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Transferring pupil records to a new school

Different parts of the authority have been getting enquiries about how GDPR affects transferring pupil records to new schools.

There seems to be some discrepancy around safeguarding concerns.

GDPR does not specify or change either the way in which schools transfer the Common Transfer File (CTF) and paper records relating to new pupils or when this should be done.

All schools must ensure that they are sending the correct files to the correct school and this must be done in a secure manner. If a school sent information relating to a pupil who was not attending the new school in September, then this potentially could be a data protection breach.

As part of the Year 6 to Year 7 transition process schools must share this information with the new school and it is appropriate to do this in a timely manner if there is every indication that the pupil will join the new school in September.

There may be exceptional circumstances where during the school holidays something happens to prevent the pupil joining the new school, but this would be rare and should be dealt with on a case per case basis.

If the information is not shared until September, this could place a huge administrative burden on the secondary schools who usually spend the period between now and the start of the new term adding information they have gathered to their CTF file and sorting through the paper records to ensure they are ready for the new pupils on the first day of term.

The pupil record should not be weeded before transfer to the Secondary school unless any of the items mentioned below have been placed on the file. It is important to remember that the information which may seem unnecessary to the person weeding the file may be a vital piece of information required at a later stage.

  • Absence notes
  • Parental consent forms for trips/outings (in the event of a major incident all the parental consent forms should be retained with the incident report not in the pupil record)
  • Correspondence with parents about minor issues
  • Accident forms (these should be stored separately and retained on the school premises until their statutory retention period is reached. A copy could be placed on the pupil file in the event of a major incident).

Primary Schools do not need to keep copies of any records in the pupil record, except if there is an ongoing legal action and then the school should keep that information until the case is closed then send the information to the new school.

Please see the Information Management Toolkit for Schools.

Contact Details

Email: dataprotection@kent.gov.uk