Student files, evidence and retention

Student-specific retention rule

Document 2 normally requires records throughout sponsorship, then until the earlier of one year after sponsorship ends or a compliance officer’s subsequent examination and approval. Specific exceptions and other legal retention needs must also be checked. A visit during active sponsorship does not end the obligation.

Use a file index rather than copying sensitive evidence into every working document. The index should point an authorised reviewer to the authoritative record, its date, its owner and any known limitation.

Suggested evidence architecture

Organise the record around decisions: why the place was offered, why sponsorship was approved, how enrolment was cleared, how engagement was monitored and how later changes were dealt with. This makes gaps visible without imposing a single storage product.

Set access according to role. An academic tutor may need to record an engagement concern without needing access to identity documents or detailed financial evidence. Test whether an authorised substitute can retrieve an item when the usual staff member is away.

• Create a consistent file reference and identify the record owner.
• Index admission evidence, status checks, engagement records, contact history and report confirmations as applicable.
• Record correction history rather than overwriting an unexplained error.
• Document the retention trigger and any separate reason for keeping an item longer.
• Apply a controlled deletion review after the relevant retention period.
• Test a sample retrieval and record inaccessible, incomplete or duplicate items.

Keep working tools proportionate

A local audit worksheet can track whether evidence exists without storing passports, share codes or medical details. Use references and anonymised case labels in exported reports. The evidence itself belongs in the institution’s approved record system.

Do not treat a retention reminder as an automatic deletion instruction. A complaint, investigation, litigation hold or another legal obligation may alter the decision. Record who checked those issues before disposal.