This schedule supplements section 9 of our Data Protection (GDPR) Policy. ICO registration: ZC042466.
1. Purpose
This schedule sets out how long Luma keeps each type of record, why, where it is held, and how it is securely deleted. It puts into practice the UK GDPR 'storage limitation' principle and our obligations under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, Keeping Children Safe in Education (KCSIE), the DBS Code of Practice, HMRC and Home Office requirements, and the HEART Academies Trust Framework.
2. Retention schedule
1. Candidates and Workers
| Record | Examples | Retention period | Reason / basis | Where held · secure deletion |
|---|---|---|---|---|
| Candidates not placed | CV, application form, interview notes, contact details | 12 months from last meaningful contact; then deleted unless the candidate asks to stay registered | Conduct of Employment Agencies Regs 2003 (min. 1 year); data minimisation | Hello Edun · permanent deletion, reviewed monthly |
| Placed Workers – recruitment and compliance file | Application, interview record, references, qualifications/TRN check, prohibition check, overseas checks, declarations, consent | 6 years after the end of the last assignment | Evidence of safer recruitment for Customers, Value Match, auditors and potential legal claims (Limitation Act 1980) | Hello Edun and OneDrive · secure deletion at end of period |
| DBS certificate information | Disclosure content, copies of certificates | Not kept beyond 6 months after the suitability decision. Afterwards only date, certificate number, type (enhanced + barred list), Update Service status and decision are recorded | DBS Code of Practice; KCSIE | Matrix eBulk / Hello Edun · copies deleted; summary record kept with Worker file |
| Right to work evidence | Passport, visa, share code check result | Duration of engagement + 2 years | Home Office right to work guidance | Hello Edun · secure deletion |
| Identity and address checks | ID documents, proof of address | Kept with Worker file (6 years after last assignment); copies of documents minimised where a verification record suffices | Evidence of checks; KCSIE | Hello Edun · secure deletion |
| Occupational health | Fitness-to-work outcome | Outcome kept with Worker file; detailed health questionnaire held by ACI under its own retention policy | Special category data – minimised | ACI / Hello Edun |
| Training records | Safeguarding, Prevent, SEND and CPD certificates, training log | 6 years after the last assignment | Spec 4.40.3 training log; evidence of competence | Hello Edun / OneDrive |
| Safeguarding concerns and allegations about a Worker | Allegation records, investigation notes, outcomes, LADO referrals | Until the Worker's normal pension age or 10 years from the allegation, whichever is longer. Malicious allegations removed; unsubstantiated or false allegations handled per KCSIE Part 4 | KCSIE Part 4; Safeguarding Vulnerable Groups Act | Restricted folder (DSL access only) |
2. Pay, timesheets and finance
| Record | Examples | Retention period | Reason / basis | Where held · secure deletion |
|---|---|---|---|---|
| Timesheets and booking confirmations | Approved e-timesheets, booking emails, compliance checklists sent to schools | 6 years after the end of the financial year | Invoice audit (Spec 4.37.11); VAT and HMRC records | QUBA DynamiQ / email · deleted after period |
| Payroll and PAYE records | Payslips, pay rates, tax, NI, pension, AWR pay parity, holiday pay | 6 years after the end of the tax year | HMRC (min. 3 years); pension auto-enrolment; employment claims | QUBA payroll bureau |
| Invoices, credit notes and accounts | Customer invoices, rebate calculations, supplier invoices | 6 years after the end of the financial year | Companies Act 2006; VAT records | QUBA / accounting records |
3. Customers, Framework and suppliers
| Record | Examples | Retention period | Reason / basis | Where held · secure deletion |
|---|---|---|---|---|
| Customer contracts and Call-Offs | Terms of business, Call-Off Contracts, rate cards, implementation plans | 6 years after the contract ends | Contractual and audit requirements | OneDrive |
| Framework MI and rebate returns | Monthly MI, KPI data, rebate returns, supplier review notes | Duration of Framework + 6 years | Value Match / HEART audit rights | OneDrive |
| Complaints and enquiries logs | Complaint records, actions and outcomes | 6 years after closure | Spec 4.34; continuous improvement; legal claims | OneDrive |
| Customer contact data | Names, roles, emails, phone numbers of school staff | While the business relationship continues + 2 years | Legitimate interests | Hello Edun / Microsoft 365 |
| Supplier records | Contracts and due diligence for QUBA, Matrix, ACI, Hello Edun and others | 6 years after the relationship ends | Contractual / audit | OneDrive |
4. Luma's own staff (as the team grows)
| Record | Examples | Retention period | Reason / basis | Where held · secure deletion |
|---|---|---|---|---|
| Employee personnel files | Contract, appraisal, training, disciplinary records | 6 years after employment ends | Employment claims; Limitation Act | OneDrive (restricted) |
| Unsuccessful applicants for Luma roles | CVs, interview notes | 6 months after the decision | Equality Act claim period | Hello Edun / OneDrive |
5. Governance
| Record | Examples | Retention period | Reason / basis | Where held · secure deletion |
|---|---|---|---|---|
| Data breach and incident log | Breach records, ICO reports, BCDR incident log | 6 years | UK GDPR Art. 33(5); accountability | OneDrive (restricted) |
| Data subject requests | Access, erasure and rectification requests and responses | 2 years after the request is closed | Accountability | OneDrive |
| Marketing contacts | Newsletter / campaign lists | Until consent is withdrawn or 2 years without engagement | PECR; consent | Email platform |
3. How the schedule is applied
Retention periods start from the trigger shown (e.g. end of last assignment, end of tax year). Where several periods apply to one record, the longest applies.
Secure deletion: records are permanently deleted from Hello Edun, OneDrive/Microsoft 365 and email, including deleted-items and recycle-bin folders. Our suppliers (QUBA, Matrix, ACI) delete data under their own data processing agreements and retention policies. Luma holds no paper records; any paper that arises is shredded.
Annual review: each year the Data Protection Officer reviews all systems against this schedule, deletes records that have passed their retention date, and records that the review has taken place.
Legal hold: deletion is suspended for any record linked to an ongoing safeguarding investigation, complaint, legal claim, audit or regulator request until the matter is closed.
Individuals' rights: requests for erasure are considered against this schedule. Records that we are legally required to keep (e.g. payroll, safeguarding allegations) are retained, and the individual is told why.
Security: all systems are protected by individual secure logins and multi-factor authentication wherever supported, and Luma holds Cyber Essentials certification (valid until September 2027).
Note: retention periods reflect current UK legislation and guidance as at November 2026 and will be updated whenever these change.