UNIVERSITY OF EXETER
Student Files – Retention of Historical and Current Student Records
1. Introduction
1.1
This consultation document addresses two issues regarding student records, firstly it looks
at the retention of historical student records held across the University, whether these records are
necessary and who has responsibility for retaining them. It then looks to the future and proposes a
retention schedule to ensure that future responsibilities and requirements are clear and coherent.
2. Background
When discussing student records the following four areas should be considered
2.1
Operational requirements:
o Storing historical files take up costly space both physical and virtual.
o Some student files held in Schools date back several decades there may be archival
value to these records.
2.2
Legal requirements
o The Data Protection Act 1998 states that personal data “shall not be kept for longer than
is necessary.” This means that student files cannot be held indefinitely and the University
should have systems in place to ensure that information is destroyed when it is no longer
necessary.
o The Limitation Act 1980 sets out general time limits for bringing legal action. The time limit
for action related to breach of contract in 6 years, this provides a basis on which to
develop retention periods for student records.
2.3
Needs and expectations of students/alumni
o The principal argument for retaining detailed student files is to provide references. It is
general policy to provide references and this is a service that students expect. However, it
is reasonable to expect that after a certain number of years a reference provided by a
University would only confirm qualifications and basic information. This type of information
is generally held centrally and would enable a factual reference or transcript to be
provided.
o Individuals have the right to access personal information held about them including
information held in student files.
2.4
Core record
o A core record for each student who attended the University should be retained
permanently, this will provide information required to provide references and help ensure
the preservation of a part of the university’s history.
o This core record should contain key information about a student’s personal, progression
and transcript details. See Annex A for a list of items recommended to be part of the core
records.
o Going forward this information is contained within SITS and whilst some of the information
in SITS may be deleted at various points this information should be retained permanently
and protected should SITS be replaced in the future.
3. Current Situation
3.1
Currently student records are held in Academic Schools and centrally by Registry Services.
Registry Services retain all records held permanently whilst there are varying practices across
Schools regarding what information is held and for how long. Practices vary from holding records
indefinitely to destroying all paper files 6 years after graduation. General guidance already exists
suggesting that most information can be destroyed six years after a student graduates however
this has not been treated as a formal policy or expectation therefore there is a lack of consistency.
3.2
Some information held on Student files in Schools, will also be held electronically on SITS
or in Registry Services.
3.3
SITS was introduced fully in 2002 holding key student data, Registry Services also maintain
an ‘electronic student file’ (WINDIP) holding scanned images of key documents. Prior to SITS
information was held on Monarch and microfiche, these records date from 1893 and are generally
sufficient to confirm awards. The completeness of records cannot be guaranteed, and it is known
that some central records were lost in a fire during the war. There is no record of what was
destroyed or whether duplicates exist in Schools.
3.4
Sample student files from several departments have been previously compared to the files
held by Registry Services. School files were found to contain more documents then the central
records (e.g. copies of references provided, correspondence etc), however central records
generally contained enough information to be able to confirm the award and provide a factual
reference for all the students in the sample. There were some gaps in centrally held records where
in several cases there was no record of the student.
3.5
There is no appraisal of student records for archival value.
4. Historical records
4.1
It is recommended that the current guidance which suggests that School files can be
disposed of 6 years after graduation becomes University policy. This is in line with guidance
provided by JISC (Joint Information Systems Committee).1 This would balance the risks of
retaining some information (medical notes etc) being held for longer than required with the risk of
destroying information which is later identified as useful.
4.2
Where departments are holding all student records indefinitely this is clearly a breach of the
data protection act and should be stopped, it is acknowledged that there is neither the time nor
resources to manually weed records to remove those documents that should be destroyed. There
is the small risk of destroying the only record of a student’s attendance if central records have
gaps. Going forward this will be less of a concern as central records on SITS are complete.
5. Current & Future Student Records
5.1
In order to ensure that that there are robust and clear procedures in place to coordinate the
future management of student records this section discusses at the ownership, format and
retention of student records for current and future students.
5.2
Ownership
Student records are currently held in Academic Schools and in Registry Services (including
Cornwall Campus). Throughout a student’s time at the University easy access is required by both
these groups. Work is being done to pilot wider access to WinDIP which will provide access to
centrally held records reducing the need to hold duplicate records but until a time when there is a
fully implemented electronic system for storing these records there will be some duplication. It is
suggested that Registry Services are responsible for retaining the core student record (outlined in
Annex A) since this is a part of the SITS record.
5.3
Format
Traditionally student files have been held in a variety of formats paper files, electronic records held
on SITS and scanned images held in either WinDIP or elsewhere on shared servers. The format in
which records are held is not addressed in detail here, rather the aim is to ensure that the correct
information is being held. This will prepare for the introduction of any future electronic storage
system that may be introduced. If records are being held electronically it is important that the
records should remain accessible be suitably structured so that they are easily searchable. Long
1
http://www.jisc.ac.uk/whatwedo/themes/eadministration/recordsman_home/srl_structure.aspx
term preservation and access to the records should also be considered. It is important that records
remain true to their original format and are not edited, if retaining electronic records it may be
helpful to save the records as pdf or other fixed format files to prevent accidental alteration.
Regardless of format the recommended retention schedule should be followed and just as paper
records are shredded and destroyed, electronic records should be deleted at the correct time.
5.4
Retention Schedule
5.4.1 The Data Protection Act does not specify a time period for retaining personal information
rather it states that personal data should ‘not be kept for longer than is necessary2.’ It is therefore
for the University to decide what length of time is considered necessary. A retention schedule
provides guidance upon how long different categories of records should be held and when they
can be destroyed. Annex B contains the recommended retention schedule for student records, it
does not list individual documents by names rather it outlines the type of information being held
thus allowing for different practices. The schedule outlines for each type of document how long it
should be retained and who is responsible for retaining the Master copy of that record.
5.4.2 All records should be destroyed when their retention period has passed. The retention
schedule takes into account that the time and resources that would be required to weed files and
therefore recommends standard points at which student files, assessment etc can be destroyed.
Given this, it is important to consider what information is held on the student file, if there is a
legitimate reason to keep a document then it should be kept, however, not every email will need to
be held on student file if the first place.
5.4.3 Currently the retention schedule does not take into account any historical value, the
University does not have a formal University Archive and therefore does not have the space or
resource to manage a formal University Archive. The quasi-permanent preservation of the core
record helps to ensure that in the absence of a formal appraisal process key historical information
is preserved.
5.4.4 The retention schedule has been written at a relatively general level so that it is accessible
and useable, further advice and information is available from the University Records Manager.
July 2009
2
Data Protection Act 1998, Schedule 1(1).
Annex A
Core Record
The core student file should be retained indefinitely, for the purposes of providing references,
confirming awards, historical records and statistical analysis. This core record is held in SITS and
therefore all other records can be destroyed in line with the Student records retention schedule.
Biographical Information
Student name
Student ID number
Address
Date of birth
Photo
Sex
Ethnicity
Disability
Nationality
Academic/Progression/Transcript Information
Funding status
Mode of study
Educational Background
Courses
Date of attendance
Performance/Assessment
Name, date and result of award
Module results
Note of serious disciplinary
Additional information as required by professional/accreditation bodies
Function: Student Administration - Student File
Record
1
Retention Period
Owner
Core Record (data as opposed to documents)
1.1
Personal details (name, address, date of birth, gender, ethnicity, disability etc)
Permanent
Registry (SITS)
1.2
Progression details (course, change of course, note of disciplinary, withdrawal)
Permanent
Registry (SITS)
1.3
Transcript details (Year of completion, award, result, modules)
Permanent
Registry (SITS)
2
Disciplinaries, appeals & complaints
2.1
Records documenting the handling and results of academic appeals by individual students.
2.2
Records documenting the handling of formal complaints made by individual students against the institution.
2.3
Records documenting the handling of complaints by individual students where the formal complaints procedure is
not initiated.
2.4
Records documenting the conduct and results of disciplinary proceedings against individual students.
3
Records documenting submitted/completed assessments: formative assessments.
3.2
Records documenting submitted/completed assessments: summative assessments.
3.4
3.5
3.6
3.7
4
4.1
4.2
4.3
4.4
School/Faculty?
School/Faculty?
School/Faculty?
School/Faculty?
Assessment
3.1
3.3
Last action on case + 6
years
Last action on case + 6
years
Last action on complaint +
3 years
Last action on case + 6
years
Records documenting marks/grades given to submitted/completed summative assessments and, where
appropriate, awards and classifications.
Records documenting feedback on academic progress, and general academic guidance and support, given to
individual taught students.
Records documenting individual students' attendance at examinations, and the handling of reports of mitigating
circumstances.
Records documenting individual students' submission of assessed work and handling of reports of mitigating
circumstances.
Examination Board: agenda, minutes, papers, correspondence and other records relating to the preparation of
committee business or to actions to be taken (or not taken) as a result of committee decisions.
Progression & Continuation
Records documenting the registration of individual students on programmes.
Records documenting the academic progress of individual students and formal action taken by the institution to
deal with unsatisfactory progress.
Records documenting the transfer of individual students to new programmes or to new courses within
programmes.
Records documenting the withdrawal of individual students from the institution.
Current academic year
Confirmation by Board of
Examiners + 6 months.
Current academic year + 6
years
Completion of student's
programme + 6 years
Current academic year + 1
year
Current academic year + 1
year
Current academic year + 6
years
End of student relationship
+ 6 years
End of student relationship
+ 6 years
End of student relationship
+ 6 years
End of student relationship
+ 6 years
School
School
School
School
School
School
School
Registry(SITS/WinDIP)
Registry(SITS/WinDIP)
Registry(SITS/WinDIP)
Registry(SITS/WinDIP)
4.5
Records documenting the termination of individual students' programmes.
4.6
Records documenting the handling of applications for admission: successful applications.
4.7
Records documenting the handling of applications for admission: unsuccessful applications.
5
Registry(SITS/WinDIP)
Registry(SITS/WinDIP)
Registry(SITS/WinDIP)
Research Students
5.1
Records documenting the conduct of formal assessments of work undertaken by research students.
5.2
Records documenting academic advice and guidance to individual students on the selection of research subjects
and on the progress and standard of their work.
5.3
Records documenting the appointment of supervisors for research students.
6
End of student relationship
+ 6 years
End of student relationship
+ 6 years
Completion of admissions
process + 1 year.
Completion of student's
programme + 6 years
Completion of student's
programme + 6 years
Termination of appointment
+ 1 year
School
School
School
Other
6.1
Records documenting the handling of individual students' requests for statements of results/transcripts.
6.2
Records documenting the handling of requests for confirmation of individual students' awards, attendance or
conduct from employers and other educational institutions.
Last action on request + 3
Months
Last action on request + 3
Months
Registry
Registry
Version 2.0