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Candidate Document Retention Policy

Date policy issued: March 2025

Review frequency: Every 12 months (as a minimum)

Review due date: March 2027

1. Introduction

This Candidate Document Retention Policy outlines the procedures for retaining and deleting personal information within Milk Education following the conclusion of an individual’s work with Milk Education. The policy ensures that all personal information is retained only for as long as necessary for legitimate business purposes and in compliance with data protection laws. This policy also clarifies Milk Education’s approach to handling candidate data in accordance with safeguarding regulations and the right to be forgotten.

2. Scope

This policy applies to all personal data collected by Milk Education from candidates. It outlines the retention periods for various categories of personal information, the process for deletion, and how we will manage candidate data in compliance with legal obligations and safeguarding requirements.

3. Retention Periods for Personal Data

The following personal information will be retained by Milk Education for the specified periods after the completion of a person’s work:

DBS (Disclosure and Barring Service) Check

  • Retained for 1 year after the completion of the assignment or employment.
  • After this period, DBS information will be securely deleted.

Proof of Address (e.g., utility bills, bank statements)

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, proof of address documents will be securely deleted.

Proof of Qualifications (e.g., certificates)

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, proof of qualifications will be securely deleted.

Photographic Identification (e.g., passport, driving licence)

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, photographic identification will be securely deleted.

Right to Work Documentation

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, right to work documentation will be securely deleted.

Proof of National Insurance Number

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, proof of National Insurance number will be securely deleted.

Employment History

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, unless a safeguarding issue has been disclosed, this will be securely deleted.

Overseas Police Check (if applicable)

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, overseas police check information will be securely deleted.

References

  • Retained for 2 years after the completion of the assignment or employment.
  • After this period, references will be securely deleted.

4. Safeguarding-Related Information

Any personal data related to safeguarding matters (e.g., child protection, safeguarding concerns, allegations) will not be deleted. This information will be retained indefinitely, as required by safeguarding regulations, and will only be accessible to authorised personnel.

5. Right to Be Forgotten

A candidate may request to exercise their right to be forgotten at any time. However, due to safeguarding requirements, if the candidate has worked through Milk Education, their data will not be permanently deleted. Instead, the following process will apply:

The candidate’s personal data will be moved to an archived status within Milk Education’s systems. This means that:

  • The candidate’s information will no longer be visible to anyone within Milk Education (e.g., recruiters).
  • The candidate’s documentation will still be accessible by the CRM administrator for safeguarding and legal reasons, ensuring that any future safeguarding concerns can be addressed.

This ensures that Milk Education complies with its legal and safeguarding obligations while respecting the candidate’s rights.

6. Method of Data Deletion

Upon expiration of the retention periods outlined above, Milk Education will take the following steps to securely delete personal data:

  • Digital data will be deleted from all systems, including emails, databases, and file storage, using secure deletion methods that ensure the data cannot be recovered.
  • Physical copies of documents will be securely shredded or otherwise disposed of.

7. Data Access and Security

Throughout the retention period, personal data will be securely stored, and access will be limited to authorised personnel only. Milk Education will implement necessary technical and organisational measures to safeguard personal data from unauthorised access, disclosure, alteration, or destruction.

8. Exceptions to the Retention Period

In some cases, Milk Education may be required to retain certain personal data for a longer period due to legal or regulatory obligations. If an exception applies, Milk Education will retain the data for the required period, after which it will be securely deleted.

9. Review and Updates to the Policy

This Document Retention Policy will be reviewed regularly to ensure it remains compliant with applicable laws, regulations, and best practices. Any updates to the policy will be communicated to relevant personnel and stakeholders.

Contact Information

For questions regarding Document Retention, please contact Milk Education – info@milk-education.co.uk.

This policy is designed to comply with UK law and will be regularly updated to ensure its effectiveness in safeguarding vulnerable individuals in educational environments.