Data Retention Policy

This is the Data Retention Policy of Chiltern Development Training Ltd (CDT).

Introduction

We recognise that in the running of our business, we collect and process personal data from a variety of sources. This personal information is collated in several different formats including letters, emails, legal documents, employment records, operations records, images and statements. The personal data is held in both hard copy and electronic form.

Aims of the policy

Our business will ensure that personal data that we hold is kept secure and that it is held for no longer than is necessary for the purposes for which it is being processed. In addition, we will retain the minimum amount of information to fulfill our statutory obligations and the provision of goods or/and services – as required by the data protection legislation, including the General Data Protection Regulation (GDPR).

Retention

This retention policy (with its schedule), is a tool used to assist us in making decisions on whether a particular document should be retained or disposed of. In addition, it takes account of the context within which the personal data is being processed and our business practices.

Decisions around retention and disposal should be taken in accordance with this policy.

Where a retention period of a specific document has expired, a review should always be carried out prior to the disposal of the document. This does not have to be time-consuming or complex. If a decision is reached to dispose of a document, careful consideration should be given to the method of disposal.

Responsibility

KARENA HILL is responsible to keep this retention schedule up to date, to reflect changing business needs, new legislation, changing perceptions of risk management and new priorities for our business.

KARENA HILL is responsible for determining (in accordance with this Policy) whether to retain or dispose of specific documents.

KARENA HILL may delegate the operational aspect of this function to any trusted member of CDT Ltd.

Any team member should inform KARENA HILL if in any doubt about minimum retention periods or if the retention of a document is necessary for a potential claim.

Disposal

We must ensure that personal data is securely disposed of when it’s no longer needed. This will reduce the risk that it will become inaccurate, out of date or irrelevant.

The method of disposal should be appropriate to the nature and sensitivity of the documents concerned and includes:

  • Non-Confidential records: place in waste paper bin for disposal
  • Confidential records: shred documents
  • Deletion of Computer Records
  • Transmission of records to an external body
  • Cloud storage

 

The table below contains the retention period that we have assigned to each type of record. This will be adhered to wherever possible, although it is recognised that there may be exceptional circumstances which require documents to be kept for either shorter or longer periods.

Exceptional circumstances should be reported to KARENA HILL without delay.

Date created: 22.5.2018

Date of review: 22.5.2019

Appendix 1: Document retention schedule

Type of record Retention period Where is it stored? Reason Method of deletion
         
Employment records:        
PAYE records 3 years from end of fiscal year COMPUTER LEGAL DELETION
Medical and health records 30 years after employment ceases COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Unsuccessful candidates 6 months after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Accident report forms 3 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Employment records: redundancy, equal opportunities; health & welfare records 6 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Employees that left the business: emergency contacts and bank account details Immediately after final payment COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Pay & tax: pay deductions, tax forms, payroll, loans 6 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Records of formal disciplinary actions in employee file 6 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Records of formal grievances in employee file 6 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Commercial contracts:        
Contracts with suppliers 6 years after last action COMPUTER

HARD COPY

END OF CONTRACT [SPECIFY]
Contracts signed as a deed 12 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Guarantees and indemnities term of the guarantee plus 6 years COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Purchase orders and invoices 7 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

 

Tax and Accounting Records:

       
Tax returns 10 years from end of fiscal year COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Accounting & financial management information 6 years from end of fiscal year COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Stock transfer forms and share certificates 20 years from purchase COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Marketing records:       [SPECIFY]
Mailing lists 1 year after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Operational records:       [SPECIFY]
Vehicles 6 years after end of financial year to which they relate] COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Fire Risk Assessments Retain until superseded COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Policies/Procedures 7 years COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Complaints 6 years from end of fiscal year COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Building (i.e. lease/deeds) Destroy 6 years after property is no longer occupied] COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Maintenance contracts 15 years from last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Website FAQs 6 months from last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Property plans and surveys 25 years COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Insurance schedules 10 years after last action COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Register of members Life of company COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Memorandum of association Life of company COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Register of directors and secretaries Life of company COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Employer’s liability insurance certificates Life of company COMPUTER

HARD COPY

LEGAL DELETION

CONFIDENTIAL SHREDDING

Email records:        
Email correspondence Archive emails after 6 months COMPUTER

HARD COPY

LEGAL OFFICE 3665 ARCHIVE TOOLS
         
Training Records        
Bucks County Council 6 MONTHS COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING

MBDRA 4 years COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING

MOT TESTERS 6 YEARS COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING

MOT MANAGERS 6 YEARS COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING

MOT ANNUAL CPD 1 year after last action COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING

MIDAS/PATS 4 years COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING

ONLINE COURSES 2 years COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING

FIRST AID COURSES 3 years COMPUTER

HARD COPY

EXPIRED DELETION

CONFIDENTIAL SHREDDING