Dear Gateshead Council Information Requests Team,

Thank you for your response dated 13 March 2026 (ref: CC67437).

I have two points to raise.

1. Incomplete disclosure – retention schedule entries (Question 1)

The document attached to your response (Corporate Retention Policy, February 2025) is a framework policy explaining how retention periods should be determined. It does not itself contain the specific retention schedule entries I requested for the categories listed in Question 1 (pupil files, SEND records, exclusions, EOTAS, alternative provision, and related finance records).

The policy refers to a 'Common Corporate Retention Periods' document at Appendix 1, described as a separate PDF. That document was not provided.

Please provide Appendix 1 – the Common Corporate Retention Periods document – along with any service-specific ROPA entries or equivalent retention schedule entries for the categories listed in Question 1 of my original request. If specific retention periods for education records are not contained in the corporate document, please provide whatever service-level documentation holds those entries.

2. Question 2 – retention schedule in force 2010 to 2014

Your response states that it has not been possible to confirm whether a formal retention schedule was in place between 2010 and 2014, and suggests the Education Department may have been following IRMS guidance for schools.

I would like to clarify: my request was directed at records held by the local authority, not at maintained schools. The IRMS toolkit for schools is not a substitute for the council's own documented retention arrangements. The council, as a data controller and public authority, would have been subject to records management obligations throughout this period.

Please confirm:
a) whether any documented retention policy, schedule, or guidance existed for council-held education records during 2010–2014 – even informally or in draft form; and
b) who conducted the search for this information, and what sources or systems were checked.

If you are unable to locate any documentation, please confirm that in writing as part of your formal response, rather than by way of suggestion.

3. Question 4 – council oversight of maintained schools

Your response states that there is no role for the council in ensuring maintained schools comply with records management, on the basis that schools are their own data controller.

While I accept that maintained schools are separate data controllers for the purposes of data protection law, my question concerned the council's recorded guidance and oversight role more broadly – including under the Education Act framework and the council's function as the responsible local authority. This includes any guidance issued by the council to schools regarding SARs, educational records requests, and retention expectations.

Please confirm whether the council holds any recorded guidance, circulars, or communications issued to maintained schools on these matters. If no such documentation exists, please confirm that explicitly.

Yours faithfully,
Jamie Halliday