GDPR – DATA RETENTION POLICY WITH SCHEDULE
This is the Data Retention Policy of Optimum Forklift Training Services
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, training 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).
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.
Clifford Hickton 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. Clifford Hickton is responsible for determining (in accordance with this Policy) whether to retain or dispose of specific documents.
Clifford Hickton may delegate the operational aspect of this function to Joanna Gray. Joanna Gray should inform Clifford Hickton if in any doubt about minimum retention periods or if the retention of a document is necessary for a potential claim.
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 This will reduce the risk that it will become inaccurate, out of date or irrelevant.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 Clifford Hickton without delay.
Date created: 13/09/2019
Date of review: 13/09/2020
Appendix 1: Document retention schedule
Type of record Retention period Where is it stored? Reason Method of deletion
Medical and health records 6 years after employment ceases File Cabinate (LOCKED) Contained within training records shredding
Accident report forms 3 years after last action File Cabinate (LOCKED) LEGAL Shredding
Contracts with suppliers 6 years after last action Hard Drive Supply contract Deletion from Hard drive
Purchase orders and invoices 7 years after last action Online Accounts Accounting/HMRC Deletion
Tax and Accounting Records:
Tax returns 10 years from end of fiscal year Hard Drive Audit Deletion
Accounting & financial management information 6 years from end of fiscal year Hard Drive Audit Deletion
Mailing lists 1 year after last action Cloud Server To assist with audit Deletion
Operational Recordings Destroy same day as training. Mobile Phone Feed back driving errors whilst training Deletion
Fire Risk Assessments Retain until superseded Hard Drive Accessibility Deletion
Policies/Procedures 7 years Folder in office Accessibility Shredding
Complaints 6 years from end of fiscal year Hard Drive Accessibility Deletion
Employer’s liability insurance certificates Life of company Office Wall Can be identified by anyone Shredding
Email correspondence [Archive emails after 6 months] Online Exchange Future correspondence Microsoft Exchange 2019