Privacy Notice – Retention

Icon

1. ABOUT THIS NOTICE

 

1.1 Our corporate information, records and data are important to how we conduct and manage our business and business relationships.

1.2 There are legal and regulatory requirements and other contractual retention obligations, which require us to retain certain data, usually for a specified amount of time. We also retain data to help our business operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to our business.

1.3 We are committed to complying with our duties by retaining those records securely and ensuring that they are destroyed in a timely and confidential manner.

 

2. SCOPE

2.1 This notice covers all data that we hold or have control over. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings and CCTV recordings. It applies to both personal data and non-personal data. In this notice we refer to this information and these records collectively as “data”.

2.2 This notice covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage.

2.3 This notice explains the differences between our formal or official records, disposable information, confidential information belonging to others, personal data and non-personal data. It also gives guidance on how we classify our data.

 

3. TYPES OF DATA

3.1 Formal or official records. Certain data is more important to us and is therefore listed in our Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business.

3.2 Disposable information. Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record. Examples may include:

 

  • Duplicates of originals that have not been annotated.
  • Preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record.
  • Books, periodicals, manuals, training binders, which are retained primarily for reference purposes.
  • Spam and junk mail.

 

3.3 Personal data. Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed.

 

4. RETENTION PERIODS

4.1 Formal or official records. Any data that is part of any of the categories listed in the Retention Schedule attached, will be retained for the amount of time indicated in the Retention Schedule. We will not retain a record beyond the period indicated in the Retention Schedule, unless a valid business reason (or notice to preserve documents for contemplated litigation or other special situation) calls for its continued retention.

4.2 Disposable information. The Retention Schedule will not set out retention periods for disposable information. This type of data should only be retained as long as it is needed for business purposes. Once it no longer has any business purpose or value it will be disposed of securely.

4.3 Personal data. We retain personal data for no longer than is necessary for the purposes for which it is processed. Where data is listed in the Retention Schedule, we have taken into account the principle of storage limitation and balanced this against our requirements to retain the data.

 

5. SPECIAL SITUATIONS

5.1 There will be occasions when certain records are relevant to litigation or disputes, government investigation, financial audit, compliance audit or other situations.

5.2 In these cases, we will preserve and not delete, dispose, destroy, or change those records, including emails and other electronic documents, until it is determined that those records are no longer needed. In these situations, we will suspend the requirements in the Retention Schedule and preserve the integrity of the electronic files or other format in which the records are kept.

5.3 We will also suspend any routine data disposal procedures in connection with certain other types of events, such as our merger with another organisation or the replacement of our information technology systems.

 

6. OTHER RELEVANT POLICIES

6.1 This notice should be read in conjunction with our other policies and procedures in force from time to time, including without limitation our:

 

  • Information security policy
  • Information handling and storage policy
  • Privacy standard
  • Confidentiality policy.
  • And other IT, security and data related policies, which are available on request or to view

 

This privacy notice may change from time to time so we recommend that you review it periodically. This version of the privacy notice was last updated on 6th June 2018.

Retention Schedule

 

Information relating to Individuals we Support and their families

Type of Record/Document
Statutory Retention /Best Practice
Retention Period
All records relating to the Individual we Support
5 years after the Individual has left the service.

Personal information can be archived from 12 months of the original date of the document.

All data relating to family members
5 years after the Individual has left the service.

Personal information can be archived from 12 months of the original date of the document.

Marketing Information

Type of Record/Document
Statutory Retention /Best Practice
Retention Period
All marketing data
3 years from the date of input into our database
After the expiry of the 3-year period for all other data, the data is moved to our archive on an annual basis.
All archived data is reviewed annually and permanently deleted three years after the archive date.

Human Resources Information

Type of Record/Document
Statutory Retention /Best Practice
Retention Period
Annual appraisal/assessment Annual leave records Application forms, interview notes and reference details
Destroy after 6 years Destroy after 6 years Evidence of identity/right to work – 2 years from the date the employment ends
All other information – destroy after 6 years
Information about disciplinary matters Legal advice received
Destroy after 6 years
Destroy after duration of action for which advice received plus 7 years
Pre-employment information
Personal data relating to an unsuccessful applicant to be kept for at least 6 months after which it can deleted.
If the applicant becomes an employee, pre-employment information to be kept as part of the employee’s HR file and to be retained for at least 6 years after employment has ended.
Sickness record
Statutory sick pay records and certificates
Destroy after 6 years
Destroy not less than 6 years after the end of the financial year to which they relate.
Statutory maternity pay records and certificates
Destroy not less than 3 years after the end of the financial year to which they relate
Unpaid leave/special leave records
Destroy 6 years after the date when the end of the leave period
Personnel file and training records
Destroy 6 years after the event to which the record relates
References given
Destroy 6 years from reference received/end of employment
Summary of record or service (name/position/dates of employment)
Destroy 10 years from end of employment

Operational and System Information

Type of Record/Document
Statutory Retention /Best Practice
Retention Period
CCTV footage
3 months accessible then archive, destroy after 1 year
Equipment inspection records
Varies according to equipment
Firewall log files
3 months accessible then archive, destroy after 1 year
Project records and papers
Destroy project records 7 years from the completion of the project

Accounting and Financial Information

Type of Record/Document
Statutory Retention /Best Practice
Retention Period
Accounting Records
6 years
Annual Depreciation
6 years
Application to write off value
Permanent for lifetime of the company
Cash Book List
10 years
Cheques and Remittance Advice
6 years
Consolidated Accounts
Permanent for lifetime of the company
Cost control ledger analysis
6 years
Disposal of Assets
Permanent
Income Tax and NI Returns
6 years
Ledger Sheets
10 years
6 years
Purchase Requisitions
6 years
Taxation
6 Years to a maximum of 15 years
Wages / Salary
6 years

Corporate

Type of Record/Document
Statutory Retention /Best Practice
Retention Period
Accident books
Retain for 3 years from the date of event unless the accident/incident leads to hazardous substances (COSHH) or asbestos in which case records must be retained for 40 years.
Approved minutes and supporting internal and external papers for specific decisions
Destroy 7 years after the month in which the decision was made
Contracts/agreements
Destroy 12 years after conclusion of contract
Insider lists
5 years from the date on which the insider list was created or updated (whichever is later)
Legal advice received
Destroy after duration of action for which advice received plus 7 years
Legal documents (all written agreements e.g. including agreements with Commissioners, supplier contracts, HP agreements, equipment rentals)
For contracts: 6 years after expiry of the contract/agreement
For deeds: 12 years after expiry of the deed
Agenda,Minutes of Board meetings
10 years from the date of the relevant meeting
Company Books/statutory registers
Permanent retention
Title deeds and property related documents
Destroy 12 years after expiry of the deed or expiry of lease

Subscribe to HFHC! Newsletter

Scroll to Top