Guidance on the retention of paper student files

Introduction

This guidance concerns the storage, retention and destruction of historical student data held in the form of paper files and student cards.

The student record

The University aims to retain a basic record of every student who attended The University of Manchester and its predecessor institutions. This enables the University to provide academic transcript information to former students and to maintain a historical record of its student body.

This record consists of the 31 elements listed below, although not all of these elements will be relevant for every student.

Student data which does not consist of the elements listed for permanent retention should be destroyed 6 years after the student has left the University. This enables the University to comply with the General Data Protection Regulation on storage limitation, which states that “personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed”

Examples of student data which should not be kept beyond the 6 year retention period would include financial data, contact details, correspondence with the University, attendance and disciplinary data, student photographs, admissions data and criminal record (DBS) checks.

Data relevant to Fitness to Practise and Fitness to Study processes will be subject to course specific rules and this should be checked locally where relevant.

Paper student files

Prior to 1978 the University holds a sufficient record for the majority of students who graduated from the institution.

From 2007 onwards the University holds a full electronic record for each student.

For students who graduated between 1978 and 2006 (inclusive) it can be the case that paper student files held locally are the only source of information held by the University.

Paper student files dating from this period should therefore be managed as important University assets, in line with Data Protection principles and specifically according to the following rules.

Paper student files should be:

• Stored securely, and should only be accessible to members of staff of the University. They should not be stored in areas accessible to students or members of the public;
• Stored in areas where they are safe from physical damage (for example not in areas which are prone to flooding or infestation);
• Stored in a manner which makes them accessible for the purposes of provision of transcript or historical information. For example their chronological and alphabetical order should be preserved to make finding particular files possible;
• Recorded to a level sufficient for the University to be aware of their existence and location. This could be to a box or series level rather than listing individual student files. This information should be kept at a local level and also communicated to the Academic Support Team in the Division of Student Admissions and Administration and located in the Student Services Centre, Burlington Street;
• Weeded to ensure that only the information listed below is retained wherever possible.

Where this is not possible for resource reasons please contact the Information Governance Office with an exception request. Please see the Information Governance Exception Handling  SOP for details;

Locally held paper records for students who graduated prior to 1978 or after 2006 should be securely destroyed in line with the Records Retention Schedule.

Information to be retained

The following is a table of data elements which need to be retained from paper student files for students who graduated between 1978 and 2006. Not all files will contain all of these elements.

Further information

For further information on the management of University data please see the Information Governance Office website.