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Retention, legal holds and anonymisation

When a person has left your care, the law usually says how long you must keep their records. Once that time has passed, their identity can be removed (anonymised) while the care history is kept.

Where: Care → Retention, and profile → Legal holds. Who: care.retention.view; changes need care.retention.manage. Both are sensitive and are never given by ADMIN. The Retention page covers the whole organisation, not just your homes.

Anonymisation cannot be undone

Approve only after checking the preview. There is no restore.

1. Set retention policies​

No periods are provided. Retention periods are a legal decision for your organisation and country. Nothing becomes due until every category that applies to a person has a policy.

Where: Retention policies → Set (or Change) on a category.

FieldWhat to enterExample
Counts fromDischarge (the last discharge or closing date), Date of birth plus, Death (only once a death is recorded), or Recorded (access log only: each log row's own time)Date of birth plus
Years1 to 15075
Legal referenceThe law or guidance you rely onChildren's homes records guidance, 2026
NotesOptionalApproved by the trustees 12/10/2026

Select Save policy. Every change is listed under Policy changes, for example "6 Nov 2026 · Child care record: Date of birth plus + 75 years by james.cole".

The six categories​

CategoryApplies to a person whenExample policy (illustration only)
Child care recordTheir programme is anything other than elderly residentialDate of birth plus 75 years
Elderly care recordTheir programme is elderly residentialDischarge plus 8 years
HealthThey have any health recordDischarge plus 8 years
IncidentThey are named on any incidentDischarge plus 10 years
SafeguardingThey are named on a safeguarding incident, or have a safeguarding concernDischarge plus 25 years
Access logNot per person: the log of who viewed whatRecorded plus 6 years

The longest period wins​

A person is due only when all their categories have passed. The latest date counts.

Example: Grace was discharged on 1 May 2006, aged 17, with incidents and a safeguarding concern.

CategoryRuleDue
Child care recordDate of birth (14 Mar 1989) + 7514 Mar 2064
IncidentDischarge + 101 May 2016
SafeguardingDischarge + 251 May 2031
Grace is due onthe latest of these14 Mar 2064

2. Review closed records​

Where: Closed records. The list covers people who are Discharged, Deceased, Closed or Transferred out, with no open admission or enrolment. Due records are shown first.

ColumnMeaning
BeneficiaryThe number
CategoriesWhich categories apply
StateDue, Not yet or Blocked
Due onThe date it becomes (or became) due
WhyThe reasons it's blocked or not yet due
StateTypical reasons in WhyWhat to do
Blocked"No retention policy for Health"Set the missing policy.
Blocked"Child care record: date of birth unknown"Record the date of birth in Party, or use a discharge-based policy.
BlockedAn active legal holdWait for the hold to be lifted.
BlockedThe person has another active role (for example they are now an employee or a donor)Their identity is still in use; they can't be anonymised.
Not yetThe due date is in the futureNothing.
Not yet"… is kept until death plus 5 years"A death-based policy waits for a recorded death.
Due(none)Can be proposed.

Preview: "What would change"​

Select What would change on a row to see the preview "If BEN-000006 were anonymised":

  • Changed: for example the name becomes "Anonymised person #…"; dates of birth and death are cut to the year; contacts, addresses, identifiers and relationships are removed; the alias, photo and identifying origin details are cleared.
  • Kept: for example admissions, care plans, notes, incidents, safeguarding and health history, unchanged but no longer linked to a name.

3. Propose a disposal​

  1. Tick the Due records to include.
  2. Optionally tick Also delete access-log rows older than the access-log policy. This needs an Access log policy. It deletes old log rows for the whole organisation, not just these people.
  3. Select Propose disposal (2). The page reminds you: "A different user must approve the proposal. Anonymisation cannot be undone."

Proposing changes nothing yet. Only records that are Due can be proposed ("Beneficiary … is not due for disposal").

4. Approve or reject (a second person)​

Where: Disposals and certificates. The proposer cannot decide their own proposal: "A disposal must be decided by someone other than who proposed it".

ButtonWhat happens
Approve and anonymiseAsks "Approve disposal 4? 2 record(s) will be anonymised. This cannot be undone." Each person is checked again; anyone no longer due (for example because a legal hold was placed since) is Skipped, with the reason. The others are anonymised, and their status becomes Anonymised.
RejectAsks "Why is disposal 4 rejected?" Nothing changes.

The certificate​

Each decided disposal stays on the page as a certificate:

Disposal 4
Proposed by james.cole 6 Nov 2026 09:10 · Approved by leah.brown 6 Nov 2026 11:42
Policies applied: CHILD_CARE_RECORD DOB+75; INCIDENT DISCHARGE+10; ...
Access-log rows deleted: 18 204
BEN-000006 · due 2026-05-01 · Anonymised
BEN-000011 · due 2026-02-14 · Skipped (legal hold placed)

It records who proposed and approved, when, the policies used and the result for each person. It never records the identity that was removed.

A legal hold stops a person's record being anonymised, for example during a court case, an inquiry or a complaint.

Where: profile → Legal holds. Who: care.retention.manage.

  1. Enter the Reason (required) and a Reference (optional). Example: "Historic abuse inquiry", reference "IICSA-2026-114".
  2. Select Place legal hold. The list shows "Historic abuse inquiry (IICSA-2026-114) · placed by james.cole 6 Nov 2026", marked Active.

To lift a hold: a different user selects Lift and answers "Why is this legal hold lifted?", for example "Inquiry closed, letter dated 01/12/2026". The person who placed a hold cannot lift it: "A legal hold must be lifted by someone other than who placed it".

Lifting a hold doesn't make the record due on its own. All the retention rules must still be met.

An anonymised record shows "This record has been anonymised under the retention policy."

What anonymisation does not do​

  • Names written inside free-text notes, document titles and earlier history entries are not rewritten.
  • Backups are not touched.
  • Other modules (finance, HR) are not affected.
  • A person with another active role in the organisation is never anonymised.
  • Nothing happens automatically. There is no scheduled disposal. Every disposal is proposed and approved by two people.

Example: a full run with two people​

  1. James sets policies for all six categories (once).
  2. James opens Closed records: BEN-000006 is Due; BEN-000009 is Blocked ("No retention policy for Health"). He sets the Health policy, and BEN-000009 now shows Not yet.
  3. James selects What would change on BEN-000006 and reads the preview.
  4. James ticks BEN-000006, ticks the access-log option, and selects Propose disposal (1).
  5. Leah signs in, opens Disposals and certificates, checks the proposal and selects Approve and anonymise.
  6. The certificate shows BEN-000006 Anonymised and the number of access-log rows deleted.