Internal Data Retention and Destruction Policy

Introduction

  1. This schedule outlines the time periods for which different types of data are to be retained and the procedures for their secure destruction once they are no longer needed for business or legal purposes.

Data Classification

Data is classified into categories based on its type, sensitivity, and importance to the firm's operations, including but not limited to:

  1. Employee Records : Includes personal information, employment contracts, performance reviews, and payroll records.
  2. Client Records : Contains client contact information, contracts, service agreements, and transaction histories.
  3. Operational Records : Includes invoices, expense reports, tax filings, and bank statements.
  4. Client Records :Contains project documentation, reports, internal communications, and meeting minutes.

Retention Schedule

Data Category Retention periods Destruction Criteria
Employee Records 7 years Post-employment termination
Client Records 7 years After end of client relationship
Candidate Records 2 years Post-decision on employment
Financial Records 10 years After tax audit possibility expires
Operational Records 5 years After operational use ends

Retention Justification

  1. Employee Records :Retained to comply with employment and tax laws, and to manage ongoing employment relationships.
  2. Client Records :Retained for the duration of the client relationship plus a statutory period to handle any post-relationship claims or inquiries.
  3. Candidate Records :Retained to defend against potential recruitment discrimination claims and to consider for future opportunities.
  4. Financial Records :Retained to comply with financial reporting, tax, and audit requirements
  5. Operational Records :Retained to provide a historical record of business activities and decisions.

Destruction Procedures

  1. Paper Records :To be cross-shredded and disposed of in a secure recycling facility.
  2. Electronic Records :To be permanently deleted using data wiping software that ensures data cannot be recovered or physically destroying the storage media.

Responsibility and Compliance

  1. Department managers are responsible for ensuring data in their area is managed according to this schedule.
  2. The IT department is responsible for implementing and verifying the secure destruction of electronic records.
  3. Compliance with this schedule will be audited annually to ensure adherence to legal and regulatory requirements and to reflect any changes in business operations or law.

Review and Update

  1. This data retention and destruction schedule will be reviewed annually or as necessary to ensure it remains compliant with current laws and relevant to the firm's operations.