SAR archive and backup retrieval and retention procedure

This procedure applies where [school name] archives or backs up personal information that may fall within the scope of a subject access request. Retrieval methods, retention periods and disposal controls must reflect the school's technologies, records-management arrangements and legitimate operational needs.

Responsibilities

The [sar coordinator role] is responsible for coordinating the application of this procedure and ensuring that the relevant archive and backup arrangements are considered.

Locating and retrieving information

The school must have procedures for finding and retrieving personal information held in electronic archives or backups where that information may fall within a subject access request.

Archive and backup retrieval may be more complicated than retrieving information from live systems. The school must nevertheless use the same effort to find information for a subject access request as it would use to find archived or backed-up information for its own purposes.

Use the school's applicable archive and backup retrieval methods to locate and retrieve relevant personal information. Record each restoration or search activity in [retrieval activity record location].

Retention of archived and backed-up information

The school must define retention periods for archived and backed-up information in [archive backup retention schedule location]. Archived or backed-up information must not be retained indefinitely merely because it might have a future use.

Retention periods must reflect the school's technologies, records-management arrangements and legitimate operational needs. Apply the defined retention period to each relevant archive or backup category.

End of retention

When the defined retention period ends, dispose of the archived or backed-up information in accordance with the school's retention schedule and disposal arrangements, or review it against those arrangements where disposal is not immediately possible.

Maintain the relevant record of restoration, search, disposal or review activity in accordance with [school record management arrangement].