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!




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 Hodge

Corporate Records Manager

Corporate Information Unit

Bolton Council


Room 320

Town Hall

Bolton BL1 1RU


Tel: (01204) 338714

Mobile: 07824541290

Fax: 01204 380043



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