[sims] Deleting SIMS data under GDPR

[fiza]

Has anyone taken the steps to bulk delete Student Data for pupils who have left the School? If so how did it go and which data areas did you select for deletion?

[cw222]

There is a bulk deletion tool in Routines > Student > Bulk delete student data. We selected all of the tickboxes and selected the students via age (for most of the users)

We delete all student data after a period of time (in accordance with your GDPR policy) has passed since the student was at the school. It went ok!

 

We then ran a report based on when the students had left the school and did these manually.

 

It took around 30 minutes out of hours and we didn't have any errors.

 

At the moment this deletes MOST student data . (So if you want full deletion you will have to manually delete some of these)

 

SIMS spring release will provide for complete deletion of student data of your choosing, so you may need to run this again in a few weeks

 

- " ·Bulk Deletion of Pupil/Students Routine: The ability to delete all pupil data has been added to the Bulk Delete Student Data routine."

 

Edited March 20, 2019 by cw222

[RyanK]

Fiza, have you checked first you are passed the time period where you are allowed to keep the data?

 

School records are to be kept until the childs' 25th Birthday, for the first 6 years they are to be kept on site, and then exported to an archive for any time after this. If a child is LAC (Looked After Children), this extends from 75 years after the date they turn 18, so in those persons cases, you may not delete/destroy their data, until they are 93 years of age.

 

Registers may only be deleted/destroyed 10 years after the date the register was taken, so if this is including children that left last July, you would not be able to delete those registers until July 2028.

 

Admission records/registers, must be kept indefinitely.

 

I would never delete data/users from SIMS unless absolute 110% sure, with confirmation from your DPO (Data Protection Officer) that you are in an absolute legal position to do so. You could be opening a very large can of worms for yourself and your institution.

[cw222]

Like Ryan said, make sure you are 110% sure - SIMS will prompt you about deletion of students with LAC status (and SEN if i remember correctly) on their account.

 

Any students who have additional data retention needs can have the "Protect from Bulk Deletion" flag added to their student information (Under basic information). You can run a report on these students to make sure that their information is not deleted in any process you undertake.

 

The archive attendance marks will keep all your registers and attendance data, however it will not be "live".

[pooley]

Fiza, have you checked first you are passed the time period where you are allowed to keep the data?

 

School records are to be kept until the childs' 25th Birthday, for the first 6 years they are to be kept on site, and then exported to an archive for any time after this. If a child is LAC (Looked After Children), this extends from 75 years after the date they turn 18, so in those persons cases, you may not delete/destroy their data, until they are 93 years of age.

 

Registers may only be deleted/destroyed 10 years after the date the register was taken, so if this is including children that left last July, you would not be able to delete those registers until July 2028.

 

Admission records/registers, must be kept indefinitely.

 

I would never delete data/users from SIMS unless absolute 110% sure, with confirmation from your DPO (Data Protection Officer) that you are in an absolute legal position to do so. You could be opening a very large can of worms for yourself and your institution.

 

Where are you getting these time frames from ?

 

IRMS says registers to be kept current year +1 (+3 if its a meal register, +6 for fsm)

 

SEN = DOB +25yrs.

 

LAc I have no idea.

[RyanK]

Hi Pooley, IRMS is correct in terms of digital data however with Admissions paperwork, a lot of schools require parents to fill this out with pen and paper, this manual record must be kept indefinitely in an archive after the main 6 year period has passed after the child has left the school - any digital record can be deleted after the 6th year. (however I personally would check with a DPO before I ever delete any information)

 

If a child is SEN then yes it is DOB + 25 years (+additional years if review needed), if they are Statemented, DOB + 30 years (+ additional years if review needed), if they are LAC its DOB (from age of 18) + 75 years (IRMS does not quote this on their website for LAC, my LA uses this policy, a number of others do also)

In regards to attendance registers I do stand corrected I was going by an old version of my LA policy that was pre GDPR, requiring manual paper registers to be held for 10 years from register date. I agree with you as above, 1 year for standard, 3 for meals, 6 for FSM - after last date of register.

Edited March 21, 2019 by RyanK

[Banjo]

There is a bulk deletion tool in Routines > Student > Bulk delete student data. We selected all of the tickboxes and selected the students via age (for most of the users)

We delete all student data after a period of time (in accordance with your GDPR policy) has passed since the student was at the school. It went ok!

 

We then ran a report based on when the students had left the school and did these manually.

 

It took around 30 minutes out of hours and we didn't have any errors.

 

At the moment this deletes MOST student data . (So if you want full deletion you will have to manually delete some of these)

 

SIMS spring release will provide for complete deletion of student data of your choosing, so you may need to run this again in a few weeks

 

- " ·Bulk Deletion of Pupil/Students Routine: The ability to delete all pupil data has been added to the Bulk Delete Student Data routine."

 

 

I would be very careful with this process. For example, the SENCO forgets to record the student as a E/K on SIMS and you delete their electronic record > ouch!

[jacquij123]

Hi Pooley, IRMS is correct in terms of digital data however with Admissions paperwork, a lot of schools require parents to fill this out with pen and paper, this manual record must be kept indefinitely in an archive after the main 6 year period has passed after the child has left the school - any digital record can be deleted after the 6th year. (however I personally would check with a DPO before I ever delete any information)

 

If a child is SEN then yes it is DOB + 25 years (+additional years if review needed), if they are Statemented, DOB + 30 years (+ additional years if review needed), if they are LAC its DOB (from age of 18) + 75 years (IRMS does not quote this on their website for LAC, my LA uses this policy, a number of others do also)

In regards to attendance registers I do stand corrected I was going by an old version of my LA policy that was pre GDPR, requiring manual paper registers to be held for 10 years from register date. I agree with you as above, 1 year for standard, 3 for meals, 6 for FSM - after last date of register.

Do you have an official document detailing this, just that it's very different to what I've seen? Especially the part about the paper records?

[Seb1780]

Do you have an official document detailing this, just that it's very different to what I've seen? Especially the part about the paper records?

 

I'd like to see that too; there's a lot of "you must" statements in this thread with no backup or justification. What one person has been told to do in one establishment is not necessarily the law!

[RyanK]

[TH="colspan: 6"]4 Pupils







[TH="colspan: 2"]Action at the end of the administrative life of the record

Basic file description	Data Prot Issues	Statutory Provisions	Retention Period [operational]
Admission Registers	Yes		Date of last entry in the book (or file) + 6 years	Retain in the school for 6 years from the date of the last entry.	Transfer to the Archives
Attendance registers	Yes		Date of register + 3 years	SHRED [if these records are retained electronically any back up copies should be destroyed at the same time]

 

Hi Jacqui, please see above in regards to attendance records, this excerpt is taken from the IRMS advice to schools regarding data retention. I don't have a link to source unfortunately, this is from the document contained within my LA's intranet. Dated 2019.

Edited March 29, 2019 by RyanK

[matt40k]

Paging @GrumbleDook

[GrumbleDook]

I think I’ve already covered that the schools toolkit is having an update out in May, but the retention schedule annex still covers the same core information on legislative / statutory reasons to retain data and the length.

 

The area many schools get confused over is operational practices ... and some of that boils down to assessing and deciding what the school needs. The DfE Data Protection covered a chunk of that too.

 

After the core retention requirements have been covered you are left with deciding what you need as a school to operate.

 

To be honest, this is nothing that new either.