Data Retention Policy May 2018
This is the Data Retention Policy of The Malvern Kitchen Studio Ltd.
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
Jane Williams, the Data Controller, 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.
Jane Williams is responsible for determining (in accordance with this Policy) whether to retain or dispose of specific documents.
Jane Williams may delegate the operational aspect of this function to Gary Williams.
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 This will reduce the risk that it will become inaccurate, out of date or irrelevant.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 Jane Williams without delay.
Date created: 10th May 2018
Date of review: 9th May 2019
Appendix 1: Document retention schedule
|
Type of record |
Retention period |
Where is it stored? |
Reason |
Method of deletion |
|
Sales enquiries |
|
|
|
|
|
Quotations |
3 years from date sent |
Hard copy at Studio, server + back up |
for future reference should customer return |
Shred + deletion |
|
Sales Confirmations |
|
|
|
|
|
Sales records |
7 years from date of placing order |
Hard copy at Studio, server + back up |
Financial record and reference for customer warranties or issues |
Shred + deletion |
|
Employment records: |
|
|
|
|
|
PAYE records |
7 years from end of fiscal year |
Hard copy at Studio, server + back up |
Legal |
Shred + deletion |
|
Unsuccessful candidates |
6 months after last action |
Hard copy
|
Legal |
shred |
|
Accident report forms |
3 years after last action |
Hard copy |
Legal |
shred |
|
Employees that left the business: emergency contacts and bank account details |
Delete immediately after making final salary payment |
Hard copy |
Legal |
shred |
|
Pay & tax: pay deductions, tax forms, payroll, loans |
6 years after last action |
Hard copy at Studio, server + back up |
Legal |
|
|
Records of formal disciplinary actions in employee file |
6 years after last action |
Hard copy |
Employment contract |
shred |
|
Records of formal grievances in employee file |
6 years after last action |
Hard copy |
Employment contract |
shred |
|
Commercial contracts: |
|
|
|
|
|
Contracts with suppliers |
6 years after last action |
Hard copy |
Supply contract confirming terms |
shred |
|
Contracts signed as a deed |
12 years after last action |
Hard copy |
Legal |
shred |
|
Guarantees and indemnities |
i.e. state the term of the guarantee plus 6 years |
Hard copy + some e copies |
legal |
Shred + deletion |
|
Purchase orders and invoices |
7 years after last action |
Hard copy at Studio, server + back up |
Reference to customer’s orders for warranties/issues |
Shred + deletion |
|
Tax and Accounting Records: |
|
|
|
|
|
Tax returns |
10 years from end of fiscal year |
Hard copy |
Audit |
shred |
|
Accounting & financial management information |
6 years from end of fiscal year |
Hard copy |
audit |
shred |
|
Operational records: |
|
|
|
|
|
Vehicles leased |
7 years |
Hard copy at Studio, server + back up |
audit |
Shred + deletion |
|
Closed circuit television recordings |
10days |
Hard drive |
Insurance/crime reporting |
Automatic deletion |
|
Fire Risk Assessments |
i.e. Retain until superseded |
Hard copy + e copy |
legal |
Shred + deletion |
|
Policies/Procedures |
7 years |
Hard copy at Studio, server + back up |
legal |
Shred & deletion |
|
Complaints |
6 years from end of fiscal year |
Hard copy |
legal |
shred |
|
Building (i.e. lease/deeds) |
Destroy 6 years after property is no longer occupied |
Hard copy |
legal |
shred |
|
Maintenance contracts |
15 years from last action |
Hard copy |
legal |
shred |
|
Website |
Life of company |
On line |
advertising |
Deletion from server |
|
Property plans and surveys - leased |
25 years |
Hard copy |
legal |
shred |
|
Insurance schedules |
10 years after last action |
Hard copy |
legal |
shred |
|
Pat tests, fire hazard tests |
6 years from last action |
Hard copy |
legal |
shred |
|
Register of members |
Life of company |
Hard copy at Studio, server + back up + online |
legal |
Shred + deletion from register |
|
Memorandum of association |
Life of company |
Hard copy at Studio, server + back up online |
legal |
Shred + deletion from register |
|
Register of directors and secretaries |
Life of company |
Hard copy at Studio, server + back up online |
legal |
Shred + deletion from register |
|
Employer’s liability insurance certificates |
Life of company |
Hard copy at Studio, server + back up |
legal |
Shred + deletion |
|
Intellectual property records: |
|
|
|
|
|
Copyright material |
50 years from expiry |
Hard copy at Studio, server + back up |
legal |
Shred + deletion |
|
Email records: |
|
|
|
|
|
Email correspondence |
Archive emails after 6 years |
Hard copy at Studio, server + back up |
Record of correspondence – legal, customer support, warranty |
Deletion from server |
Print