Equra College London
Version: 1.0
Approved by: Governing Body / Academic Board (as applicable)
Effective from: 25/12/2025
Review date: 20/12/2025
Owner: Data Protection Lead / Quality Lead

1. Purpose

Equra College London (“Equra”) keeps records to deliver education, protect students, meet legal and regulatory duties, and evidence decisions. This policy sets out how Equra manages records and how long different categories of records are retained, before secure disposal.

2. Scope

This policy applies to all records created or held by Equra in any format, including:

Paper files and scanned documents
Email and messaging records where used for official purposes
Learning platform records
Student information systems and spreadsheets
Audio/video recordings where used for official purposes
CCTV where applicable
Staff and HR records
Finance and payment records
Safeguarding and wellbeing records

3. Principles

Equra will:

Keep only what is necessary for clear purposes;
Keep records accurate, organised and accessible to authorised staff;
Retain records for no longer than necessary;
Dispose of records securely;
Apply additional controls to sensitive categories (health, safeguarding, disciplinary);
Pause deletion where a legal hold applies.

4. Roles and responsibilities

Governing Body: oversight and approval of retention approach.
Data Protection Lead: retention governance, advice, incident oversight, audits.
Quality Lead / Student Services Lead: ensures student records are created and filed correctly.
Finance Lead: ensures financial records are retained appropriately.
All staff: must store records in approved systems and follow retention rules.

5. Records management requirements

Equra will ensure:

Clear file naming and version control for key documents;
Controlled access based on role and need-to-know;
Secure storage (locked cabinets for paper; access controls for digital);
Regular backups where applicable;
Secure transfer methods for sensitive files;
Minimal use of personal devices for official records unless authorised.

6. Legal hold and exception to deletion

Where there is an active or reasonably anticipated:

Complaint, appeal, disciplinary matter, safeguarding investigation, legal claim, tribunal, regulator/partner review, audit, or police enquiry,
Equra will place relevant records under a legal hold and suspend routine deletion until the matter is concluded and any further retention need is assessed.

7. Secure disposal

Equra will dispose of records securely, for example:

Confidential shredding for paper records;
Secure deletion for digital records, including deletion from shared drives and backups where feasible;
Disposal actions recorded for high-risk categories (safeguarding, disciplinary, complaints, HR).

8. Review

This policy and schedule will be reviewed annually, and updated where required by new systems, partner requirements, or changes in law/regulation.

Appendix A: Retention Schedule (Template)

Retention periods below are set by Equra based on legal, safeguarding, audit and operational needs. Where “trigger” is stated, retention begins from that event date.

A. Student admissions and enrolment records

Application forms, offer letters, enrolment confirmations: [X years] from end of relationship or last activity
Identity/right-to-study checks (where held): [X years] from end of relationship
Fee agreements and instalment plans: [X years] from final payment/closure

B. Academic delivery and assessment records

Module/course registers and attendance logs: [X years] from course end
Assessment briefs, marking records, feedback, grade sheets: [X years] from results confirmation
Moderation records and sampling evidence: [X years] from results confirmation
Examination materials (where applicable): [X years] from assessment date
Certificates issued and award records: [X years] from award date (often long-term)

C. Student support, wellbeing and adjustments

Support plans and learning support documentation: [X years] from end of support or end of relationship
Disability and reasonable adjustment records: [X years] from end of relationship
Fitness to Study records: [X years] from case closure

D. Safeguarding and serious incident records

Safeguarding reports, referrals, risk assessments, outcome notes: [X years] from case closure
Serious incident logs involving safety risk: [X years] from case closure
(Access to these records must be strictly restricted.)

E. Student conduct, harassment and disciplinary

Anti-bullying/harassment reports and investigation files: [X years] from case closure
Student disciplinary case files and outcomes: [X years] from case closure
Academic misconduct case files and outcomes: [X years] from case closure

F. Complaints and appeals

Complaint case file and outcome letters: [X years] from completion of procedures
Appeal case file and outcome letters: [X years] from completion of procedures

G. Finance and payments

Invoices, receipts, payment confirmations, refunds: [X years] from end of financial year
Banking/payment processor records received by Equra: [X years] from end of financial year
Bursary/discount approvals (if used): [X years] from end of financial year

H. Staff, HR and recruitment

Recruitment records (applications, interview notes): [X years] from recruitment decision
Employment records (contracts, role changes): [X years] from employment end
Training records (safeguarding, EDI, data protection): [X years] from completion or employment end
Staff disciplinary/grievance (if applicable): [X years] from case closure

I. IT and systems

System access logs (where held): [X months/years] from creation
Learning platform activity logs (where held): [X months/years] from creation
Incident and breach logs: [X years] from incident closure

J. Marketing and communications

Marketing consent records: [X years] from consent withdrawal or last engagement
Newsletter lists (if used): [X years] from last engagement
Event attendee lists: [X years] from event date

K. CCTV (if applicable)

CCTV recordings: [X days] unless required for investigation or legal hold
CCTV extracts used for investigations: [X years] from case closure

L. Governance and quality

Policies and versions, approvals, meeting minutes: [X years] from approval date (often long-term)
External partner correspondence related to approvals: [X years] from closure of matter
Audit reports and action plans: [X years] from completion

Data Retention and Records Management Policy