Data Retention and Erasure Policy

Data retention and erasure policy guidance

How should I use my data retention and erasure policy?

Your company’s data retention and erasure policy is designed to provide your company with a defined data retention schedule. You should fill in the template using your company’s particulars and store this document with your other GDPR documents, for safekeeping.

Will I need to update my data retention and erasure policy?

Yes. It is a crucial aspect of your company’s GDPR compliance to ensure that you have a clearly defined policy in place, dictating data retention and erasure. You should review this policy at least every 6 months and amend as necessary to ensure your company remains GDPR compliant.

Data retention and erasure policy introduction

Our approach towards data retention

This policy is designed to ensure Earth Friendly Concrete By Wagner does everything within its power to adequately protect, maintain and store data. This policy has also been developed to ensure that any data, documents or records that have no further use or value to Earth Friendly Concrete By Wagner are disposed of in line with our regulatory obligations and relevant company policy.

Employees should consult our data retention and erasure policy, to develop an understanding of our company’s obligations relating to the ways in which we retain data or electronic documents. These documents may include, but are not limited to:

  • Emails
  • Word Documents
  • Spreadsheets
  • PDF documents
  • Web files
  • Sound files
  • Videos

Personal data must never be kept for longer than it is needed. Consequently, employees should utilise our company’s data retention schedule as a guide to understanding [COMPANY NAME]’s general retention period time for various data categories that have been assigned based upon the purpose of the data. In line with our regulatory obligations, all data that is no longer necessary should be deleted and all copies must be destroyed in line with our data erasure schedule.

Data retention schedule administration

This data retention schedule documents the maintenance, retention and disposal guidelines relating to any and all records our company holds. It must be reviewed and accordingly amended on a regular basis to ensure data storage and erasure processes are adhering to Earth Friendly Concrete By Wagner’s wider data retention policy approach.

There will be times when data may need to be retained longer than the pre-defined amount of time permitted. Circumstances in which our policy will need to be suspended may include, but are not limited to:

  • Legal proceedings
  • Regulatory investigations
  • If criminal activity is suspected or alleged
  • If relevant data concerns a company or organisation in receivership or liquidation
  • If the relevant data is of historical importance to the owner or controller

In the event of legal proceedings, criminal activity or investigations, Earth Friendly Concrete By Wagner and its employees must retain data that relates to the situation and could serve to aid the company’s case or position, liability or amount involved. If such a situation may occur during the lifetime of this policy, Earth Friendly Concrete By Wagner will inform all staff of the policy’s suspension as it relates to said situation.

Data retention and erasure policy guidance

Earth Friendly Concrete By Wagner has developed its data retention policy in line with the following data retention schedule:

DepartmentFunction
01Accounting and finance data
02Contract data
03Corporate records
04Correspondence and internal memoranda
05Personal data
06Electronic data
07Insurance data
08Legal data
09Miscellaneous data
10Personnel records and data
11Tax records and data

01. Accounting and finance data

RecordRetention period
Company financial statements and annual audit reportsPermanent
Annual audit records (including relevant documents)Annual audit records (including relevant documents) 7 years after audit completion
Company bank statements7 years
Cancelled cheques7 years
Employee expense reports7 years
Interim company financial statements7 years
Credit card records2 years
Annual plans and company budgets2 years

Any and all items that display customer bank details or credit card information must be kept under secure conditions when not in immediate use. This includes keeping printed records in a locked desk drawer or filing cabinet.

If Earth Friendly Concrete By Wagner determines it is necessary to keep a document that displays customer financial details beyond a retention period of 2 years, all identifying details or financial information as it relates to any customer must be redacted or removed from the document in question.

02. Contract data

RecordRetention period
All company contractsRetention period 7 years after expiration or termination
All correspondence relating to contractsRetention period 7 years after expiration or termination

03. Corporate records

RecordRetention period
Corporate recordsPermanent
Licenses and permitsPermanent

For the purpose of this schedule and corresponding policy, ‘corporate records’ should be defined to include anything relating to:

  • Meeting minutes
  • Signed minutes of the board
  • Signed minutes of any committees
  • Record of incorporation
  • Articles of incorporation
  • Annual corporate reports

04. Correspondence and internal memoranda

The vast majority of correspondence and internal memoranda must be retained to match the period of time as the document or data to which they relate. Examples may include an email relating to a contract – in which case the email in question would be expected to be retained for a period of 7 years after the expiration of the corresponding contract.

Bearing this in mind, Earth Friendly Concrete By Wagner recommends that all correspondence and internal memoranda as it relates to a company project be kept with said project as part of a project-wide file.

Company correspondence or internal memoranda unrelated to documents that have a defined retention period, should be securely destroyed at an earlier time depending upon which of the following two categories it corresponds:

Category 1

Category 1 correspondence or internal memoranda includes any and all data as it relates to routine processes. Category 1 correspondence and internal memoranda generally do not carry any significant consequences and should be disposed of with 2 years.

Examples of category 1 correspondence and internal memoranda may include (but are not limited to):

  • Notes of appreciation or thanks
  • Plans for meetings
  • Forms or letters that do not require a follow up
  • General enquiries that have been settled
  • Chronological correspondence data
  • Complaints requesting a specific action that have already been addressed and carry no further value
  • Correspondence relating to inconsequential subject matter

All copies of internal office correspondence should be read and destroyed as per this policy unless that correspondence includes data or content that must be retained as part of a wider project.

Category 2

Category 2 correspondence or internal memoranda includes non-routine information or correspondence that is likely to have a consequential impact upon the company or its employees. Category 2 correspondence and internal memoranda should be retained on a permanent basis.

05. Personal data

There will be times when Earth Friendly Concrete By Wagner and its employees must retain and/or delete personal data in line with its legal obligations.

For the purposes of this data retention and erasure policy, ‘personal data’ can be defined as any identifying information as it relates to an individual. We never keep personal data for longer than is necessary for the purpose in which that data was collected. All personal data as defined within the following categories should be deleted based upon this retention and erasure schedule:

RecordRetention period
Data relating to customer devices2 years after the account is closed
Data relating to use of our company website2 years after the account is closed
Any data collected when registering with our website2 years after the account is closed
Data collected and submitted as part of any profile creation processes2 years after the account is closed
Data submitted for the purpose of subscribing to email marketing activitiesIndefinitely (or until customer unsubscribes)
Data submitted as part of online service deliveryIndefinitely
Data relating to any subscriptions2 years after the account is closed
Data posted in a public area on our company website2 years after the post
Any other personal data2 years after the post
Data contained in communications sent through the website2 years after the post

Earth Friendly Concrete By Wagner reserves the right to retain any and all documents (both electronic and print) containing personal data to the extent our company is required by law to do. We will also retain documents containing personal data if we have reason to believe said documents could be relevant to legal proceedings, or to establish and/or exercise our own legal rights.

Our company will organise backups of our database and all of the electronic data held within our company server(s). Backup activities should include all data that relates to current users or customers, alongside any document or dataset relating to one of the aforementioned reasons as outlined within this data retention and erasure policy. Earth Friendly Concrete By Wagner does this to ensure that lost information can be retrieved within one year, as and where needed.

06. Electronic data

Emails

Most emails do not need to be kept. Emails that are inconsequential or unrelated to contracts or projects should subsequently be treated in line with the following policies:

  • All emails should be deleted after 12 months. This includes both internal and external emails
  • Earth Friendly Concrete By Wagner will archive emails for six months after employees have deleted them. After this six-month period, archived emails will be destroyed
  • Employees should never send emails containing confidential or proprietary data to external sources unless it has been approved by a relevant manager
Electronic documents

Electronic documents include, among other formats, both PDF document and files originating from Microsoft Office Suite or similar software.

Retention and erasure will depend upon the purpose of the electronic document, yet as a general rule of thumb employees can apply the following rules:

For PDF documents, the maximum period of retention should be 6 years. PDF documents that employees deem vital to their performance or role should be printed and/or stored in the relevant employee’s workspace.

For text documents or other formatted files, the maximum period of retention should be 5 years. Text documents or other formatted files that employees deem vital to their performance or role should be printed and/or stored in the relevant employee’s workspace.

Earth Friendly Concrete By Wagner does not and will not automatically delete electronic documents or corresponding data beyond the time periods defined within this policy. It is the responsibility of our employees to ensure they are adhering to our policy guidelines.

07. Insurance data

RecordRetention period
CertificatesPermanent
Claims filesPermanent
Current insurance policiesPermanent
Expired insurance policiesPermanent

08. Legal data

RecordRetention period
Legal memoranda and legal opinions7 years after resolution
Litigation data1 year after expiration of appeals or time for filing appeals
Court ordersPermanent
Requests for a departure from Earth Friendly Concrete By Wagner retention and erasure schedule10 years
Register of membersPermanent
Director’s meetings minutes10 years

09. Miscellaneous data

RecordRetention period
Reports from consultants2 years
Documents containing content of historical valuePermanents
Original policy and procedures manualsCurrent version with revision history
Copies of policy and procedures manualsRetain current version only
Annual company reportsPermanent
Records of personal identifications5 years
Any work-related reportable accident, injury or deaths3 years from incident
Immigration checks2 years from termination of job

10. Personnel data

RecordRetention period
Job applications and/or related interview data concerning unsuccessful candidates6 months
Employee personnel records6 years after end of contract
Employment contracts7 years after end of contract
Employment records correspondence with employment agencies3 years from date of hiring
Job descriptions3 years after superseded
Working time opt-out documentation2 years
Financial details of employeesAs long as necessary

11. Tax data

Earth Friendly Concrete By Wagner keeps accounts and/or records to demonstrate and establish amounts of gross income, deductions, credits and other information. These records are crucial to maintaining our company’s compliance of tax laws.

Associated records and documentation will include (but are not limited to) the following records and associated schedules:

RecordRetention period
Tax-exemption documentationPermanent
Tax bills7 years
Tax returnsPermanent
Tax receiptsPermanent
Tax statementsPermanent
Sales and/or use of tax records7 years
Annual returnsPermanent
Payroll/wage records for unincorporated businesses5 years after 31 Jan following the year of assessment
PAYE records3 years from the end of the tax year to which they relate
Maternity records3 years after the end of the tax year in which the maternity pay period ends