University Secretary
Retention Schedules
For guidance on retention schedules, either download the factsheet or select one of the options below.
- What is a retention schedule?
- Why are retention schedules required?
- What factors should be considered?
- How to draft a retention schedule
- How to implement a retention schedule
- Reviewing retention schedules
- Retention schedule for financial and staff records
- Retention schedule for minutes and policies
- Retention policy for student and course records
1. What is a retention schedule?
A retention schedule lists the length of time for which categories or series of records should be retained in order to comply with legal and regulatory requirements, as well as to meet operational and business needs. It applies to all records in whatever medium they are held (i.e.paper or electronic).
2. Why are retention schedules required?
Retention schedules are central to organisational efficiency and achieving legal and regulatory compliance. They
- prevent records from being discarded prematurely;
- ensure that information is not kept unnecessarily;
- provide a consistent, controlled system for the disposal of material;
- can help to save space, time and money.
The Data Protection Act requires that personal data is protected from unauthorised destruction, and the fifth protection principle stipulates that personal data processed for any purpose or purposes shall not be kept for longer than is necessary. Assigning retention periods to records is therefore a critical part of ensuring that the Act is not breached.
The Lord Chancellor's Code of Practice on the Management of Records (issued under section 46 of the Freedom of Information Act) states: It is particularly important under FOI that the disposal of records is undertaken in accordance with clearly established policies which have been formally adopted by authorities and which are enforced by properly authorised staff. In addition, under section 77 of the Act it is an offence to destroy any document held by a public body to prevent disclosure of information. It is therefore essential that departments use coherent, clearly defined procedures for discarding records, so that they can demonstrate that their information has been destroyed legitimately - not to prevent disclosure.
3. What factors should be considered?
When deciding for how long particular categories of records should be kept, the following factors should be considered:
| 1. | Operational and business requirements | |
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Are the records still needed to carry out the work of the department or has their operational purpose come to an end? |
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| 2. | Legal and regulatory requirements | |
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Are there legal or regulatory reasons for retaining the records? (e.g. the VAT Act 1994 requires certain financial records to be retained for up to 7 years.) Are there any standards or codes of practice issued by professional bodies that specify retention periods? (e.g. Chartered Institute of Personnel and Development: Retention of Personnel and other related records December 2006) |
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| 3. | Accountability and transparency | |
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Are the records required to demonstrate accountability and transparency? Do they preserve an audit trail that is still required? (e.g. records concerning a complaint) |
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| 4. | Long-term reference or evidential value | |
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Some documents may have outlived their original administrative purpose, but still have long-term reference or evidential value. Do they create a precedent or describe how to deal with a particular situation that is likely to occur again? |
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| 5. | Data Protection Act 1998 | |
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The fifth data protection principle states personal data processed for any purpose or purposes shall not be kept for longer than is necessary'. Do the records contain personal data and have they served the purpose for which they were created. |
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| 6. | Duplication | |
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Are these records the definitive versions/originals or simply copies of information held by another department (or another organisation)? Duplicates can usually be retained for a shorter period than originals. |
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| 7. | Relationship with other records | |
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Are the records needed in order to understand or use other records? If so, the retention periods of all sets of related data should be co-ordinated. |
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| 8. | Level of use | |
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Have the records been consulted during the past 5 years? Monitoring the use of records will assist retention decisions. |
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| 9. | Cost | |
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What is the cost of retaining the records? (e.g. costs of storage, maintenance, and responding to Data Protection and Freedom of Information requests) Can the cost be justified? |
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| 10. | Risk | |
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What would the consequences be if these records were to be discarded? Would there be any legal or financial implications? Ultimately retention decisions are based on an analysis of reasonable risk. |
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4. How to draft a retention schedule
A retention schedule should record:
- the major categories of records held by a department;
- their retention periods (e.g. 1 year, 6 years, permanent);
- when the retention period begins (e.g. the end of the academic year, the expiry of the contract).
It should be approved by an appropriate member of staff (e.g. the Head of Department), and signed and dated.
5. How to implement a retention schedule
Responsibility for implementing the schedule should be assigned to specific individuals. They will need to ensure the department's records are arranged logically, so that it will be possible to locate with ease material that is due for destruction. In addition, file covers and storage boxes should be labelled with disposal dates to help staff to identify redundant information.
6. Reviewing retention schedules
Retention schedules must be flexible. They should be reviewed at regular intervals to accommodate either new categories of records or new legislation affecting retention requirements.
7. Retention schedule for financial and staff records
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Retention Schedule: Financial and Staff Records [Acrobat (.pdf) - 126 KB Thu, 21 Sep 2006 09:32:00 BST] |
8. Retention Schedule for minutes and policies
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Retention Schedule: Minutes and Policies [Acrobat (.pdf) - 143 KB Thu, 05 Feb 2009 10:10:00 GMT] |
9. Retention policy for student and course records
The Retention Policy sets out minimum retention periods for a range of student and course records: ie. the length of time for which each category is to be retained may therefore be lengthened, but must not be shortened. The policy should be used as a basis for developing a departmental retention schedule (see example).