Data Retention Policy

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Context and overview

Key details

  • Policy prepared by:​​​​ Nayfe Slusjan, Head of Technology & Design, The TYF Group Ltd
  • Approved by board / management on: ​14/05/18.
  • Policy became operational on:​​ 14/05/18.
  • Next review date:​​​​ 10/01/19.​​

 

 

Purpose

The purpose of this Policy is to ensure that necessary records and documents are adequately protected and maintained and to ensure that records that are no longer needed by The TYF Group Ltd or are of no value are discarded at the proper time.  This Policy is also for the purpose of aiding employees of The TYF Group Ltd in understanding their obligations in retaining electronic documents – including email, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.

 

Policy

This Policy represents the The TYF Group Ltd’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

 

Administration

Attached as Appendix A is a Data Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of The TYF Group Ltd and the retention and disposal of electronic documents.  The Data Retention Policy Administrator (the “Administrator”) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Data Retention Schedule is followed.  The Administrator is also authorized to: make modifications to the Data Retention Schedule from time to time to ensure that it is in compliance with U.K laws and includes the appropriate document and data categories for The TYF Group Ltd; monitor U.K laws affecting data retention; annually review the data retention and disposal program; and monitor compliance with this Policy.

 

Suspension of Record Disposal In Event of Litigation or Claims

In the event The TYF Group Ltd is served with any summons or request for documents or any employee becomes aware of a governmental investigation or audit concerning The TYF Group Ltd or the commencement of any litigation against or concerning The TYF Group Ltd, such employee shall inform the Administrator and any further disposal of documents shall be suspended until shall time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

 

Applicability

This Policy applies to all physical records generated in the course of The TYF Group Ltd’s operation, including both original documents and reproductions.  It also applies to the electronic documents described above.

This Policy was approved by the Board of Directors of The TYF Group Ltd on 14/05/18.

 

APPENDIX A  – DATA RETENTION SCHEDULE

The Data Retention Schedule is organized as follows:

SECTION TOPIC

  1. Accounting and Finance
  2. Contracts
  3. Corporate Records
  4. Customer Records
  5. Correspondence and Internal Memoranda
  6. Electronic Documents
  7. Grant Records
  8. Insurance Records
  9. Legal Files and Papers
  10. Miscellaneous
  11. Payroll Documents
  12. Pension Documents
  13. Personnel Records
  14. Property Records
  15. Tax Records
  16. Contribution Records
  17. Programs & Services Records
  18. Fiscal Sponsor Project Records

 

1. ACCOUNTING AND FINANCE

Record Type

Retention Period

Accounts Payable ledgers and schedules

6 years plus current year

Accounts Receivable ledgers and schedules

6 years plus current year

Annual Audit Reports and Financial Statements

6 years plus current year

Annual Audit Records, including work papers and other documents that relate to the audit

6 years plus current year

Annual Plans and Budgets

6 years plus current year

Bank Statements and Canceled Checks

6 years plus current year

Employee Expense Reports

6 years plus current year

General Ledgers

6 years plus current year

Interim Financial Statements

6 years plus current year

Notes Receivable ledgers and schedules

6 years plus current year

Investment Records

6 years plus current year

Credit card records (documents showing customer credit card number)

N/A

 

2. CONTRACTS

Record Type

Retention Period

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation)

7 years after expiration or termination

3. CORPORATE RECORDS

Record Type

Retention Period

Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, bylaws, annual corporate reports)

Permanent

Licenses and Permits

Permanent

4. CUSTOMER RECORDS

Record Type

Retention Period

Enquiry Forms

7 years

Activity Registration Forms

7 years

Medical Declaration Forms

7 years

Session Record Forms

7 years

Feedback Forms

7 years

Incident Report Forms

7 years

Accident Report Forms

7 years

Equipment Hire Agreements

7 years

Retail History Records

7 years

Retail Shipping Records

7 years

Retail Billing Records

7 years

Marketing Opt-in Email address

Until Opt-out

Child welfare concerns that The TYF Group Ltd refers onto children’s social care or the police. For example this would include concerns about physical, sexual, emotional or neglect of a child, disclosures from a child about being abused or information from a third party which might suggest a child is being abused; concerns about a parent or another adult that uses The TYF Group Ltd, or a young person who has been abused by another young person. The referral should be acknowledged in writing by children’s social care and The TYF Group Ltd keeps this on file.

Records should be kept for 6 years after the last contact with the service user unless any of the exemptions apply or if your organisation is required to comply with any other statutory requirements.

Child welfare concerns that The TYF Group Ltd decide, after consultation, do not necessitate a referral to children’s social care or the police. In such circumstances The TYF Group Ltd should make a record of the concern and the outcome. For example where a child has been bullied, overly pushy parents or a very distressed child where the distress is unrelated to child abuse. 1 year after the child/adult concerned ceases to use the service unless the child or adult are continuing to use The TYF Group Ltd.
Concerns about people (paid and unpaid) who work with children and young people, for example, allegations, convictions, disciplinary action, inappropriate behaviour towards children and young people. For example where an employee has breached the code of conduct, a record of the behaviour, the action taken and outcome should be recorded. Personnel files and training records (including disciplinary records and working time records) are retained for 6 years after employment ceases. However the records should be retained for a longer period if any of the following apply:

  • There were concerns about the behaviour of an adult who was working with children where s/he behaved in a way that has harmed, or may have harmed, a child;
  • The adult possibly committed a criminal offence against, or related to, a child;
  • The adult behaved towards a child in a way that indicates s/he is unsuitable to work with children. In such circumstances records should be retained at least until the adult reaches normal retirement age, or for 10 years if that is longer.

5. CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document they pertain to or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

  1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within two years. Some examples include:
  • Routine letters and notes that require no acknowledgment or followup, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
  • Form letters that require no follow-up.
  • Letters of general inquiry and replies that complete a cycle of correspondence.
  • Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
  • Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
  • Chronological correspondence files.

 

Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.

  1. Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently.

 

6. ELECTRONIC DOCUMENTS

  1. Electronic Mail: Not all email needs to be retained, depending on the subject matter.
  • All email—from internal or external sources—is to be deleted after 6 years.
  • Staff will strive to keep all but an insignificant minority of their email related to business issues.
  • The TYF Group Ltd will archive email for 3 years after the staff has deleted it, after which time the email will be permanently deleted.
  • All The TYF Group Ltd business-related email should be downloaded to a service center or user directory on the server.
  • Staff will not store or transfer The TYF Group Ltd-related email on non-work-related computers except as necessary or appropriate for The TYF Group Ltd purposes.
  • Staff will take care not to send confidential/proprietary The TYF Group Ltd information to outside sources.
  • Staff with more than 2GB in their email account will be unable to send or receive messages until the size of their account is reduced. Staff will be notified by the IT Department as their account size approaches 2 GB.

 

  1. Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on the subject matter.
  • PDF documents – The length of time that a PDF file should be retained should be based upon the content of the file and the category under the various sections of this policy. The maximum period that a PDF file should be retained is 6 years. PDF files the employee deems vital to the performance of his or her job should be printed and stored in the employee’s workspace.
  • Text/formatted files – Staff will conduct annual reviews of all text/formatted files (e.g., Microsoft Word documents) and will delete all those they consider unnecessary or outdated. After five years, all text files will be deleted from the network and the staff’s desktop/laptop. Text/formatted files the staff deems vital to the performance of their job should be printed and stored in the staff’s workspace.
  1. Web Page Files: Internet Cookies
  • All workstations: Browsers should be scheduled to delete Internet cookies once per month.

 

The TYF Group Ltd does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

Each day The TYF Group Ltd will run a digital backup copy of all electronic files (including email) on The TYF Group Ltd’s servers, as specified in the The TYF Group Ltd Disaster Recovery Plan. This backup is a safeguard to retrieve lost information within a one-year retrieval period should documents on the network experience problems. The digital backup copy is considered a safeguard for the data retention system of The TYF Group Ltd, but is not considered an official repository of The TYF Group Ltd records. All monthly and yearly backups are stored off-site according to The TYF Group Ltd’s Disaster Recovery Policy.

In certain cases a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

7. GRANT RECORDS

Record Type

Retention Period

Original grant proposal

7 years after completion of grant period

Grant agreement and subsequent modifications, if applicable

7 years after completion of grant period

All requested HMRC/grantee correspondence including determination letters and “no change” in exempt status letters

7 years after completion of grant period

Final grantee reports, both financial and narrative

7 years after completion of grant period

All evidence of returned grant funds

7 years after completion of grant period

All pertinent formal correspondence including opinion letters of counsel

7 years after completion of grant period

Report assessment forms

7 years after completion of grant period

Documentation relating to grantee evidence of invoices and matching or challenge grants that would support grantee compliance with the grant agreement

7 years after completion of grant period

Pre-grant inquiry forms and other documentation for expenditure responsibility grants

7 years after completion of grant period

Grantee work product produced with the grant funds

7 years after completion of grant period

 

8. INSURANCE RECORDS

Record Type

Retention Period

Annual Loss Summaries

10 years

Audits and Adjustments

3 years after final adjustment

Certificates Issued to The TYF Group Ltd

Permanent

Claims Files (including correspondence, medical records, injury documentation, etc.)

Permanent

Group Insurance Plans – Active Employees

Until Plan is amended or terminated

Group Insurance Plans – Retirees

Permanent or until 6 years after death of last eligible participant  

Inspections

3 years

Insurance Policies (including expired policies)

Permanent

Journal Entry Support Data

7 years

Loss Runs

10 years

Releases and Settlements

25 years

9. LEGAL FILES AND PAPERS

Record Type

Retention Period

Legal Memoranda and Opinions (including all subject matter files)

7 years after close of matter

Litigation Files

1 year after expiration of appeals or time for filing appeals

Court Orders

Permanent

Requests for Departure from Data Retention Plan

10 years

10. MISCELLANEOUS

Record Type

Retention Period

Consultant’s Reports

2 years

Material of Historical Value (including pictures, publications)

Permanent

Policy and Procedures Manuals – Original

Current version with revision history

Policy and Procedures Manuals – Copies

Retain current version only

Annual Reports

Permanent

11. PAYROLL DOCUMENTS

Record Type

Retention Period

Employee Deduction Authorizations

4 years after termination

Payroll Deductions

Termination + 7 years

P45 and P60 Forms

Termination + 7 years

Garnishments, Assignments, Attachments

Termination + 7 years

Labor Distribution Cost Records

7 years

Payroll Registers (gross and net)

7 years

Time Cards/Sheets

2 years

Unclaimed Wage Records

6 years

12. PENSION DOCUMENTS AND SUPPORTING EMPLOYEE DATA

General Principle: Pension documents and supporting employee data shall be kept in such a manner that The TYF Group Ltd can establish at all times whether or not any pension is payable to any person and if so the amount of such pension.

Record Type

Retention Period

Retirement and Pension Records

Permanent

13. PERSONNEL RECORDS

Record Type

Retention Period

Commissions/Bonuses/Incentives/Awards

7 years

Employee Earnings Records

Separation + 7 years

Employee Handbooks

1 copy kept permanently

Employee Medical Records

Separation + 6 years

Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records)

6 years after separation

Employment Contracts – Individual

7 years after separation

Employment Records – Correspondence with Employment Agencies and Advertisements for Job Openings

3 years from date of hiring decision

Employment Records – All Non-Hired Applicants (including all applications and resumes  whether solicited or unsolicited, results of post-offer, pre-employment physicals, results of background investigations, if any, related correspondence)

2-4 years (4 years if file contains any correspondence which might be construed as an offer)

Job Descriptions

3 years after superseded

Personnel Count Records

3 years

Disclosure and Barring Service (DBS) Certificate

Duration of employment

14. PROPERTY RECORDS

Record Type

Retention Period

Correspondence, Property Deeds, Assessments, Licenses, Rights of Way

Permanent

Original Purchase/Sale/Lease Agreement

Permanent

Property Insurance Policies

Permanent

15. TAX RECORDS

General Principle: The TYF Group Ltd must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of state and local income, franchise, and property tax laws.

Record Type

Retention Period

Tax-Exemption Documents and Related Correspondence

Permanent

HMRC Rulings

Permanent

Excise Tax Records

7 years

Payroll Tax Records

7 years

Tax Bills, Receipts, Statements

7 years

Tax Returns – Income, Franchise, Property

Permanent

Tax Workpaper Packages – Originals

7 years

Sales/Use Tax Records

7 years

Annual Information Returns

Permanent

HMRC or other Government Audit Records

Permanent

16. CONTRIBUTION RECORDS

Record Type

Retention Period

Records of Contributions

Permanent

The TYF Group Ltd’s or other documents evidencing terms of gifts

Permanent

17. PROGRAM AND SERVICE RECORDS

Record Type

Retention Period

The TYF Group Ltd convenings

Permanent (1 copy only)

Research & Publications

Permanent (1 copy only)

18. FISCAL SPONSOR PROJECT RECORDS

Record Type

Retention Period

Sponsorship agreements

Permanent