A Records Retention Schedule (RRS) documents the length of time University records should be retained in order to comply with legal or regulatory requirements and our operational needs. It is an important element in effective records management.
It supports our policy on retention of our records here, and helps establish consistent practice across the organisation. The schedules ensure business records are kept for as long as they are needed (accounting for effective operations, legislative compliance, regulatory compliance, demonstrable accountability). They are also kept only for as long as they are needed (and not longer), so storage space (both physical and virtual/electronic) is used effectively.
This RRS is based upon a generic schedule developed by JISC and published on the web at http://bcs.jiscinfonet.ac.uk/he/. It is divided into ARU business areas and within each business area, a number of record types are described.
The retention periods specified in each specific Service Area are the maximum recommended periods for particular record types, and are based on relevant legislative requirements, common practice in the Higher Education sector or our own identified need. Under certain circumstances, longer periods may apply to certain groups of records, such as where the records are subject to a Freedom of Information request, an ongoing complaint, court action, an audit or extenuating business requirements. There may also be situations where records are subject to external temporary regulatory requirements determining a different (longer or shorter) retention period. We must also note that any records that are identified as CAY (Current Academic Year) refers to the last academic year in question for the record. An example of this would be CAY for a student would be the last academic year of their studies.
Our Records Retention Schedules are living documents and subject to change and revision as determined by University structures and organisation, operations and external influences such as legislation revisions and guidance on best practice.
A number of our systems currently have limited capability to delete records or anonymise the content. The University is currently engaged in initiatives to improve this functionality either by requiring the supplier to develop the necessary changes and we are therefore waiting for this to be delivered, developing our own bespoke solution and managing the project to deliver this, or reviewing alternative systems to replace existing ones. The entries on our retention schedule where data is held in these systems is therefore a statement of our intention to manage personal data to the stated timescales once the functionality is available to us. In the meantime, where data may be held beyond a retention period, the University will have safeguards in place to ensure that it is not processed in a manner which impacts adversely on data subjects.
We have issued guidance notes on the Retention Schedule, which can be found here.