How should schools manage paper archives?
A paper archive is a physical collection of documents, records and contracts stored in their original hard-copy form. This article discusses best practice guidance for keeping records, safe, secure and accessible - an archive is much more than just a 'storage unit'.
Legal Basis
⚖️Purpose Distinction: You must distinguish between records kept for daily business (i.e. current staff files) and those kept for archiving.
⚖️Exemption from Rights: Schools may claim exemptions when archiving in the public interest, but should check with their DPO for advice.
⚖️Safeguarding: Your DSL is the best person to advise if you need to keep special cases or safeguarding files longer than your retention schedule. If you do decide to do this then document why you need to keep the file and review the date for destruction accordingly.
Environmental Controls & Location
🌦️Fire & Flood Protection: Avoid rooms with water pipes overhead, or flood-prone basements.
🌦️Climate Control: Aim for a cool, dry and well-ventilated space to avoid mould or brittleness.
🌦️Pest Control: Regularly check for silverfish, rodents, mice or birds. Use sealed cabinets, such as filing cabinets.
Security
Physical archives will contain 'special category data' (such as SEN records and safeguarding files), therefore security must be multi-layered:
🔐Restricted Access: The archive must be locked. Access should be limited to specific staff (those people who would have access to the same 'live' data). Consider recording who enters and why.
🔐Confidentiality: Documents should not be visible to others walking by and the room should not have a dual-purpose where there is a risk of inappropriate access to the archive. For example, the room should not be used to store other items, nor should it be part of a communal area like a meeting room or staffroom - in those cases restricted access and confidentiality would be at risk. Ensure no sensitive files are left unlocked or out on tables.
🔐Audit Trails: As these are original documents, consider how you will record removal of files and why they have taken it.
Organisation & Indexing
It's essential to be able to find any data you are storing in the event of a request from Ofsted or a Subject Access Request.
🏷️Labelling: Ensure there is clear labelling about the content (don't mix staff and student files for example).
🏷️Destruction Date: Clearly label the destruction date.
🏷️Master Index: Keep a spreadsheet (archive register) that maps every box to its physical location.
Retention & Disposal
Ensure you are able to comply with your retention schedule by having regular reviews and removal of files to meet your retention schedule.
⚠️Dispose of the data appropriately - confidential data does not stop being confidential when you no longer need it. Disposal using a cross-cut shredder is the most appropriate and easy method of destruction.
Transitioning to Digital
Many schools are transitioning to digital archives, examples of how this might be done are:
💻Scanning on Exit: When a student leaves or staff member resigns, their files are scanned into the secure MIS and the paper copy is destroyed.
Vital records may need to be identified and stored off site. There may be specific statutory or insurance related reasons to keep physical documents. This might include original contracts, deeds, land registry etc. In these instances, make sure the files are clearly labelled and kept separate.
💻Don't digitise 'mess' - only scan what is legally required. If a piece of paper has passed its retention date, then shred it immediately.
💻Check: When moving to the cloud, ensure the digital copy has been verified before shredding the physical copy.
Backup vs Archive
A backup is not the same as an archive - a backup is a 'safety-net' and an archive is storage. They both involve moving data to another location, but serve different purposes and follow different rules.
An archive is a move of inactive data where its primary goal is long-term storage, while keeping records safe and searchable without cluttering your active data and systems.
Further Resources:
Getting Started with Records Management & Data Retention
Records Management Toolkit: Where do I start with records management?
Podcast Episode 3: Records Management and Retention
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DPE Customers should review our Records Management Best Practice Area and Retention Schedule on our Knowledge Bank platform. We can view your archive during one of our visits and provide feedback and guidance. |
