until the child turns 25

 

Emails

  • 12 months after the date of email unless relating to above areas where the above relevant timescales are followed and then the email is printed.

 

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