Data Retention Policy

Changing Lives 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 reflects current practice, legislation and guidance. It may be amended from time to time, with changes notified to employees within one month of effect.

This policy sets out how long employment-related and pupil data will normally be held and when it will be destroyed in compliance with UK 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 under UK GDPR.

Information (hard copy and electronic) will be retained for at least the periods specified in the retention schedule. Paper and electronic records will be monitored by regular internal reviews. The schedule lists record types and their required retention periods based on business needs and legal requirements.

Where records have been identified for destruction, they should be disposed of appropriately. All information must be reviewed before destruction to determine whether special factors (litigation, complaints, grievances) require delay.

Destruction will normally occur outside normal operating periods (e.g., school holidays). Records identified for destruction will be destroyed by 1st September after the retention period expires.

Paper records containing personal or sensitive information should be shredded; electronic records will be deleted.

The school maintains a database of destroyed records, recording for each:

• File reference or unique identifier;
• File title/description;
• Number of files;
• Name of authorising officer;
• Date destroyed or deleted;
• Person(s) undertaking destruction.

Malicious allegations must not be part of personnel records. For other allegations, keep a comprehensive summary of the allegation, investigation details and decisions on the accused’s personnel file.

Allegations of sexual abuse must be preserved for the duration of any Independent Inquiry into Child Sexual Abuse (IICSA). Other records should be retained until the accused reaches normal pension age or 10 years from the allegation date (whichever is longer).

While IICSA is ongoing, it is an offence to destroy relevant records. After the inquiry concludes, retention guidance will be issued.

Records identified for long-term preservation should be transferred to archives. The SLT maintains a database of archived records, recording for each:

• File reference or unique identifier;
• File title/description;
• Number of files;
• Name of authorising officer.

For records with lengthy retention periods, consider converting paper records to digital media or virtual storage (e.g., cloud). Always consider media lifespan and data migration needs.

Pupil educational records are retained while the child attends the school. Upon transfer, responsibility moves to the receiving school. The original file is archived in case issues arise. Destruction may be delayed for special factors (e.g., litigation).

SLT have primary responsibility for implementing this policy. Internal controls and procedures are audited regularly to ensure effective record creation, maintenance, and removal.

Management at all levels must ensure their teams understand and follow this policy and receive adequate training.

Email accounts are not case management tools. Retention periods depend on email content. Staff must file emails in relevant areas to ensure proper retention and retrieval.

All schools (except independent) must maintain a pupil record for each pupil. When a pupil leaves, the record transfers to the next school. We retain the file for one year post-transfer in case issues arise.

Employment Records

Financial and Payroll Records

Agreements and Administration Paperwork

Health and Safety Records

Temporary and Casual Workers

Pupil Records

Other Records

Associations and/or Old Pupils