Record keeping in schools.

Why schools need to keep records, and under which rules

Record keeping in schools is governed by three overlapping regimes, and most confusion comes from treating them as one.

Education law and statutory guidance. The Department for Education requires certain records to exist and to be maintained: the admission register and attendance register, the single central record of recruitment checks, and the pupil record itself. Academies and academy trusts have their own obligations through the funding agreement and the Academy Trust Handbook, which is why the DfE publishes separate record keeping and retention information for academies.

Data protection. UK GDPR and the Data Protection Act 2018 apply to every record containing personal data, which in a school is nearly all of them. The data protection principles do two things here that pull in opposite directions: they require personal information to be kept no longer than necessary, and they require it to be kept securely and accurately while you have it.

Freedom of information. Maintained schools and academies are both public authorities under the Freedom of Information Act 2000, so a member of the public can ask to access information the school holds and the school has twenty school days to respond. The Environmental Information Regulations sit alongside it and cover anything about the school estate. That obligation is the practical reason a school needs to be able to find things, not merely to have them.

One more requirement sits across all three. Because a school is a public authority, UK GDPR requires it to appoint a data protection officer, and record management is squarely within that person's remit: advising on the retention schedule, monitoring compliance with the legislation, and being the contact point for the ICO. In a small school the role is often bought in, which works, provided the retention schedule is theirs to own rather than a document they were shown once.

A school that reads only the first regime keeps too much. One that reads only the second deletes things it needed. The retention schedule is where the three are reconciled.

What counts as a school record

It helps to sort records by who they are about, because that is what drives the retention period.

• Pupil records. The educational record and pupil file, admissions and appeals, attendance, assessment, special educational needs files, behaviour and exclusions, accidents involving a child, and safeguarding or child protection records, which are kept separately from the main pupil file
• Staff personnel records. Recruitment and the checks that feed the single central record, contracts, training, appraisal, absence, disciplinary and grievance material, and payroll
• Governance records. Governing body or trust board minutes and papers, policies and their review history, registers of interests, statutory policies, and correspondence with the DfE, ESFA or local authorities
• Operational and estates records. Health and safety, risk assessments, asbestos management, fire safety, contracts, and finance
• Information governance records. Your records management policy, the retention schedule itself, subject access requests and their outcomes, and any personal data breaches

Two categories are routinely missed. Safeguarding records are not part of the pupil file and follow their own rules on storage, transfer and retention. And the school's own decision making, the minutes and the correspondence, is a record in exactly the same sense as a pupil file, subject to freedom of information and often the first thing asked for.

How long schools must keep records

There is no single statute setting school retention periods. The standard reference in England is the Information Management Toolkit for Schools, published by the Information and Records Management Society, which gives a recommended retention schedule for schools covering every record type they hold. The DfE's own guidance on keeping records for academies covers the trust specific material. Most local authorities publish their own retention guidelines for maintained schools, usually a version of the same toolkit.

The anchors worth committing to memory, because they cover most of the volume:

• The pupil's educational record, defined by the Education (Pupil Information) (England) Regulations 2005, is generally retained until their twenty fifth birthday. Those same regulations give parents at maintained schools a right to see it within fifteen school days, which is a shorter clock than a subject access request and catches schools out
• Child protection and safeguarding records are retained until the person's twenty fifth birthday, and longer where they relate to an ongoing inquiry
• Accident records involving a child run until the child's twenty fifth birthday, rather than the three years that applies to adults
• Staff personnel records are generally kept six years after the person leaves, with longer periods for pension and certain safeguarding material
• Asbestos management records are kept for forty years, which is longer than most schools expect and is a health and safety requirement rather than an educational one
• Governing body and trust board minutes are permanent records, and should never be part of a routine disposal run

Two things about these recommended retention periods are widely misunderstood. They are best practice rather than statute, and a school can depart from them where it has a documented reason, which answers the common question about needing to keep something for longer or shorter than the recommendation. And a retention period is a maximum as well as a minimum: keeping every pupil file indefinitely is a data protection failure, not caution. Older files created under the Data Protection Act 1998 are not exempt from that, and are usually where the largest unreviewed volume sits.

What makes a retention schedule work is the trigger rather than the number. Twenty five years from what: date of birth, date of leaving, or last entry? Write the trigger down beside the period, or the schedule cannot be applied by anyone other than its author.

Storing, scanning and finding records

The question schools ask most often is whether to scan or to store. There is no legal preference: a scanned record is admissible and acceptable provided the scanning process is documented, the copy is complete and legible, and the school can show the digital version has not been altered.

Scanning earns its cost where records are requested often and stored where they are not. Pupil files carrying pupil information that must transfer when a child moves school, and safeguarding records holding sensitive information that may be needed at speed, are the strongest candidates. Boxes of finance records that nobody will open before disposal are the weakest, and professional document storage is usually cheaper than scanning them. Sorting by types of documents rather than by age is what makes that decision cheap: a document management review that starts with the archive tends to stall in it.

Both routes can be compliant, and educational institutions run a mixture in practice. Whichever route, three controls do the work. Records must be held in secure storage, whether that is a live system, a parent portal or an archive, with access limited to those who need it. Information management in schools fails most often at this point rather than at the retention schedule. There must be a log of what exists and where, because a freedom of information request or a subject access request is answered from the log rather than from memory. And personal information must be protected against loss and unauthorised alteration, which for digital records means backups and an audit trail, and for paper means a locked room rather than a cupboard in a corridor.

Confidential records are disposed of by secure destruction, normally cross cut shredding or a certificated destruction service, with a record of what was destroyed and when. The disposal log is itself a record, and it is the evidence that a deletion was deliberate rather than a loss.

When a pupil moves, and when a school changes

The educational record follows the pupil. When a child transfers, the school sends the file to the new school, and the common law duty is to do it promptly rather than at the end of term. Safeguarding and child protection records transfer separately and securely, and KCSIE expects the receiving designated safeguarding lead to be told where there is a live concern rather than left to read the file.

Conversion and reorganisation cause more record loss than any other event. When a school joins a trust, closes, or merges, the records do not evaporate with the legal entity: responsibility passes with it, and someone must be named as the recipient. The commonest failure is a school whose historic files were left in a building that changed hands.

Practically, the point to fix in advance is the list. A school that can show what records it holds, where they are and who is responsible can transfer them. A school that cannot is discovering its retention problem at the worst moment.

The school records that were never records

Every category above is a record the school knows it holds. The gap is the one it does not.

A parent raises a concern by text to a teacher, because that is the number they have. A safeguarding worry is first mentioned in a staff group chat at half past nine in the evening. A trip is reorganised over messages between three members of staff and a coach company. A head of year approves something in a message, and the decision reaches the file, if it reaches the file, as a line typed by someone else the following week.

Each of those is recorded information within the meaning of the Freedom of Information Act, and personal data within the meaning of UK GDPR, and it can be asked for. Almost none of it is held anywhere the school controls. It sits on personal phones, on both sides, belonging to people who may since have left.

That matters most at the moment schools are least able to absorb it. A safeguarding review asks when a concern was first raised. A subject access request from a parent covers messages about their child, wherever they are. An employment tribunal asks what was said to a member of staff and when. In each case a parent or an employee will produce their own copy, and a school that cannot produce its side is not neutral in that exchange, it is silent.

This is a records management question rather than a behaviour one, and staff are not doing anything unreasonable. It is worth asking, at your next leadership or trust board meeting, where the first report of a concern in your school actually lands, and whether you could produce it tomorrow.

Where to read the official guidance

The IRMS Information Management Toolkit for Schools is the retention schedule most English schools work from. The DfE publishes record keeping and retention information for academies and academy trusts. The ICO's guidance covers storage limitation, security and subject access, and its education sector material addresses schools directly. For safeguarding records specifically, read Keeping Children Safe in Education alongside the toolkit.

This page is a summary rather than advice on your school's own schedule. Where a record is subject to a live inquiry or an ongoing case, take proper advice before disposing of anything.

Related guides

• KCSIE: the records it actually asks you to keep
• Data retention policy: how long to keep what

All guides