DATA RETENTION AND DISPOSAL POLICY
The purpose of this Policy is to ensure that necessary records and documents of Xtract Accounting that are no longer needed by us or are of no value, are discarded at the proper time and in an appropriate manner.
This Policy represents our policy regarding the retention and disposal of records.
As stated below, in our Privacy and Cookies Policy, and as required by law, we shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.
When establishing and/or reviewing retention periods, the following shall be considered:
Our objectives and requirements,
The type of personal data in question,
The purpose(s) for which the data in question is collected, held, and processed,
Our legal basis for collecting, holding, and processing that data, and
The category or categories of data subject to whom the data relates.
If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made by us to do so (whether in response to a request by a data subject or otherwise).
Document: Legal Contracts
Retention Period: 7 years after expiration or termination
Document: Financial Statements/Accounts, Tax Returns, Working Papers, Payroll records and assessments, and banking records
Retention Period: 6 years + the current tax year
Document: Records establishing client’s identity for Money Laundering purposes
Retention Period: 5 years
Document: Payroll and Wage records for Unincorporated businesses (e.g. Sole Traders and Partnerships)
Retention Period: 5 years after 31st January following the year of assessment
Document: Payroll and Wage records for Companies
Retention Period: 6 years from the financial year-end in which payments were made
Document: PAYE records
Retention Period: Not less than 3 years after the end of the tax year to which they relate
Document: Maternity and Paternity records
Retention Period: 3 years after the end of the tax year in which the pay period ends
Document: Sickness records required for the purposes of Statutory Sick Pay
Retention Period: 3 years after the end of the tax year in which payments are made
Document: Consents for the processing of Personal and Sensitive data
Retention Period: For as long as the data is being processed and up to 6 years afterwards
Document: General correspondence and Internal memoranda
Retention Period: 7 years after expiration or termination of contract
Upon the expiry of the data retention periods set out above, or when a data subject exercises their right to have their personal data erased, personal details shall be deleted, destroyed, or otherwise disposed of as follows:
Personal data and Special category personal data stored electronically (including all backups thereof) shall be deleted,
Personal data and Special category personal data stored in hardcopy form shall be securely shredded,
Client documents (if any) shall be returned to the client within 2 months of completing the work for the year. Copies of documents not required to be returned will be securely shredded as part of our paperless office policies unless they are required to be retained for legal & tax reasons.
SUSPENSION OF RECORD DISPOSAL IN EVENT OF LEGAL PROCEEDINGS OR CLAIMS
There are certain occasions when information needs to be preserved beyond any limits set out in the Policy. The Policy must be SUSPENDED relating to a specific customer or document and the information retained beyond the period specified in the above Data Retention Schedule in the following circumstances:
Legal proceedings or a regulatory or similar investigation or obligation to produce information are known to be likely, threatened, or actual.
A crime is suspected or detected.
Information is relevant to a company in liquidation or receivership, where a debt is due to us.
Information is considered by the owning unit to be of potential historical importance and this has been confirmed by the Administrator.
In the case of possible or actual legal proceedings, investigations or crimes occurring, the type of information that needs to be retained relates to any that will help or harm us or the other side’s case or liability or amount involved.
If there is any doubt over whether legal proceedings, an investigation or a crime could occur, or what information is relevant or material in these circumstances, the Administrator should be contacted, and legal advice sought.
The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.
CHANGES TO THIS POLICY
We may update this policy from time to time by publishing a new version. This page should be checked occasionally to ensure that the policy remains relevant.
HOW TO CONTACT US
If you have any questions about this policy, please do not hesitate to email us at firstname.lastname@example.org.
This Policy was last updated on 1st September 2020.