Records Management

Interim Retention Schedule

An Interim Retention Schedule was approved by Council on 29 June 2010. It specifies, for certain particularly important areas, notably those relating to personal data, obligations to destroy information at particular times.

The Interim Retention Schedule was arrived at in the light of recognised good practice guidance for the university sector, both formal and informal, as well as guidance on employee records published by the Chartered Institute of Personnel and Development. There was a period of consultation on the schedule involving all departments in the College from April 2010 onwards. It is called "Interim" because it addresses only priority elements of the College's information where there is a particular operational or legal need for a centralised policy (see below).

Departments were required to certify by 17 December 2010 that they had completed all destructions in this regard, and over half of departments did so within a few working days of the target date. All all academic departments had by early summer 2011 met the requirement or had indicated that only the formal certification was outstanding. More serious problems with implementation emerged for Estates, Finance Human Resources and Quality, Planning and Academic Governance. This is a matter of particular concern as it means that a high proportion of staff records have not been destroyed on schedule. In part this is due to short-term staffing issues, and in part to a more fundamental issue of database design which is now being addressed (and which was brought to light through the publication of the Interim Retention Schedule).

[Download the current Interim Retention Schedule  in pdf format: this is the version current following revisions to the schedule by Information Management and Systems Committee in the first half of 2011, in the light of the first round of certified destructions.]

[Link to a  Summary of amendments to the Interim Retention Schedule   in the Spring and Summer terms 2011. Please note that further detail, including the rationale for changes, is to be found in the minutes and papers of Information Management and Systems Committee available to staff on the K drive Committee Archive]

[Link to information about services at Goldsmiths provided by Design and Print to help with the disposal of expired paper records.]

[Download the standard Declaration Form for completion by Heads of Department: this should be signed formally, but it is helpful if an electronic copy of the form is also sent to cgim@gold.ac.uk]

[Download the Special declaration form for Departments which did not submit a declaration form in the 2010 destruction round, viz: Estates; Finance; Human Resources; QPAG; Student Services and the Centre for Cultural Studies.] 

Why do we need to define retention periods?

Production of an Interim Retention Schedule was a key early priority in the implementation of the Goldsmiths Records Management Strategy. A Retention Schedule enables a university to ensure that:  

• legal obligations relating to the retention of the information are consistently honoured, including in particular the destruction of any personal data in accordance with what the Data Subject has been told (at the time of collection or subsequently);
   
• information required to meet internal operational needs, or in response to Freedom of Information Requests, can be more reliably located and retrieved (and we rely less on the memories of individuals - which with high staff turnover, as well as any unplanned absences, is insecure); 
   
• space (both space for paper records and server space) is not wasted through unnecessarily long retention of documents; 
   
• there is clear accountability for retention for the correct period and destruction as specified; 
   
• appropriate information is retained which allows the maintenance of a historical record and relationships with former students, while respecting the legal rights of Data Subjects.  

The fundamental principle underpinning all these requirements is the recognition that holding recorded information is an active, not a passive process: it involves the exercise of responsibility in the same way as destroying it or acquiring it in the first place. The problem here is that for most people this is counter-intuitive: leaving an inherited file on a dusty top shelf of a storeroom simply does not feel like an action in the same way as, for example, spending money, although there are circumstances in which those actions can be of equivalent significance. It is not yet widely recognised that the institution's need for good information management, along with appropriate supporting procedures, is similar.

The ethical dimension may also fail to be immediately evident, yet to have unclear procedures for the management of information means we may not honour the undertakings we have given to individuals (Data Subjects) about the way in which their personal data will be processed - including the period for which it will be kept. Similarly, if we have poor knowledge of what information we have and where it is, that will impair our ability to meet our obligations to those making requests under the Freedom of Information Act. Recognising and responding to all this means embedding consideration of information requestor requirements and Data Subject rights into the design of all relevant administrative processes at the outset, rather than as an afterthought. In this sense information rights are, in their legal, ethical and operational implications, comparable to rights under equal opportunities legislation.

For these reasons, an approach to enhancements in information management which focuses purely on detailed operational planning is likely to fail. Rather, success depends on recognising the changed framework for daily life which lies behind the detail. It means questioning our previous criteria for value judgements, whether about the actions of human beings (including ourselves!) or about the infrastructure - especially in terms of IT systems - which supports us in our work. Yet the extent to which we need to change our approach fundamentally will vary according to the sphere of activity with which we are engaged, because the consequences of failure are not of equivalent gravity in all areas, and indeed local freedom of operation may have positive value in some aspects of activity. The scope of this Interim Retention Schedule reflects this kind of prioritisation, as well as the effect of current resource constraints.

The immediate priorities at Goldsmiths: the need for an "Interim" Schedule 

The Interim Retention Schedule focuses on high priority areas, to cover the period until a Records Manager can be appointed. In practice these high priority areas mainly relate to two overlapping categories, viz:  

• major areas of personal data holdings (where failure to define retention clearly could threaten the rights of individuals or create unfairness through different policies in different offices);
   
• areas such as the retention of student work, where a lack of institutional policy on retention causes serious pressure on space.  (Student work is, of course, also personal data.)

Early duties of the future Records Manager (it is hoped from late 2010-11 onwards) will include the development of a full Retention Schedule.

Some key features of the Interim Retention Schedule

• No attempt is made to be comprehensive: the objective is to include the main areas of high-volume personal data, or personal data of types most likely to raise concern should the retention period remain unspecified. (A full Retention Schedule, as it already exists in most universities, is many times longer than this.)
   
• Statutory retention periods are not included in the Interim Schedule: in general these are the responsibility of specialist areas in the central administration with staff already trained in the requirements, and are not an area of concern in terms of either external compliance or internal transparency and interest. They will for completeness be included in due course in the full Retention Schedule, according to the requirements then in force.
   
• Accepted good practice on retention of all records is essentially based on the nature of the data, not the medium in which it is held. as it is the nature of the data which determines both the need to retain and (for personal data) what is reasonable in terms of Data Subject rights. This is not universally the current approach at Goldsmiths. It is important to recognise that the destruction obligations described here apply equally to paper and electronic records.
   
• The Schedule is structured so that in general destructions become due at the end of an academic year: this allows one destruction exercise to be conducted per year. In operational terms, the Summer Vacation should be regarded as defining the acceptable range of timings for scheduled destructions.
   
• A common, if not universal, feature of sectoral good practice guidelines on student records is that the driver for retention periods is the end, not the beginning, of the period spent by the student at the institution. This is necessary because the legal and operational need to access the information concerned relates to exit not entry. It follows that the basis organisational principle for student records should be expected graduation date not initial enrolment date, in order properly to accommodate non-standard periods of study (likely to become more common in future), or intermitting students. For some academic departments the adoption of this principle will involve a significant change of approach;
   
• Most if not all information which needs to be held longer than three years after the year in which a student relationship ends will be held by the central administration, so academic departments will be operating a subset of the schedule with few retention periods which are relatively short. (There may be exceptions in departments with an obligation to assess fitness to practise in accordance with professional body requirements.)

JISC Guidance on Retention

JISC has published a model records retention schedule for the higher and further education sector, which also provides information on those retention periods which are defined by legislation. The Goldsmiths Interim Retention Schedule was designed with reference to JISC and other good practice guidance, but is not comprehensive at present, in the way that the JISC schedule is.

Previous versions

The following (superseded) documents relate to the original version of the Schedule (approved Council June 2010):

Interim Retention Schedule (original (2010) version)  

Declaration form for completion by Heads of Department (2010 version)