GDPR – DATA RETENTION POLICY WITH SCHEDULE
The General Data Protection Regulations affects any organisation holding personal data and requires Marquis Estates to consider the legal basis on which we process personal date.
This is the Data Retention Policy of MARQUIS ESTATES.
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, application forms, telephone calls, invoices and statements.
The personal data is held in both hard copy and electronic form.
Any information provided to us will be processed in compliance with the provisions of the G D P R which came into force on the 25th May 2018
Aims and Policies of Marquis Estates
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 fulfil our statutory obligations and the provision of our services – as required by the data protection legislation, including the General Data Protection Regulation (G D P R).
Retention
This retention policy, is used to assist us in making decisions on whether a particular document should be retained or disposed off. 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 is 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 is given to the method of disposal.
Responsibility
Jonathan White 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.
Jonathan White is responsible for determining (in accordance with this Policy) whether to retain or dispose of specific documents. All storage is on the premises of Marquis Estates in a separate locked office.
Jonathan White may delegate the operational aspect of this function to Carol Brennan.
Carol Brennan should inform Jonathan White 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 is appropriate to the nature and sensitivity of the documents concerned and includes:
- Non-Confidential records: are placed in waste paper bin for disposal
- Confidential records: shred documents
- Computer Records (pERSONAL ELEMENTS DELETED)
- Burnt or compost
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 Jonathan White or Carol Brennan without delay.
Date created: June 2018 by MARY N BLOOMFIELD
Date of review: MAY 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 | Book keeping office | Legal | Shredder |
| Maternity and paternity pay records | [3] years from end of fiscal year | Book keeping office | Legal | Shredder |
| Medical and health records | [30] years after employment ceases | Book keeping office | Legal | Shredder |
| Unsuccessful candidates | [6 months] after last action | Post room
|
Legal | Shredder |
| Accident report forms | [3] years after last action | Bathroom | Legal | Shredder |
| Employment records: redundancy, equal opportunities; health & welfare records | [6] years after last action | Book keeping office | Legal | Burnt |
| Employees that left the business: emergency contacts and bank account details | [i.e. Delete immediately after making final salary payment] | Post room | Legal | Burnt |
| Pay & tax: pay deductions, tax forms, payroll, loans | [6] years after last action | Book keeping office | Legal | Shredder |
| Records of formal disciplinary actions in employee file | [6] years after last action | Post room | Reference | Shredded or burnt |
| Records of formal grievances in employee file | [6] years after last action | Book keeping office | No grievances since 2000 | Shredded or burnt |
| Commercial contracts: | ||||
| Purchase orders and invoices | [7] years after last action | Filing cabinet | Legal | Shredded or burnt |
|
Tax and Accounting Records: |
||||
| Tax returns | [10] years from end of fiscal year | Book keeping office | Audit | Shredded or burnt |
| Accounting & financial management information | [6] years from end of fiscal year | Book keeping office | Legal | Shredded or burnt |
| Marketing records: | ||||
| Mailing lists | [1] year after last action | Legal | Business | Shredded or burnt |
| Operational records: | ||||
| Vehicles | [i.e. Keep asset and depreciation records for 6 years after end of financial year to which they relate] | Filing cabinet | Legal | Shredded or burnt |
| Fire Risk Assessments | [i.e. Retain until superseded] | Main office | Legal | Shredded |
| Policies/Procedures | [7] years | Main office | Burnt | |
| Complaints | [6] years from end of fiscal year | Filing cabinet | Business | Burnt |
| Maintenance contracts | [15] years from last action | Filing cabinet | Legal & Business | |
| Website FAQs | [6] months from last action | Managers office | Issue is generally resolved upon response | Removed |
| Property plans and surveys | [25] years | Filing cabinet | Legal | Burnt |
| Insurance schedules | [10] years after last action | Filing cabinet | Legal | Burnt |
| Pat tests, fire hazard tests | [6] years from last action | Filing cabinet | Legal | Burnt |
| Employer’s liability insurance certificates | Life of company | Filing cabinet | Legal | |
| Intellectual property records: | ||||
| Copyright material | 50 years from expiry | Filing cabinet | Legal | |
| Email records: | ||||
| Email correspondence | [Archive emails after 6 months] | Filing cabinet | Business | Burnt |
Note. Filing cabinets are locked when the office is closed