Records Retention Policy

1. Introduction


This Policy sets out retention periods for a range of records relating to student (at all levels and modes of study, including those at partner institutions) and course administration.  It aims to ensure that these records are managed consistently and are retained for as long as necessary to meet operational and business needs, and to demonstrate compliance with legal and regulatory requirements.  It applies to all the listed categories in whatever format they are held (ie paper or electronic).

The retention periods take into account relevant requirements of the University’s regulations and policies, as well as recommendations of the JISC HE Retention Schedule and common practice within higher education.

Unless otherwise stated, it is the responsibility of Faculties and Services to retain the items listed in this document.  It is recommended that Faculties and Services designate staff with responsibility for the oversight of records retention and the application of this policy at a local level.

1. Introduction


This Policy sets out retention periods for a range of records relating to student (at all levels and modes of study, including those at partner institutions) and course administration.  It aims to ensure that these records are managed consistently and are retained as long as necessary to meet operational and business needs, and to demonstrate compliance with legal and regulatory requirements.

1.1 Retention requirements

 The retention periods, with a few exceptions, have been categorised as minimum: ie the length of time for which each category is to be retained may be lengthened, but must not be shortened.  When determining whether to lengthen a retention period, there will be a need to balance a number of factors, including:

1.1.1 Cost

The resource implications of holding records should be considered: eg the cost of storage (physical and server), the cost of maintenance, and the cost of responding to Data Protection and Freedom of Information requests (see section 1.2).

1.1.2 Limitation Act 1980

Students have a contractual relationship with the University.  Various documents define the terms of the contract (eg student handbooks, programme specifications), while others provide evidence that the University has fulfilled its obligations and compiled with agreed procedures.  The Limitation Act limits the time for bringing a case for breach of contract or negligence to six years from the date of the alleged incident.  Certain records may therefore need to be retained for six years (following a student’s graduation or withdrawal) in case they are required for evidential purposes.

1.1.3 Data Protection Act 1998

  The Data Protection principles stipulate that personal data must only be used for the purposes for which it was obtained and kept for no longer than necessary.  If personal data is retained, a clear justification for doing so must be made (see section 1.2).

1.1.4 Professional, statutory and regulatory bodies

Where Faculties provide courses accredited by professional, statutory or regulatory bodies they must ensure compliance with any specific requirements affecting the maintenance and disposal of their records.

1.1.5 Risk

The risk implications of discarding information should be considered, such as the financial or legal consequences.  If there is an ongoing dispute or high risk of litigation, Faculties/Services will need to identify documents of value as evidence and retain them for an appropriate length of time.  They must also ensure that course information is not discarded prematurely, but continues to be available for students who take longer than average to complete a course (eg part-time students, students who intermit their studies).

Students should be informed about how long records (such as student files and assessed work) will be retained by advertising their retention periods, for example, within student handbooks.

1.2 Data Protection Act 1998 and Freedom of Information Act 2000

Records need to be managed in a consistent and controlled way, not only to ensure organisational efficiency but also to comply with statutory requirements, such as Data Protection and Freedom of Information legislation.

The Data Protection Act allows individuals to request access to their personal data (whether in paper or electronic format), and the University must respond to these subject access requests within 40 calendar days.  The Act also requires data to be accurate, kept up-to-date, gathered for a specified purpose, retained for no longer than necessary and protected against unauthorised loss, destruction or damage.  To comply with all these requirements, it is essential that information is managed efficiently and there are clear procedures for its retention and destruction. 

 The Freedom of Information Act provides a general right of access to the University’s records: the public have the right to be told whether information exists and to receive that information (subject to certain exemptions) within 20 working days of making a request.  Compliance with this legislation relies heavily on effective records management.

 Under section 77 of the Freedom of Information Act it is a criminal offence to alter, conceal or destroy any record held by a public body to prevent disclosure of information.  It is therefore essential that staff follow coherent and clearly defined procedures for the management of records: documenting retention periods allows the University to demonstrate that information has been destroyed legitimately and not to prevent disclosure.

1.3 Storage

Documents need to be arranged systematically and labelled helpfully, so that it will be possible to locate them with ease and respond promptly to enquiries.  In the case of electronic information, a logical hierarchical structure of folders and sub-folders should be used to ensure that documentation relating to a particular category and year can be readily identified.

Any records of a confidential nature (eg Disclosure and Barring Service forms) must be kept securely, and access only granted to authorised staff.  In addition, it is advisable to reserve the immediate office space for paper records that are consulted frequently and therefore need to be close at hand; while documents that will be required for several years, but rarely consulted, can be housed separately.

1.4 Formats

A recommendation has been given concerning the format in which each category should be held:

a) P = paper; eg files, folders, forms
b) E = electronic: eg word processed documents, spreadsheets, databases, emails, scanned images, web and multimedia documents

 It is important to ensure that any records held electronically remain accessible and do not become trapped in obsolete technology.  Faculties/Services should review their data periodically (ideally every five years) and, if necessary, arrange for it to be converted to new file formats.  There is always a risk of portable media (eg USB memory sticks, CDs, DVDs) degrading or becoming corrupted; all critical, long-term data must therefore be held on a central server, so that it will be adequately backed up and safeguarded from hardware and software failure.

A number of the categories listed in this Policy are likely to include related emails (eg student files, complaints, External Examiners’ records).  A decision should be made whether to print these messages and place them with the relevant records or simply retain them electronically.  If they are to be held in digital form, their management must be linked to the related paper files (eg when the files are destroyed, the accompanying emails should similarly be deleted).

1.5 Destruction of records

File covers or storage boxes should be labelled with disposal actions (eg destroy on 1 August 2017) to help staff to identify records that are no longer required, and time must be set aside at least once a year for discarding redundant material.  Before any items are discarded, however, an appropriate person should authorise the destruction.  When permission is given, all copies (both paper and electronic versions, including those held on portable media or laptops) must be eliminated, otherwise the information will be considered still held by the University and therefore accessible under the terms of Data Protection and Freedom of Information legislation.  Any documents of a restricted or sensitive nature must be discarded in a confidential manner, and kept secure whilst awaiting destruction.

If there is any doubt concerning the destruction (because of, for example, pending litigation or investigation), the material must be retained and reviewed at a later date; a specific date for the review should be agreed and recorded.  Similarly, if the records are known to be the subject of a request under Data Protection or Freedom of Information, destruction must be delayed.  The Information Commissioner’s Office recommends postponing the disposal of material requested under Freedom of Information for at least six months from the date of the last communication concerning the request.

2. Retention periods

 

2.1 Admission records

Admission records - eg application forms, references, transcripts of entry qualifications, copies of certificates, offer letters complete with any conditions of offer and scholarship details for PhD applicants, responses, visa letters (Confirmation of Acceptance for Studies).

Minimum retention period Format Reasons and further details
Applicants who are offered a place, accept and enrol:  Retain for 6 years after graduation or withdrawal (within individual student files). P/E To ensure information is available in case of enquiries, audits, disputes or litigation; to coincide with the limitation period set by the Limitation Act 1980; JISC recommendation; Data Protection Act 1998; common practice within higher education

Applicants who are not offered a place or offered a place, but do not attend:

  Retain current academic year + 1 year 

P/E 

Eg applicants who withdraw, decline, fail to meet the entry requirements, fail to enrol.

To ensure information is available in case of enquiries, audits, disputes or litigation.  Time limits for legal actions by applicants are specified by the Employment and Training Regulations S.I. 2003/1660, S.I. 2003/1661, S.I. 2006/2930, JISC recommendation; Data Protection Act 1998.

 


 

2.2 Tier 4: Points based immigration system

The University is required to keep certain records for all its non-European students in order to comply with the points based immigration system: these include a copy of each student’s passport, contact details and records or absence.

Minimum retention period FormatReasons and further details
Copy of passport or immigration status document:  Retain for 6 years after graduation or withdrawal. P/E 

To ensure information is available in case of enquiries, audits and disputes; UKVI’s sponsorship guidance – please check the website for the latest information www.ukvi.homeoffice.gov.uk

Responsibility for retention: International Student Support (ISS). Copies of passports of all non-European students will be held centrally by ISS.

Contact details: Retain for 1 year after graduation or withdrawal. E 

To ensure information is available in case of enquiries, audits and disputes. 

Contact details must be updated regularly and a history of past details maintained.

Records of absence or attendance:   Retain for 1 year after graduation or withdrawal. P/E To ensure the attendance of overseas students can be monitored effectively.

2.3 Recognition of Prior Learning

Minimum retention period FormatReasons and further details
Claim forms, assessments, evidence:

Either retain for 1 year after graduation or withdrawal, if held separately from student files.

Or retain for 6 years after graduation or withdrawal, if held within student files.

  P

To ensure information is available in the event of a dispute or complaint; to provide evidence to External Examiners and auditors, as well as internal reviews.

Student files are retained for 6 years to ensure information is available in case of enquiries, disputes or litigation (see 2.26).

Samples of claims, evidence and assessments: Retain current academic year + 3 years.  P To provide evidence for External Examiners and auditors, as well as internal reviews.
Summary records of claims and decisions:  Retain current academic year + 6 years. P To provide evidence for External Examiners and auditors; and to monitor APL process.
 

2.4 Disclosure and Barring Service (DBS) records

Eg signed disclosure application forms, clearance forms, disclosure forms, accompanying correspondence

 DBS records must be managed in compliance with the DBS’ Code of Practice for Registered Bodies.  All documentation must be held within secure, locked cabinets (or password-protected databases), and access restricted to a minimum number of authorised users.  The information must only be used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.

The retention periods listed below are mandatory: when the relevant retention period elapses the documents must be shredded immediately.

Minimum retention periodFormat Reasons and further details
Signed disclosure application forms (copies): Retain until clearance form is received from DBS.  P Copy is not required once clearance form has been received; DBS Code of Practice for Registered Bodies; Data Protection Act 1998.
Clearance and disclosure forms: disclosure is clear  Retain clearance form until disclosure is received from DBS and checked; then discard both clearance and disclosure forms.  P DBS Code of Practice for Registered Bodies; Data Protection Act 1998.
Clearance and disclosure forms; disclosure matches details in student’s application form  Retain clearance and disclosure forms until confirmation is received that details have been considered by the University.  P DBS Code of Practice for Registered Bodies; Data Protection Act 1998.
Clearance and disclosure forms; disclosure does not match details in student’s application form  Retain clearance and disclosure forms (and associated correspondence) for no longer than 6 months after date of decision or resolution of any dispute about accuracy of disclosure information.  P DBS Code of Practice for Registered Bodies; Data Protection Act 1998.
Summary records: eg unique DBS reference number, date of issue of disclosure, name of student, student number, type of disclosure, course for which it was requested, details of decision taken; disposal date of disclosure certificate.

Retain for 6 years after graduation or withdrawal.

  P/E   DBS Code of Practice for Registered Bodies.

2.5 Assessments

Eg coursework assignments, examination question papers, marking criteria, marking schemes, model answers, submission deadlines.

These records may be stored as paper copies within module files or held electronically.  If they are stored in electronic format, a note of their location should be made within the relevant module file so that they can be readily located.

Minimum retention period  FormatReasons and further details
Retain current academic year + 3 years unless professional bodies require a longer retention period. P/E To ensure information is available for internal and external audits/reviews.

2.6 Assessed work - coursework

Including major/final year projects and dissertations.

 All assessed work is legally the property of the University.  Faculties should ensure that coursework is held long enough to allow students a reasonable opportunity to collect it, and they should inform students that there will be a time limit for retrieving their work, after which it will be confidentially destroyed.  The retention period for coursework must be extended appropriately in the case of students who are likely to have difficulty in reclaiming their work on time (eg students who are on placements or abroad for a year).
 

 

 Minimum retention period  Format Reasons and further details

If uncollected, retain for 6 months after confirmation of results by Award Board.

In the event of an appeal/complaint, the work (or a copy) should be retained until all appeal/complaint procedures (both internal and external) have been exhausted.

 P/E 

To allow students a reasonable opportunity to reclaim their work; to ensure the work is available in the event of an appeal or dispute; JISC recommendations.

2.7 Assessed work – examination scripts

Examination scripts must be held long enough to allow time for students to raise appeals or complaints.  They must also be retained for a sufficient period to allow students the opportunity to view their work, if they wish to do so; retention periods must be adequately publicised, so that students are made aware of the time limit for requesting access to their work.

 Minimum retention period Format Reasons and further details
Retain for 6 months after confirmation of results by Award Board.  P/E To ensure work is available in the event of an appeal or dispute; to ensure students have a reasonable opportunity to request access to their work; JISC recommendation.

2.8 Assessed work – samples

Eg samples of coursework, major/final year projects, examination scripts, as well as accompanying feedback.

  Minimum retention period  Format  Reasons and further details
Retain for current academic year + 3 years unless professional requirements specify a longer retention period. P/E To meet requirements of External Examiners, as well as internal and external audits/reviews.

If samples need to be retained longer than three years to meet professional requirements, the related assessments (eg examination question papers, assignments – see section 2.5) must be held for the same length of time.

 

2.9 Registers recording the submission of coursework


 Minimum retention period Format  Reasons and further details
Retain for 6 months after confirmation of results by Award Board.   P/E To ensure information is available in the event of a query or dispute; to ensure the submission of work is monitored effectively.

2.10 Examination administrative records

Eg examination timetables, attendance records, appointments of invigilators, invigilation reports (if held). 
 
 Minimum retention periodFormat Reasons and further details
Retain current academic year + 1 year.P/E To ensure information is available in the event of a query or dispute; JISC recommendation.

2.11 Feedback issued to students

 

 Minimum retention period  Format Reasons and further details
Group/generic feedback per cohort:   Retain current academic year + 3 years.  P/E To ensure information is available for audits/reviews, as well as disputes and complaints.
Individual feedback:

If uncollected, retain for 6 months after confirmation of results by Award Board.

In the event of an appeal/dispute, copies of feedback should be retained for 6 years after last action on case. 

   P/E

 To ensure information is available in the event of an appeal or dispute.

To ensure information is available in the event of litigation; to coincide with the limitation period set by the Limitation Act 1980; JISC recommendation.

2.12 Students’ marks

Unconfirmed marks (ie original paperwork recording marks provided by tutors, which are submitted to Assessment Boards) and confirmed marks (ie marks/results confirmed by Assessment and Award Boards, and input into the student records system).

 Minimum retention period   Format Reasons and further details

Unconfirmed marks: 

Retain for 1 month after Re-sit Board.

   P/E To ensure paperwork is available in case of queries and academic appeals.
Confirmed marks:  Retain permanently.   P/ETo provide transcript data for students (see 2.25).

 

  

2.13 Assessment Boards

The minutes (including the accompanying mark sheets) of Assessment Boards should be required no longer than six years, provided that all marks have been input into the student records system.

Minimum retention periodFormat Reasons and further details
Assessment Board minutes:  Retain current academic year + 6 years.  P/E  To ensure information is available in the event of a dispute or complaint; JISC recommendation; Limitation Act 1980.


2.14 Award Boards

The minutes of Award Boards should be required for no longer than six years, provided that all results have been input into the student records system.

Minimum retention period  FormatReasons and further details
Award Board minutes:  Retain current academic year + 6 years. P/E To ensure information is available in the event of a dispute or complaint; JISC recommendation; Limitation Act 1980.

2.15 Extenuating circumstances

Eg forms, evidence, minutes of panels.

Some forms and evidence may contain sensitive personal data (eg medical information) and in these cases access must be restricted.  If the items are held within individual student files, they should be placed within sealed envelopes to ensure confidentiality; if they are held separately from the files; they must be kept in a secure location.

Minimum retention period Format 
Reasons and further details
Minutes: Retain current academic year + 6 years.  P/E JISC recommendation; Limitation Act 1980; Data Protection Act.
Forms and evidence:  Retain current academic year + 6 years.   P

 JISC recommendation; Limitation Act 1980; Data Protection Act 1998.

2.16 Academic appeals

Eg reports, evidence, correspondence.

Minimum retention period Format Reasons and further details
Retain for 6 years after last action on case.   P To ensure information is available in case of litigation; to coincide with the limitation period set by the Limitation Act 1980; Data Protection Act 1998; JISC recommendation.


2.17 Complaints

Eg reports, evidence, correspondence.

Minimum retention period Format Reasons and further details
Retain for 6 years after last action on case.  PTo ensure information is available in case of litigation; to coincide with the limitation period set by the Limitation Act 1980; Data Protection Act 1998; JISC recommendation.

2.18 Disciplinary cases

Eg reports, evidence, correspondence.

Minimum retention period Format Reasons and further details
Retain for 6 years after last action on case. P  To ensure information is available in case of litigation; to coincide with the limitation period set by the Limitation Act 1980; Data Protection Act 1998; JISC recommendation.

  

2.19 Attendance registers

For guidance on the record-keeping requirements for non-European students, please see section 2.2.  The following only applies to recording the attendance of Home and European students, including where required to monitor attendance by an external regulatory body.

Minimum retention period Format Reasons and further details

Home and EU students:

Retain current academic year + 6 months; or retain until graduation/withdrawal, if a regulatory body requires attendance to be monitored throughout a programme.

   P/E To ensure information is available in the event of a query or dispute; to ensure Faculties can confirm whether a student has a satisfactory attendance record.

2.20 Personal Development Planning records

Eg individual learning profiles, action plans and review forms.

 

Minimum retention period Format Reasons and further details
Retain for 6 years after graduation or withdrawal.  P/E To ensure data is available for providing references; Data Protection Act 1998.


 

2.21 Tutorial records

It is advisable for tutors to retain records of significant meetings with students in order to preserve an audit trail and ensure evidence is available in the event of a dispute.  Any documentation that is held by personal tutors should be maintained in line with the requirements of the Personal Tutor Handbook.  Following the graduation or withdrawal of students, tutors should review their records and transfer all items they consider to be important to the student files; any redundant material must be confidentially destroyed.  Amalgamating tutorial records with student files will ensure that information relating to past students is readily available within a single location and can be managed consistently.

Minimum retention period Format 
Reasons and further details
Retain for 6 years after graduation or withdrawal. P/E To ensure information is available in the event of a dispute or complaint; to coincide with the limitation period set by the Limitation Act 1980; Data Protection Act 1998; JISC recommendation.

2.22 Supervision records

To document the amount of supervision given in relation to major pieces of assessed coursework (such as projects and dissertations).  Recording the dates and outcomes of discussions is essential to ensure that evidence is available in the event of a dispute.

Minimum retention period Format Reasons and further details
Retain for 6 years after graduation or withdrawal.  P/E To ensure information is available in the event of a dispute or complaint; to coincide with the limitation period set by the Limitation Act 1980; Data Protection Act 1998; JISC recommendation.
 

2.23 Placement and training records

Eg records of individual students (such as application forms, reviews, assessments, reports), guidance issued to students (such as health and safety information, placement handbooks), documentation relating to placement providers or trainers (such as health and safety checklists, risk assessments, placement agreements).

Minimum retention period FormatReasons and further details

Placement and training records of individual students:

Retain for 6 years after graduation or withdrawal.

 P/E To ensure information is available in case of enquiries, requests for references, disputes or litigation; to coincide with the limitation period set by the Limitation Act 1980; Data Protection Act 1998.
Summary data of individual students: Retain permanently. P/E Eg dates of placement/training, name and address of employer/trainer, summary of work undertaken.

Generic guidance issued to students:

Retain for 6 years after superseded.

 P/E 

Eg placement handbooks, health and safety guidance.

To ensure information is available in case of disputes, insurance claims or litigation; to coincide with the limitation period set by the Limitation Act 1980.

Risk assessments, and Health and Safety checklists:  Retain for 6 years after superseded or 6 years after completion of placement/training (if held).   P To ensure information is available in case of disputes, insurance claims or litigation; to coincide with the limitation period set by the Limitation Ac t 1980.

Placement agreements:

Retain for 6 years after completion of placement/training. 

  P To ensure information is available in case of disputes, insurance claims or litigation; to coincide with the limitation period set by the Limitation Ac t 1980.

2.24 Fitness to practise records

Documents concerning the ‘fitness to practise’ of students who are registered on programmes leading to professional qualifications or entry into professions (eg teaching, health, social work).

Minimum retention period Format Reasons and further details
Retain for 6 years after graduation or withdrawal.  P To ensure information is available in case of enquiries, requests for references, disputes or litigation; to coincide with the limitation period set by the Limitation Act 1980; Data Protection Act 1998; JISC recommendation.
 

2.25 Student transcript data

Eg name, date of birth, student number, title of qualification, award classification, details of units, marks/credits/results, dates of attendance.

Minimum retention period  Format Reasons and further details
Confirmation of awards:  Retain permanently.   P/ETo confirm award/attendance and prevent fraudulent claims.
Transcript data:   Retain permanently.   P/E 

To supply transcripts (see also 2.30 and 2.32); QAA Guidelines for HE Progress Files.

 

 

2.26 Ethics

Minimum retention periodFormat Reasons and further details
Claim forms, rapporteurs statements,

Either retain for 1 year after graduation or withdrawal, if held separately from student files.

Or retain for 6 years after graduation or withdrawal, if held within student files.

 P/E

 To ensure information is available in the event of a dispute or complaint; to provide evidence to External Examiners and auditors, as well as internal reviews.

Student files are retained for 6 years to ensure information is available in case of enquiries, disputes or litigation (see 2.26).

Samples of applications:

Retain current academic year + 3 years. 

 P/E To provide evidence for External Examiners and auditors, as well as internal reviews.

Summary records of applications and decisions:

Retain current academic year + 6 years.

 P/E 

To provide evidence for External Examiners and auditors; and to monitor APL process.

 

2.27 Research student data

Eg Early Stage Review Report, Late Stage Review Report, annual progress review reports, applications for transfer from MPhil to PhD and intention to submit thesis notifications.

Minimum retention period Format Reasons and further details
Retain current academic year + 6 years.  P/E To ensure information is available in the event of a dispute or complaint; JISC recommendation; Limitation Act 1980.

Equality issues have been taken into account during the development of this policy and all protected characteristics have been considered as part of the Equality Analysis undertaken.