Data Retention
Schedule.
How long we keep records, and how they are securely disposed of.
Purpose and Legal Basis
This Data-Retention Schedule sets out how long New Seeds Education Ltd keeps different categories of personal data and records, and how they are securely disposed of at the end of that period. It supports and should be read alongside our Data Protection and Information Governance Policy and our Privacy Notice.
We process personal data lawfully under the UK GDPR and the Data Protection Act 2018. We keep personal data only for as long as is necessary for the purpose for which it was collected, or for as long as required by law, statutory guidance or safeguarding duties.
Data Controller: New Seeds Education Ltd · Company No. 16614132
ICO registration reference: ZC207388
How to Read This Schedule
For each record type the schedule states the retention period (the trigger point from which the period runs) and the disposal method. Where statutory guidance sets a minimum period, we apply that period; where it does not, we apply a reasonable period proportionate to the purpose.
Common trigger points:
- DOB — date of birth of the individual
- End of placement — the date the learner leaves New Seeds
- Date of record — the date the record or event was created
Safeguarding and Child Protection Records
| Record | Retention period | Disposal |
|---|---|---|
| Child protection / safeguarding files | Until the learner's 25th birthday, then reviewed | Secure shredding / secure deletion |
| Low-level concerns about staff | Until retirement or 25 years from record where linked to allegations (IICSA) | Secure shredding / secure deletion |
| Allegations against staff (substantiated) | Until normal pension age or 10 years, whichever is longer | Secure shredding / secure deletion |
| Allegations found to be malicious | Deleted from personnel file | Secure deletion |
| Accident / incident records | DOB + 25 years (or as advised) | Secure shredding / secure deletion |
Learner Education and SEND Records
| Record | Retention period | Disposal |
|---|---|---|
| Learner educational record | End of placement + up to DOB + 25 years for SEND | Secure shredding / secure deletion |
| EHCP and SEND provision records | DOB + 30 years (potential litigation) | Secure shredding / secure deletion |
| Individual Learning Plans / reviews | End of placement + 3 years | Secure shredding / secure deletion |
| Examination results / certificates | Copy to learner; centre record + 6 years | Secure shredding / secure deletion |
| Attendance registers | Date of register + 3 years | Secure shredding / secure deletion |
| Behaviour / restraint / incident logs | DOB + 25 years | Secure shredding / secure deletion |
Admissions, Health and Consent
| Record | Retention period | Disposal |
|---|---|---|
| Admissions / referral records | End of placement + 1 year | Secure shredding / secure deletion |
| Individual Healthcare Plans | End of placement, then reviewed | Secure shredding / secure deletion |
| Medication administration records | Date of record + current year + 6 years | Secure shredding / secure deletion |
| Photo / media consent forms | While valid + review annually; delete on withdrawal | Secure deletion |
| Trip consent forms | End of trip + 3 years (or DOB + 25 for incidents) | Secure shredding |
Staff, Recruitment and HR
| Record | Retention period | Disposal |
|---|---|---|
| Staff personnel file | End of employment + 6 years | Secure shredding / secure deletion |
| Recruitment records (unsuccessful) | 6 months from decision | Secure shredding / secure deletion |
| DBS certificate details | Verified, then no longer than 6 months (number/date only retained) | Secure deletion |
| Single Central Record entries | Duration of employment; entry removed on leaving | Secure deletion |
| Payroll / pension records | Current year + 6 years (pension per scheme rules) | Secure shredding / secure deletion |
| Staff training records | Duration of employment + 6 years | Secure shredding / secure deletion |
Governance, Finance and Operations
| Record | Retention period | Disposal |
|---|---|---|
| Financial / accounting records | Current year + 6 years | Secure shredding / secure deletion |
| Contracts and agreements | Expiry of contract + 6 years | Secure shredding / secure deletion |
| Governance / Board minutes | Permanent (archived) | N/A — archived securely |
| Complaints records | Date of resolution + 6 years | Secure shredding / secure deletion |
| CCTV footage | 30 days (unless required for an investigation) | Automatic secure overwrite |
| Website / marketing enquiries | Up to 2 years from last contact | Secure deletion |
Disposal and Review
Secure disposal
- Paper records are cross-cut shredded or destroyed by a certificated confidential-waste contractor
- Electronic records are securely deleted and, where held by third-party processors, deletion is confirmed contractually
- A disposal log records what was destroyed, when and by whom
Review
This schedule is reviewed annually by the Data Protection Lead, and sooner following any change in legislation, statutory guidance or ICO guidance. Any variation to a stated period is recorded with the reason.