Part V — Data, Technology and the Portal
Chapter 21 — Document and Database Management
Chapter 21
Document and Database Management
Every credential issued under the WISE system is only as reliable
as the record that supports it. This chapter sets out the
retention periods, storage media, backup arrangements, and
integrity requirements that an Affiliated School must observe in
respect of the records it holds on behalf of its students and of
WEQSC.
21.1 General Principle
21.1.1
Records governed by this Framework fall into two categories:
Physical Records, held in original
paper or other tangible form; and
Digital Records, held in electronic
form on a Non-Corruptible Medium.
21.1.2
Physical Records are subject to a retention period of five
years. Digital Records are subject to a retention period of
unlimited duration. Both are subject to the modification
governance rules in Chapter 22 and the data protection rules
in Chapter 24.
21.1.3
Where a record exists in both physical and digital form, the
Digital Record is the authoritative version. Where any
discrepancy exists between the two, the Digital Record
prevails, subject to the modification procedure in
Chapter 22.
21.1.4
Records held on behalf of WEQSC are subject to WEQSC's
oversight. Records held by the School for its own purposes,
not governed by this Framework, are outside the scope of this
chapter.
21.2 Categories of Records
21.2.1
The following categories of records are governed by this
chapter:
| Category | Examples | Retention |
|---|
| Student Records |
Admission forms, identity documents, enrolment details, parent contact details, contact history |
Physical: 5 years. Digital: unlimited. |
| Academic Records |
Internal Assessment marks, project submissions, practical record books, examination results, grade calculations |
Physical: 5 years. Digital: unlimited. |
| Examination Records |
Invigilator reports, seal-opening records, attendance registers, incident reports, submitted scripts (as required) |
Physical: 5 years. Digital: unlimited. |
| Attendance Records |
Daily attendance registers, monthly summaries, exemption records |
Physical: 5 years. Digital: unlimited. |
| Welfare Records |
Safeguarding records, mental health records, disability adjustment records, medical exemptions |
Physical: 5 years. Digital: unlimited. |
| Financial Records |
Fee receipts, bank statements, audit reports, invoices to and from WEQSC |
Physical: 5 years. Digital: unlimited. |
| Governance Records |
Board minutes, conflict of interest declarations, delegation records, succession plans |
Physical: 5 years. Digital: unlimited. |
| Compliance Records |
Audit reports, corrective action plans, grievance registers, branding compliance records |
Physical: 5 years. Digital: unlimited. |
| Teacher Records |
Qualification certificates, teaching register, induction records, professional development records |
Physical: 5 years. Digital: unlimited. |
21.2.2
A record is governed by this chapter regardless of whether it
is held at the School's premises, at the School's premises
under a separate arrangement, at an off-site location
controlled by the School, or in the Portal.
21.3 Physical Record Retention
21.3.1
Every Physical Record must be retained for a period of five
years from the date of its creation or receipt, whichever is
later.
21.3.2
Where a record relates to an ongoing matter — for example, an
open grievance, an unresolved audit finding, or a pending
appeal — the five-year period does not begin to run until the
matter is closed.
21.3.3
Where a record relates to a matter in litigation or under
investigation, the record must be retained for the duration
of the matter and for any period thereafter required by the
applicable law or by WEQSC.
21.3.4
Physical Records must be stored in a manner that preserves
their legibility, protects them from loss, damage, or
unauthorised access, and permits their prompt retrieval.
21.3.5
On the expiry of the five-year retention period, a Physical
Record may be securely destroyed — by shredding, incineration,
or another method that renders the record irrecoverable —
provided that a Digital Record of the same information has
been preserved in accordance with Section 21.4.
21.3.6
Where no Digital Record exists at the time of expiry of the
five-year period, the Physical Record must be digitised before
destruction, and the Digital Record retained indefinitely.
The digitisation must be certified by a member of the School's
staff and recorded in the Portal.
21.4 Digital Record Retention
21.4.1
Every Digital Record must be retained for an unlimited period.
There is no time at which a Digital Record may be deleted,
destroyed, or permitted to become unreadable.
21.4.2
Digital Records must be held on a
Non-Corruptible Medium, being a
Hard Disk Drive (HDD), Solid-State Drive (SSD), USB storage
device, optical disc (DVD or equivalent), or other medium
approved by WEQSC from time to time, and not being any
volatile or transient storage medium.
21.4.3
Digital Records must be held in a format that is:
- Non-proprietary or otherwise readable using publicly available software at the time of audit;
- Encrypted in accordance with Chapter 25;
- Free from dependence on a single vendor, operating system, or platform; and
- Capable of being migrated to a successor medium without loss of content or integrity.
21.4.4
The School must maintain, at all times, at least two offline
backups of its Digital Records, on separate physical media,
stored in separate physical locations within the School's
control or in a location notified to WEQSC.
21.4.5
The School must test the readability of each offline backup
at least once per Academic Session, and must record the
result of the test in the Portal.
21.4.6
Where a backup is found to be unreadable, incomplete, or
otherwise defective, the School must create a replacement
backup within thirty days and must record the fact in the
Portal.
21.4.7
Digital Records must be migrated to a new medium before the
medium on which they are currently held reaches the end of
its useful working life, as indicated by the manufacturer or
by industry practice. Migration must be verified and recorded
in the Portal.
21.5 WISE Server Backup
21.5.1
In addition to the School's own backups, WEQSC maintains a
centralised backup of all Digital Records submitted to the
Portal, on WEQSC's own infrastructure.
21.5.2
The WISE server backup is a secondary copy. It does not relieve
the School of its obligations under Section 21.4.
21.5.3
Where a School loses a Digital Record as a result of hardware
failure, natural disaster, or similar event, it may request
restoration from the WISE server backup. Restoration is
ordinarily provided free of charge for the first request in
any twelve-month period, and on payment of a fee for
subsequent requests.
21.5.4
Where a School requests restoration under Section 21.5.3, the
fact of the loss and the fact of the restoration are recorded
in the School's compliance record, and may be considered at
audit as evidence of the adequacy of the School's own backup
arrangements.
21.6 Record Integrity
21.6.1
Records must be maintained in a form that preserves their
integrity, meaning that:
- The record is a faithful representation of the information it purports to record;
- The record has not been altered except through the modification procedure in Chapter 22;
- Where the record has been modified, the modification is recorded in the audit trail; and
- The record remains readable and retrievable throughout the retention period.
21.6.2
A School must not:
- Delete, alter, or obscure any record, in whole or in part, without WEQSC approval;
- Create a copy of any record that differs in any material respect from the original;
- Hold any record on a storage medium that does not satisfy Section 21.4.2; or
- Represent a record as authoritative where it is not the version most recently approved by WEQSC.
21.6.3
A breach of Section 21.6.2 is a Critical Finding under
Chapter 28, and may constitute grounds for Suspension under
Chapter 29.
21.7 Record Retrieval
21.7.1
The School must be able to retrieve any record within its
retention period, in response to a request from WEQSC, the
Local Education Authority, a court, or a student or parent
exercising a right of access under Chapter 24.
21.7.2
Retrieval must ordinarily be possible within five business
days of a request. Where a request requires retrieval of a
large number of records or records held in an off-site
backup, the School must notify the requester of the extended
period and must retrieve the records within twenty business
days.
21.7.3
A School that is unable to retrieve a record within the
applicable period, whether by reason of loss, corruption, or
inadequate retrieval arrangements, commits a Breach. The
matter is treated as a Major Finding where the loss is
material or the failure affects multiple records.
21.8 Ownership of Records
21.8.1
Student Records and Academic Records are held by the School
in trust for the student to whom they relate, subject to the
School's obligations under this Framework.
21.8.2
The student, or the student's parent or guardian where the
student is a minor, is entitled to obtain a copy of the
Student Record at any time, on written request and on
payment of any reasonable copying or administrative charge.
21.8.3
Where a School ceases to operate, whether by closure,
insolvency, or de-affiliation, Student Records must be
transferred to WEQSC in accordance with Chapter 29.
21.8.4
Nothing in this section affects any right of WEQSC to access
records for the purposes of audit, verification, or
compliance under this Framework.
21.9 Compliance and Audit
21.9.1
Compliance with this chapter is verified at the annual digital
audit under Chapter 28.
21.9.2
At audit, the School must produce:
- A register of the categories of records held, with the retention period applicable to each;
- Evidence of the storage medium and location of each category of Digital Record;
- Evidence of the offline backups and their most recent readability tests;
- A record of any data loss in the preceding twelve months, with the action taken; and
- A record of any digitisation undertaken under Section 21.3.6.
21.9.3
Failure to produce the documents in Section 21.9.2 is a Major
Finding.
21.10 Breach — Consequences
21.10.1
A Breach of any provision of this chapter is subject to the
audit regime in Chapter 28 and, where applicable, to the
suspension and termination regime in Chapter 29.
21.10.2
The following are classified as indicated:
| Breach | Classification |
|---|
| Deletion, alteration, or concealment of a record without WEQSC approval |
Critical |
| Loss of a Digital Record by reason of inadequate backup or storage |
Major (Critical if material and systemic) |
| Holding records on a storage medium that does not comply with Section 21.4.2 |
Major |
| Failure to test offline backups as required by Section 21.4.5 |
Minor (Major if repeated) |
| Failure to migrate records before end of medium life |
Minor (Major if loss results) |
| Failure to retrieve a record within the applicable period |
Major if material |
| Failure to produce the audit documents in Section 21.9.2 |
Major |
| Physical Record destroyed before its five-year retention period |
Major |
21.10.3
Nothing in this chapter displaces the School's right of appeal
under Chapter 35.
Further Resources
- Record register template —
wise.weqsc.org/forms/record-register
- Backup readability test log —
wise.weqsc.org/forms/backup-test
- Digitisation certification form —
wise.weqsc.org/forms/digitisation
- Retention period guidance —
wise.weqsc.org/retention
- Approved storage media list —
wise.weqsc.org/storage-media