Record-Keeping and Retention Policy


1. Purpose

This policy defines the learner, competency demonstration, and operational records that American Professional School (APS) creates and maintains in connection with its competency-based education (CBE) professional credential programs. It specifies retention periods, security measures, and access controls to support accurate credentialing, quality assurance, auditability, and compliance with data-protection obligations.

2. Scope

This policy applies to all records created or received by APS relating to learners, competency demonstrations, credential decisions, complaints, quality reviews, and core operational activities for the Professional, Master, and Executive pathways and associated services. Training records include enrollment information, participation, competency demonstration evidence and decisions, competency judgments, and credential outcomes.

3. Principles

APS manages records according to the following principles:

  • Records are accurate, complete, and retained only as long as necessary
  • Access is limited to those with a legitimate need
  • Security measures protect confidentiality and integrity
  • Retention and disposal support both operational needs and data-protection requirements
  • Records enable verification of credentials and review of decisions when required
  • Training records are retained for a minimum of seven years and made available to learners

4. Categories of Records and Retention Periods

Record CategoryExamplesMinimum Retention PeriodNotes
Learner enrollment and identityApplication/enrollment data, contact details, eligibility informationDuration of enrollment + 3 yearsSupports program administration and follow-up
Competency demonstration evidence and decisions (training records)Submitted portfolios/work products, reviewer feedback, competency judgments, credential outcomes, participation recordsMinimum of 7 years from completion or closure of the learning eventSupports credential verification, learner requests, and potential appeals or audits. Made available to the learner.
Credential recordsIssued credential details, dates, and status10 years from date of issue (or longer if required for verification)Enables confirmation of credentials for employers or learners
Complaints and appealsFormal complaints, investigation records, outcomes, appeals3 years from closureSupports quality review and consistency
Quality assurance recordsReview notes, feedback summaries, action plans, improvement logs3 yearsSupports continuous improvement and audit
Support and adjustment recordsTechnical support logs, reasonable adjustment requests and decisionsDuration of enrollment + 3 yearsLinked to learner experience and fairness
Operational and financial recordsInvoices, payment confirmations, contracts with processors7 years (or as required by tax/accounting rules)Standard business retention
Staff and contractor records related to program deliveryRelevant training or role recordsDuration of engagement + 3 yearsSupports quality and accountability

APS retains training records for a minimum of seven (7) years and makes them available to learners upon request. Retention periods begin from the date the record is closed or the relevant activity ends, unless otherwise noted. APS may retain records longer where required by law, for active legal matters, or for legitimate credential-verification needs.

5. Certification and Credential Records

Credentials (occupational diploma and corresponding Certified designation) are issued only after a learner has demonstrated the required competencies and APS has approved completion. Credential records are created and maintained to support accurate issuance, verification, and any subsequent amendment or withdrawal.

  • Issuance occurs only after successful competency demonstration and formal approval. No credential is issued on the basis of partial completion or unverified evidence.
  • Issued credentials are recorded with the learner’s name, credential title, completion date, and unique Credential ID. These records are retained in accordance with the periods set out above and made available for verification through the APS Open Credential Verification Tool.
  • Corrections or amendments (for example, correction of a name or title error) are made only after verification of the request and are documented in the credential record.
  • Replacement credentials may be issued to the original holder upon request after identity confirmation. The original Credential ID is retained for verification continuity.
  • A credential may be withdrawn or marked invalid if an investigation under the Academic Integrity and Malpractice Policy determines that it was obtained through academic misconduct or other material breach of integrity standards. Withdrawal is documented, the verification record is updated, and the learner is notified.

All certification actions are performed under controlled access and are subject to the security, retention, and auditability requirements of this policy.

6. Security and Storage

Records are stored in secure electronic systems (with physical records, if any, kept in controlled locations). The recordkeeping system includes regular backups to protect against loss. Security measures include:

  • Access controls and authentication
  • Encryption of data in transit and at rest where feasible
  • Regular backups of the recordkeeping system
  • Protection against unauthorized access, alteration, or loss

The privacy and information security of learner records—including the roles of information input, maintenance, release, and issuance of records following learning event completion—are governed by this policy and the Privacy Policy. Systems and practices are reviewed periodically as part of APS quality and data-protection processes.

7. Access Management

Access to records is granted on a need-to-know basis:

  • Staff and contractors receive access only to the records required for their role (for example, competency demonstration, support, or quality review)
  • Access rights are reviewed when roles change or engagements end
  • Learners may request access to their own training records. APS makes these records available to learners in accordance with this policy and the Privacy Policy
  • External requests (for example, for credential verification) are handled through controlled processes that confirm legitimacy and limit disclosure to necessary information

8. Disposal

When the retention period ends and no further legitimate need exists, records are securely deleted or anonymized. Disposal methods prevent reconstruction or unauthorized recovery. Disposal actions are carried out in a manner consistent with the Privacy Policy.

9. Responsibilities

  • Academic Quality Lead: Ensures the accuracy and integrity of competency demonstration evidence, competency judgments, and credential academic records; provides input into audits of academic and training records; and supports quality review of competency demonstration documentation.
  • Operations Manager: Overall accountability for this policy, including approval of retention schedules, oversight of secure practices, system controls, and access management.
  • Staff and contractors: Create accurate records, follow access rules, and do not retain personal copies of learner or competency demonstration records beyond what is required for their role.
  • Designated system or administrative contacts: Implement technical controls, maintain backups, and support secure storage and disposal.

10. Auditability

Records are maintained in a form that supports internal review, response to learner requests, credential verification, and any external audit or quality review. Key decisions (competency demonstration outcomes, appeals, complaints) are documented with sufficient detail to understand the basis for the decision. Training records are retained for a minimum of seven years and made available to learners upon request. The Academic Quality Lead supports review of the integrity of competency demonstration and credential records during internal audits or quality reviews.

11. Review of This Policy

This policy is reviewed at least annually by the Operations Manager, with input from the Academic Quality Lead on academic and competency demonstration record requirements, to ensure retention periods, security measures, and access controls remain appropriate for APS operations and applicable legal and data-protection requirements. Updates are version-controlled and communicated to relevant staff.