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Retention of Records Policy

Retention of Documents Policy

1.1  Executive Summary

This Policy sets out retention periods for a range of records.  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 (i.e. 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 Schools and Services to retain the items listed in this document.  All Schools and Services will have designated staff who have responsibility for the oversight of records retention and the application of this policy at a local level.

1.2  Introduction

This Policy sets out in the table below the retention periods for a range of records whether they are paper records or electronic.  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.

1.3  Retention requirements

In exceptional cases, the retention periods, i.e. the length of time for which each category is to be retained, may be lengthened but will not be shortened.  When determining whether to lengthen a retention period, there will be a need to balance a number of factors, including:


   1.3.1  Limitation Act 1980

Students and staff have a contractual relationship with the University.  Various documents define the terms of the contract (e.g. student handbooks, contracts of employment, 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 on the termination of staff employment) in case they are required for evidential purposes.

   1.3.2 General Data Protection Regulation

The Data Protection principles stipulate that personal data must only be used for the purposes for which it was lawfully 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) and a record kept of the justification in each case.


   1.3.3 Professional, statutory and regulatory bodies

Where Schools 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.

   1.3.4 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, Schools/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 (e.g. 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.

   1.3.5 Cost

 The resource implications of holding records should be considered: e.g. 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).
 

2 Data Protection and Freedom of Information

1.1 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 General Data Protection Regulation 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 one month.  The law 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.


2.2  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 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.

2.3  Action to be Taken

When the stipulated retention period expires, the Custodian will determine whether there is any legitimate basis for further retention of the relevant record(s). If there is no such basis, the record(s) will be destroyed. If there is a legitimate basis for ongoing retention, then the Custodian must record the justification for ongoing retention and must specify a new review date for that retention.

 

2 Table of Retention

INFORMATION STORED TIMESCALE FOR RETENTION   OWNER Data Classification
STUDENT RECORDS
Enquirer data (e.g. telephone enquiries from non- applicants, open day bookings, prospectus requests) 1 Year after the enquirer’s proposed start date SRA  
 Student application records which can include references, transcripts of entry qualifications, codes of certificates, offer letters complete with any conditions of offer and scholarships for PhD applicants, responses, visa letters and confirmation of acceptance for studies.

Applicants who are offered a place, accept and enroll: 6 years

Applicants who start the application form but do not submit: current academic year + 1 year

Applicants who are not offered a place, or who are offered a place but do not attend: current academic year + 1 year

SRA  
Student File – (including Enrolment data, general correspondence, any document pertaining to a student, student references and other misc. student details) 6 Years after the year of graduation or date of leaving if earlier. SaAS  
Student Loan applications 1 year from enrolment  SaAS  
Conferment/Pass lists 100 years SaAS  
Hardship Fund Applications 6 years   SaAS  
Student transcripts 100 years SaAS  
Placement details – managed across the Institution – lead should be with employer partnerships  6 Years after the year of graduation or date of leaving if earlier Employer Partnerships  
Placement results  100 years  SaAS  
Recognition of prior learning
Claim forms, assessment and evidence
Sample of claims and evidence
Summary records of claims and decisions
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.
Retain current academic year + 3 years.
Retain current academic year + 6 years.
 SaAS  
Disclosure and Barring Service
Signed disclosure application forms (copies): 
Self-declaration form: disclosure is clear 
Self-declaration form and DBS certificate; disclosure matches details in student’s application form 
Self-declaration and DBS certificate; disclosure does not match details in student’s application form 
Summary records: e.g. 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 until clearance form is sent received
Retain self-declaration form until disclosure is received from DBS and checked; then discard both self-declaration and DBS certificate.
Retain self-declaration and DBS certificate until confirmation is received that details have been considered by the University.
Retain self-declaration and DBS certificate (and associated correspondence) for no longer than 6 months after date of decision or resolution of any dispute about accuracy of disclosure information.
6 Years after the year of graduation or date of leaving if earlier
ARC


ARC


ARC


ARC


 
ARC

 
 Attendance Sign in sheets  Retain current academic year + 6 months or retain until graduation/withdrawal if a regulatory body requires attendance to be monitored throughout a programme   SaAS   
Disabled Student Support Archive
Student and support worker records
 6 years  SaAS  
 Student Complaints   6 years after last action on case  SaAS  
 Student Appeals  6 years after last action on case  SaAS  
 Extenuating Circumstances – applications  6 years after last action on case  ARC   
Student Disciplinary cases  6 years after last action on case   ARC   
 Fitness to practice records  Retain for 6 years after graduation or withdrawal   ARC   
  Audit files - Completed and withdrawn students   6 years    SaAS  
 Visa and passport copies - for Student visa holders a copy of each student’s passport, contact details and records or absence. Either
  • 1 year from the date the University ends its sponsorship of the Student visa holder;
or
  • if the Student visa holder is no longer sponsored by the University, the point at which a compliance officer has examined and approved them
International Office   
  Case Notes – records of student interactions   6 years   SaAS   
 Audit files – extra information to support student files  6 years  SaAS   
 OIA Cases   6 years after last action on case SaAS  
 Legal Files  6 years after last action on case    SaAS  
 STAFF RECORDS
Employee personal files including;
  • New Employee Documentation
  • Contract of Employment
  • Changes after Appointment
  • Job Descriptions
  • Pension Information
  • Clearances
  • Performance and Development Review records
  • Sickness Cautions
  • Investigation and casework outcome letters
6 years from the date of termination HR&OD  
Recruitment documentation (all applicants)  6 months from the date the job is closed  HR&OD  
Investigation and casework documentation (excluding the official letter confirming the outcome of such activities)  2 years after the date the case is closed  HR&OD  
Non-staff records e.g. Specialist/Guest Lecturers, External Examiners, Visitors, Service Users and Carers etc. 3 years after the date of termination  HR&OD  
 Payroll Records 4 years from the date of termination  HR&OD  
 HEALTH AND SAFETY
Accidents Adults – 8 years
Minors – 8 years from 18th birthday 
  HEALTH AND SAFETY  
Surveillance Reports for hazardous materials (e.g. asbestos)  30 years  ESTATES  
Occupational Health Records  30 years   HR  
Health and Safety Training Records   8 years  HR   
COMMITTEE PAPERS AND MINUTES
Academic Board Indefinitely SaAS  
Sub-Committees of Academic Board Indefinitely QES/RIIS  
School Academic Committee 5 years QES  
Course Committee 5 years SaAS  
 ASSESSMENT
Assessment Task - E.g. assessment briefs, examination question papers, marking criteria, marking schemes, model answers, submission deadlines. Retain current academic year + 3 years unless professional bodies require a longer retention period.  SCHOOL  
Moderated sample of assessed work Retain for current academic year + 3 years unless professional requirements specify a longer retention period.   SaAS  
Assessed Work – Coursework not included in moderated sample (see above)

 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.

   
Examination Administrative Record - E.g. examination timetables, attendance records, appointments of invigilators, invigilation reports (if held).

Retain current academic year + 1 year.

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.

   
Assessed Work - Examination scripts not included in moderated sample (see above). Retain for 6 months after confirmation of results by Award Board. SaAS  
Student Marks

 Unconfirmed marks – retain for one month after board

Confirmed marks – retain permanently

SaAS

SaAS

 
Assessment Boards Minutes Retain current academic year + 6 years  SaAS  
Award Board minutes Retain current academic year + 6 years  SaAS  
 RESEARCH RELATED DOCUMENTS
Research Data  At least ten years from the date of publication which is based upon it.   RIIS  
Research Degree Thesis  At least ten years from the date of publication which is based upon it   RIIS  
 Ethics Either retain for 1 year after graduation or withdrawal if held separately from student file or re or retain for 6 years after graduation or withdrawal if held within student files.    RIIS  
COURSE APPROVAL AND MONITORING
Course approval documentation  7 years  QES  
Course approval reports Indefinitely  QES  
Annual monitoring reports  7 years  QES  
Periodic review documentation  7 years   QES  
Periodic review reports Indefinitely QES  
COURSE DOCUMENTATION
Programme Specifications Indefinitely QES  
Course handbooks Indefinitely QES  
Module handbooks Indefinitely QES  
COLLABORATIVE ACADEMIC PARTNERSHIPS
Collaborative agreements Indefinitely CAP  
Course Manager Reports  7 years QES  
 Link Tutor reports 7 years  QES  
 Partnership review documentation 7 years QES  
 Partnership review reports Indefinitely  QES  
 EXTERNAL EXAMINER INFORMATION
External Examiner File (e.g. Nomination forms, correspondence)  5 years after expiry of tenure  QES  
External examiner reports  7 years  QES  
 FINANCIAL RECORDS
Annual Account papers  Indefinitely  FINANCE  
HESA Returns  Indefinitely  FINANCE  
VAT Schedules  Indefinitely  FINANCE  
Purchase invoices  6 years  FINANCE  
Manual cheques  6 years  FINANCE  
Foreign payments  6 years  FINANCE  
Sales invoice requests  6 years  FINANCE  
Travel Claims  3 years   FINANCE  
 Internal purchase requisitions  3 years  FINANCE  
 Hospitality forms  3 years  FINANCE  
 Journal vouchers  3 years  FINANCE  
 Accommodation Agreements  3 years  FINANCE  

 

EUROPEAN UNION/EUROPEAN COMMISSION FUNDED PROJECTS TIMESCALE FOR RETENTION ACTION OWNER

General:
Tender specification 
Original bids 
Contracts and any variations
Any associated sub contracts or lease agreements
Output definitions and evidence required (evidence of agreement with funder) Job adverts for project team
Job descriptions
Project management procedures
Index of records SMT actions relating to project management Copies of blank forms used for evidence collation
Organisational structure demonstrating where project fits in organisation along with detailed local management structure
Correspondence with funders


Financial
Invoices 
Purchase orders 
Claims Expenses 
Staff timesheets
Hourly rate calculations

Marketing: 
Marketing plan 
Publicity materials 
Publicity procedures 
Events – delegate list, materials, feedback etc. 
Project contacts database  

Meetings and team file: 
Minutes of steering group 
Minutes from team meetings 
Minutes from individual line management meetings 
Minutes from internal meetings e.g. with finance 
Any actions from SMT meetings relating to the project 
Minutes from external meetings 
Copies of staff appraisals and training plan relevant to the performance of the project 

Output evidence: 
All beneficiary and output associated documentation e.g. beneficiary details and eligibility, timesheets, TNAs, etc.
Meetings and team file: Minutes of steering group Minutes from team meetings
Minutes from individual line management meetings Minutes from internal meetings e.g. with finance
Any actions from SMT meetings relating to the project Minutes from external meetings
Copies of staff appraisals and training plan relevant to the performance of the project

European Social Funded projects 2000-2006 programme Authorisation required from the contracting body (Government Office) be sought and Employer Partnerships/RIIS notified before documentation can be destroyed.

European Regional Development Fund 2007- 2013 programme
Until at least 3 years beyond the closure of the programme or 31 December 2025, whichever is later. After this date authorisation from the contracting body (DCLG) and Employer Partnerships/RIIS notified before documentation can be destroyed.


European Social Fund\European Regional Development Fund 2014-2020
The grant recipient will be informed of the retention period at the end of the project. The period is dependent on the date at which the final claim is submitted to the Managing Authority so the retention period would be unique to each project and this period cannot be specified at the outset. Seek confirmation from the Lead Partner or Managing Authority. 
 
Other European Union/European Commission funded projects
Retain as per individual contractual guidelines. Employer Partnerships/RIIS notified before documentation can be destroyed.


Minimum of seven years after closure. 

Review/ Destroy

Employer Partnerships /RIIS