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Alex Don't know how much information you are talking about and I don't know how your information systems are designed, however, probably easier said than done, but on option could be when it comes to destruction, only destroy the index information (that is the identifiying information that would connect individual to information) provided sufficient index information is destroyed then you can continue to hold the remaining information (indefinitely if necessary) for your analytical business needs. If not, my other suggestion would be to extend the retention of the information on a cascading scale. Your extending the retention to produce the analytical results (business requirement), however you have a action plan over X period to remove all index information so that after this point no personal information will be retained beyond the original retention date (in other words you are working towards a solution - but cannot happen overnight). If challenged it would show "intention" to rectify -v- disproportionate effort. Hope this helps Have fun! Regards Trish Bailey ________________________________ From: The UK Records Management mailing list [mailto:[log in to unmask]] On Behalf Of Hodge, Alex Sent: 05 August 2008 15:54 To: [log in to unmask] Subject: Children's personal data and analytical reports Dear all, To make a change from the e-mails about the job evaluation and other hot topics, I'm asking a question regarding children's personal data and analytical reports (!). In Children's Services a section currently analyses personal data on school pupils to create reports. The reports cover such things as pupil attainment, areas of deprivation. Some are used to create demographic information. This requirement comes from the Department of Children's Schools and Families. There is a requirement to analyse pupil data from previous years to show trends, etc. The data used to create the reports currently comes from live systems, such as EMS. As the pupil data comes from a live system, there will become a time when the data will need to be disposed of following retention schedules. However, there will still be a requirement to access data, even after the retention period, for these analytical reporting purposes. How do we reconcile the need to dispose of data following retention periods so we meet principle 5 of Data Protection Act against the need to access some data for analytical purposes? I'm currently thinking of how best to take this forward and would be interested in hearing from other local authorities who have looked at this issue. Best wishes, Alex Alex Hodge Corporate Records Manager Corporate Information Unit Bolton Council Room 320 Town Hall Bolton BL1 1RU Tel: (01204) 338714 Mobile: 07824541290 Fax: 01204 380043 This e-mail and any attached files are confidential and may also be legally privileged. They are intended solely for the intended addressee. If you are not the addressee please e-mail it back to the sender and then immediately, permanently delete it. Do not read, print, re-transmit, store or act in reliance on it. This e-mail may be monitored by Bolton Council in accordance with current regulations. This footnote also confirms that this e-mail message has been swept for the presence of computer viruses currently known to Bolton Council. However, the recipient is responsible for virus-checking before opening this message and any attachment. Unless expressly stated to the contrary, any views expressed in this message are those of the individual sender and may not necessarily reflect the views of Bolton Council. http://www.bolton.gov.uk -------------------------------------------------------------------------------------------------------------------- This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the originator of the message. Any views expressed in this message are those of the individual sender, except where the sender specifies and with authority, states them to be the views of Telford & Wrekin Council. The content of this email has been automatically checked in conjunction with the relevant policies of Telford & Wrekin Council.