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Data Retention &
Disposal Policy
Policy Type: Non Statutory
Review Frequency: 3-Yearly
Approved – Finance & General Purposes Committee: 28/9/2018
Next Review Date: 28/9/2021
Document History:
Date Author Summary of Changes Version
18/08/2018 Rawdon Cowley Creation of Policy 1.0d
28/09/2018 Rawdon Cowley Published 1.0
Rationale
The retention and disposal policy lays down the length of time which the record needs to be retained and the
action, which should be taken when it is of no further administrative use.
Members of staff are expected to manage their current record keeping systems using this policy schedule and to
take account of the different kinds of retention periods when they are creating new record keeping systems.
The policy refers to all information, regardless of the media in which they are stored.
Retention Period
The Trust has adopted the retention schedule guidelines as published in the Information Record
Management Toolkit for Schools (currently version 5 dated 1/2/16) and lists the current legislative
frameworks for managing records within schools. This is the basis for the retention period and subsequent
disposal of the Trust’s records.
Appendix A reproduces this retention and disposal schedule.
The IMRS toolkit document can be downloaded at www.irms.org.uk
Appendix B lists the retention and disposal schedule for documents not listed in the IMRS schedule or
where the Trust wishes to deviate from the suggested schedule for good operational reasons.
What to do with records once they have reached the end of their administrative life
Destruction of Records
Where records have been identified for destruction, they should be disposed of in an appropriate way. All
records are likely to contain data that would be identified under the GDPR act such as personal
information or sensitive information and should disposed of using the confidential waste disposal system
in place at each school location.
Transfer of records to the Archives
Where records have been identified as being worthy of long term or permanent preservation and not
needed in the day-to-day operation of the school or Trust then arrangements should be made to transfer
the records to archives.
Transfer of 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. The lifespan of the media and the ability
to migrate data where necessary should always be considered. Records transferred to media must be
transferred in accordance with the Data Protection Policy and ICT System Acceptable Use Policy &
Agreement.
Appendix A: IRMS - Retention and disposal actions
Appendix B: Trust – Supplementary and overriding (to IRMS, Appendix A) retention and disposal actions
1. Management of the School
Basic File Description Data Protection
Issues
Provisions Retention Period Action at the end of the
administration life of the record
1.1.x Governing Body
1.1.12 Related Party Documents Yes Date of declaration + 6
years
SECURE DISPOSAL
1.2.x Executive Headteacher and Senior Management Team
None
1.3.x Admissions Process
None
1.4.x Operational Administration
None
2. Human Resources
Basic File Description Data Protection
Issues
Provisions Retention Period Action at the end of the
administration life of the record
2.1.x Recruitment
2.1.4 Latest Document
September 2018
2.16 Latest Document
June 2018
2.2.x Operational Staff Management
None
2.3.x Management of Disciplinary and Grievance Processes
2.3.1 Latest Document
September 2018
2.3.3 Incident Investigation Reports Yes Date of investigation + 12
months
SECURE DISPOSAL
2.4.x Health and Safety
None
2.5.x Payroll and Pensions
None
3. Financial Managemnt of the School
Basic File Description Data Protection
Issues
Provisions Retention Period Action at the end of the
administration life of the record
3.1.x Risk Management and Insurance
None
3.2.x Asset Management
None
3.3.x Accounts and Statements including Budget Management
None
3.4.x Contract Management
None
3.5.x School Fund
None
3.6.x School Meal Management
None
4. Property Management
Basic File Description Data Protection
Issues
Provisions Retention Period Action at the end of the
administration life of the record
4.1.x Property Management
None
4.2.x Maintenance
None
5. Pupil Management
Basic File Description Data Protection
Issues
Provisions Retention Period Action at the end of the
administration life of the record
5.1.x Pupil’s Educational Record
5.1.3 Child Protection Latest Document
September 2018
5.1.4 Child Protection Latest Document
September 2018
5.2.x Attendance
5.2.1 Latest Document
September 2018
5.3.x Special Educational Needs
None
6. Curriculum Management
Basic File Description Data Protection
Issues
Provisions Retention Period Action at the end of the
administration life of the record
6.1.x Statistics and Management Information
None
6.2.x Implementation of Curriculum
None
7. Extra-Curricular Activities
Basic File Description Data Protection
Issues
Provisions Retention Period Action at the end of the
administration life of the record
7.1.x Educational Visits outside the Classroom
None
7.2.x Walking Bus
None
7.3.x Family Liaison Officers and Home School Liaison Assistants
None
8. Central Government and Local Authority
Basic File Description Data Prot Issues Provisions Retention Period Action at the end of the
administration life of the record
8.1.x Local Authority
None
8.2.x Central Government
None
