Two kinds of record, two retention periods
An institution keeps two different kinds of record about every certificate it grants:
- The record of the award: which certificate was granted to whom, for what, on which date, with which result, and whether it was later corrected or withdrawn. This is what a verification request concerns, and graduates rely on it throughout their working lives.
- The supporting documentation: applications, attendance sheets, examination scripts, correspondence. It explains how the award was decided and is generally required only for a limited period, for appeals and audits.
Retention schedules treat the two differently, and institutional policy should do the same.
Registrar guidance: keep the academic record permanently
In the United States, the American Association of Collegiate Registrars and Admissions Officers (AACRAO) publishes a guide to the retention and disposal of student records. Institutional schedules based on it, such as those published by D'Youville University and Duke University, list the academic record and the transcript as records to be kept permanently, together with graduation lists and original grade sheets. The same schedules set shorter periods for much of the supporting documentation.
US law: FERPA
The Family Educational Rights and Privacy Act (FERPA) does not set a general retention period for education records. It does set two limits. An institution may not destroy education records while a request to inspect and review them is outstanding (34 CFR 99.10(e)), and the record of disclosures it must keep for each student has to be kept for as long as the education records themselves (34 CFR 99.32).
The GDPR: no longer than necessary
In the European Union and the European Economic Area, the General Data Protection Regulation requires personal data to be kept in a form that permits identification of individuals for no longer than is necessary for the purposes for which it is processed: the principle of storage limitation, in Article 5(1)(e). Longer storage is permitted for archiving in the public interest, scientific or historical research, or statistical purposes, subject to the safeguards of Article 89(1).
For an institution, this means stating the purpose of each record. Being able to confirm, for as long as a graduate may need it, that a certificate was granted is a clear purpose for the record of the award. It is a far weaker basis for retaining every examination script. The retention periods should be confirmed with the institution's data protection officer.
Spain: a national register of official degrees
In Spain, Real Decreto 1002/2010 established the Registro Nacional de Titulados Universitarios Oficiales, a public register of official university degrees maintained by the ministry responsible for universities. Graduates may consult it and authorise others to verify their degrees. The register covers official degrees only, so an institution's own qualifications and short courses remain its responsibility to record and confirm.
A practical retention schedule
The periods below are a starting point, to be adapted with the institution's own legal advice, not a rule:
| Record | Suggested period | Rationale |
|---|---|---|
| Register of certificates granted (recipient, award, date, result, serial) | Permanently | Graduates rely on it; registrar guidance keeps academic records permanently |
| Corrections and withdrawals, with their reasons | As long as the certificate record | A verification response must explain a change of status |
| The public halves of the signing keys | As long as any certificate they signed | Required to check earlier signatures |
| Supporting documentation (applications, scripts, attendance) | The institution's schedule, usually years rather than decades | Required for appeals and audits, then no longer necessary |
| Access and audit logs | The period set by the security policy | Required to investigate misuse |
What changes when certificates are digital
A digital certificate does not remove the need for a register; it makes the register the authoritative source. If the verification page is the proof, it must continue to respond for as long as the certificate matters, which makes the provider's retention policy part of the institution's own. Institutions should ask any provider what happens to verification if the contract ends.
In Emitcert, each certificate is a fixed record: its wording is copied in when it is granted and signed, and withdrawal is the only subsequent change, recorded with its date and reason. Every action is written to an audit trail that cannot be edited. When an organisation closes its account, the certificates it granted continue to verify. For how the rest of the process fits together, see how to issue verifiable digital certificates.
Frequently asked questions
Does FERPA require schools to keep transcripts permanently?
No. FERPA sets no general retention period. It prohibits destroying records while a request to inspect them is pending. Permanent retention of the academic record is a recommendation of registrar guidance such as AACRAO's, not a FERPA requirement.
May old certificate records be deleted under the GDPR?
The GDPR requires personal data to be kept no longer than necessary for its purpose. Confirming that a certificate was granted is a lasting purpose for the record of the award; supporting documents usually have a shorter one. The periods should be set with the data protection officer.
What happens to verification if a training provider closes?
That depends on who keeps the register. It should be agreed in advance who will answer verification requests: a successor body, an archive, or the provider hosting the verification pages. In Emitcert, certificates continue to verify after an organisation closes its account.
Sources
The factual statements on this page rest on the documents listed below. Legislation and services change; consult the current version before relying on any of them.
- D'Youville University: Guide for retention and disposal of records (based on AACRAO guidance)
- Duke University Archives: Student records retention guidelines
- 34 CFR § 99.10 (FERPA), Legal Information Institute, Cornell Law School
- 34 CFR § 99.32 (FERPA), Legal Information Institute, Cornell Law School
- Regulation (EU) 2016/679 (GDPR), Article 5, legislation.gov.uk (as adopted)
- Regulation (EU) 2016/679 (GDPR), Article 89, legislation.gov.uk (as adopted)
- Real Decreto 1002/2010 on official university degrees, Boletín Oficial del Estado
- Ministerio de Ciencia, Innovación y Universidades: Consulta al Registro Nacional de Titulados Universitarios Oficiales
