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Document Storage & Retention Policy

Centre: ACLAS Global International Education Group

Effective: 2025-07-05 | Review Date: 2026-07-05

Status: Draft — pending signature. This page was last reviewed on 2026-10-29. The scheduled review date of 2026-07-05 has passed; the policy will be updated with the signatory name and signature date once signed by the Centre Director.

Policy Owner: Centre Director

1. Purpose

This policy defines how the Centre stores, protects, retains, and disposes of documents and records relating to learners, staff, and Centre operations. It ensures compliance with OTHM requirements and applicable data protection legislation.

2. Scope

This policy covers all documents and records in any format—physical (paper) or electronic (digital files, Moodle records, emails)—that contain information about learners, staff, or the Centre's operations.

3. Retention Schedule

Learner Records

| Record Type | Minimum Retention |

|-------------|:-----------------:|

| Enrolment forms and learner agreements | 3 years after certification or withdrawal |

| Learner assessment plans | 3 years after certification |

| Learner assessment submissions (all units) | 3 years after certification |

| Unit Assessment Records (marksheets) | 3 years after certification |

| Assessor feedback records | 3 years after certification |

| IQA sampling reports relating to the learner | 3 years after certification |

| EQA reports | Permanently |

| Learner registration and certification records | Permanently |

| Appeals and complaints records | 3 years after resolution |

| Reasonable adjustment records | 3 years after certification |

| RPL assessment records | 3 years after certification |

| Safeguarding records | Minimum 7 years (legal advice) |

Staff Records

| Record Type | Minimum Retention |

|-------------|:-----------------:|

| CVs, qualification certificates, appointment letters | 3 years after termination |

| Employment contracts | 7 years after termination |

| CPD records and IDPs | 3 years after termination |

| Performance review records | 3 years after termination |

Centre Records

| Record Type | Minimum Retention |

|-------------|:-----------------:|

| Current policy documents | While in effect |

| Superseded policy documents | Permanently (archived) |

| Governance meeting minutes | Permanently |

| Standardisation meeting minutes | 3 years |

| Financial records | 7 years (tax requirement) |

Where a different period is required by applicable law, the longer period applies.

4. Storage — Physical Documents

  • Physical documents are stored in locked filing cabinets in the Centre's office at 1401 Pennsylvania Ave, Suite 105, Wilmington, DE 19806.
  • The office is secured when unoccupied.
  • Access to learner and staff files is restricted to authorised personnel.
  • Documents are protected from fire, water, and environmental damage to the extent reasonably practicable.

5. Storage — Electronic Documents

  • Learner submissions, grades, and feedback are stored within the Moodle LMS, which is hosted on secure, password-protected servers with SSL encryption.
  • Administrative records (enrolment forms, marksheets, policies) are stored on password-protected cloud storage with access controls.
  • Access is managed through role-based permissions: Administrators, Managers, Tutors/Assessors, IQAs (read-only access to learner work), and Learners (own work only).
  • The Moodle LMS and all cloud storage are backed up automatically at least daily. Backups are stored off-site or in a separate cloud region.
  • Anti-virus and firewall protection are maintained on all Centre devices.

6. Security of Current Learner Assessments

  • Learner submissions in progress are stored securely within Moodle.
  • Once assessed and certified, learner work is archived.
  • No learner work is disposed of before the end of the retention period.

7. Disposal

At the end of the retention period:

  • Physical documents are shredded.
  • Electronic documents are permanently deleted from all systems, including backups.
  • A disposal log is maintained for sensitive records.
  • Documents subject to an ongoing investigation, complaint, appeal, or legal hold are not disposed of until the matter is resolved.

8. Responsibilities

  • Centre Director: Overall responsibility for compliance.
  • Administrative Coordinator: Day-to-day management of physical and electronic filing, backup verification, and disposal.
  • All staff: Responsibility for storing records in the appropriate location and reporting any security concerns.

9. Policy Review

This policy is reviewed annually.