Data Retention Schedule – NSEMM Policies

This is the one place where NSEMM sets how long it keeps each kind of record. Our Privacy Notice and Data Protection Policy point here. Our financial year runs from 6 April to 5 April.

Families, pupils and lessons

Ref	Record	How long	Then	Reason
F1	An enquiry form that was started but not finished	21 days after the last activity, then 30 days more	Deleted	Data minimisation
F2	Enquiries, applications and contact records where no lessons took place	2 years from the last contact	Anonymised	Enough to help a returning family or answer a complaint
F3	Family and pupil records where lessons took place: accounts, contact details, the enquiry, bookings, attendance, lesson notes, progress and reports	6 years after the end of the financial year of the last lesson or payment	Anonymised	Limitation Act 1980 s.5; Charities Act 2011 s.131
F4	Documents a family uploads to their portal (other than for the Community Education Fund)	7 days after a member of staff has checked them	Deleted	Data minimisation
F5	Support needs a family tells us (learning needs, disability, health), and the short summary for the tutor	While the family is with us (lessons or an open application), then 12 months after they leave, or straight away if consent is withdrawn	Deleted	Explicit consent
F6	Your Path saved plans	18 months without use (warning at 12 and 16 months)	Deleted	Data minimisation
F7	Lesson recordings	LessonSpace deletes the recording 90 days after the lesson. Our link to it is kept while the family is with us, then 90 days after they leave	Deleted	Safeguarding and quality checks
F8	Lesson transcripts and summaries	While the family is with us (lessons or an open application), then 90 days after they leave	Deleted	Safeguarding and quality checks
F9	Messages and group chat in our platform	3 years from the message	Deleted	Safeguarding record of contact with children
F10	Accounts of pupils at partner schools	12 months after the school programme ends (their lesson records follow F3)	Anonymised	Contract with the school
F11	Closed support tickets	2 years after the ticket closes	The words and files are removed; a count is kept	Data minimisation
F12	Lesson ratings and check-in answers, including answers given by phone with staff	6 years after the end of the financial year the account closed	Deleted	Service quality and the evidence of impact we report to funders

Any recording, transcript, message or ticket linked to a safeguarding concern is kept under S1 instead.

A family leaves when their last pairing ends and they have no open application. The time counts from the latest of the last pairing ending, the last application closing and the last lesson. Anything needed for a safeguarding concern is kept under S1.

Help with the cost (Community Education Fund)

Ref	Record	How long	Then	Reason
C1	Step 1 take-home income range (the £500 range only)	With the application (F2 or F3)	Deleted with it; reports use totals only	Legitimate interests
C2	Step 2 answers, reasons for asking to pay less, the decider’s note, and every evidence document	28 days after we tell you our decision, or until a review is decided, or while a recorded safeguarding or legal hold applies. A member of staff confirms each deletion	Deleted	Long enough for a review and a second check; no longer
C3	The outcome (confirmed amount, rule version, evidence types checked, date, who decided, short reason), the offer and Fund agreement documents, review decisions and the 1 in 10 check result	6 years after the end of the financial year of the last payment under the award	Deleted or anonymised	Charities Act 2011 s.131; contract
C4	Records made before CEF Access Policy v2: evidence files	7 days after they were checked (90 days if never decided)	Deleted; a record that a file was checked is kept with C3	Earlier policy
C5	Records made before CEF Access Policy v2: circumstance answers, inputs and scores	12 months after the award ends, or 12 months after a not-eligible decision, or straight away if consent is withdrawn	Removed; the decision is kept under C3	Earlier policy
C6	Professional referral records and funded sessions	As C3	As C3	Award records
C7	Priority score and its factors	While the application is open	Deleted with the application	Worked out again when needed
C8	Full Bursary documents, including asylum support, no recourse to public funds and housing letters	28 days after the decision, or until an appeal is decided	Deleted (the Fund evidence deletion queue)	As every Fund document (C2)
C9	The Full Bursary outcome: which reason applied, the type of evidence checked (never figures or copies), who decided, when and why, and the Fund status at the time	6 years after the end of the financial year of the last payment, as C3	Deleted	As C3

Calls, emails and texts

Ref	Record	How long	Then	Reason
P1	Call recordings, voicemail, voicemail transcripts and call notes	90 days after our last contact with that person (a call, text, support ticket or message)	Deleted	Long enough to act on a message and to follow up while we are in touch
P2	Call and text records (numbers, times) and text messages	2 years	Deleted	Answering questions and complaints
P3	Email content	90 days after sending; the record of who, when and the subject 2 years	Deleted	Data minimisation
P4	Short links sent in texts	180 days without use	Deleted	Data minimisation

Safeguarding

Ref	Record	How long	Then	Reason
S1	Safeguarding records about a child: concerns, reports (including drafts), case records, a possible child missing education, consent to pass details to another service, and recordings, messages or notes kept as evidence	Until the child reaches 25, or 6 years after the case closes, whichever is longer; longer while legal proceedings are open or expected	Two people (the safeguarding lead and one other) agree disposal; never by a timed job	Children Act 1989; Limitation Act 1980 s.28
S2	Allegations against staff, tutors or volunteers	Until normal pension age, or 10 years from the allegation, whichever is longer	As S1	Keeping Children Safe in Education
S3	A concern sent through the outage form while our safeguarding system is down	The sealed copy at most 30 days, until it moves into S1; a record with no words or names, 12 months	Deleted	Data minimisation
S4	Whistleblowing disclosures	Until closed, then 10 years	Deleted	Public Interest Disclosure Act 1998
S5	Data protection and other incident reports	10 years after closure	Deleted	Accountability

For confirmed child sexual abuse records we also consider the Independent Inquiry into Child Sexual Abuse recommendation of 75 years, case by case.

Tutors, staff, volunteers and applicants

Ref	Record	How long	Then	Reason
H1	Applications from people not hired, with interview notes and references	6 months after the decision (12 months if you agree)	Anonymised	Equality Act 2010 time limits
H2	HR file: contract, training, supervision, performance, sickness, disciplinary and grievance, HR notes (including lesson-log booking pauses)	6 years after the engagement ends	Deleted	Limitation Act 1980
H3	Pay, payroll and holiday records	6 years after the end of the tax year (holiday records: the holiday year)	Deleted	HMRC; Working Time Regulations 1998 reg. 9A
H4	DBS checks	We do not keep a copy of a certificate beyond 6 months from issue. The certificate number, date, level and result are kept with H2	Deleted with H2	DBS Code of Practice
H5	Right to work checks	2 years after employment ends	Deleted	Immigration, Asylum and Nationality Act 2006
H6	Bank details for pay or expenses	6 years after the person leaves	Deleted	HMRC
H7	Support presence (last time Support was open)	Only the latest time is kept	Overwritten	Sharing enquiries fairly

Money, donations and governance

Ref	Record	How long	Then	Reason
M1	Accounting records: invoices, payments, refunds, payment and lesson money logs	6 years after the end of the financial year	Deleted	Charities Act 2011 s.131; HMRC
M2	Donations and Gift Aid declarations	6 years after the end of the financial year of the last donation claimed under the declaration	Deleted	HMRC Gift Aid rules
M3	Annual accounts, trustee minutes, governing documents	Permanently	Kept	Charity law
M4	Grant agreements and reports	6 years after the grant ends, or longer if the funder requires	Deleted	Funder terms

Other records

Ref	Record	How long	Then	Reason
O1	Newsletter list	Until you unsubscribe; we keep a note of the unsubscribe and the consent record for 3 years after	Deleted	PECR; consent evidence
O2	Website statistics	12 months (anonymous from the start)	Deleted	Service improvement
O3	Security and audit logs	2 years; file access logs and in-app notifications 12 months	Deleted	Security; accountability
O4	Error reports	90 days	Deleted	Fixing faults
O5	Secure document links	2 years after the link ends (6 years for safeguarding documents and subject access bundles); the file itself when the link ends	Deleted	Accountability
O6	Requests about personal information and data protection complaints	6 years after we finish; identity documents 30 days after the request closes, or sooner once checked	Deleted	UK GDPR accountability
O7	Backups	Copies on the server 3 days; off-site daily copies 35 days and weekly copies 12 weeks	Deleted	Recovery; deleted records leave the backups within this time
O8	Temporary copies made to fix data	30 days	Deleted	Data minimisation
O9	Files that no record points to	90 days after they are set aside	Deleted	Data minimisation

Holds and disposal

A record due for deletion is kept while a complaint, claim, subject access request, investigation or safeguarding concern is open, with the reason recorded. Digital records are deleted securely and paper is cross-cut shredded. Each disposal is logged. The data protection lead (our Chief Executive Officer, [email protected]) reviews this schedule every year and checks that our systems follow it.

Last updated: 19/10/2026.