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Data Retention Policy

Purpose

This policy sets the required retention periods for specified categories of personal data and sets out the minimum standards to be applied when destroying certain information within Scantec. 


Scope

This Policy applies to all Scantec departments, processes and systems in which the Scantec processes and stores personal data.


Responsibilities

This Policy applies to all Scantec directors, employees, contractors, consultants, or service providers that may collect, process, or have access to data (including personal data and / or sensitive personal data).  It is the responsibility of all of the above to familiarise themselves with this Policy and ensure adequate compliance with it.

This policy applies to all information used by the Scantec. Examples of documents include:

  • Emails
  • Hard copy documents
  • Soft copy documents
  • Video and audio
  • Data generated by physical access control systems


Method Of Storage

Data will be stored securely by one of the following methods:

  • Electronic secure drive
  • Hard copy
  • People HR (Employee records)
  • Trisys (Candidate records)
  • On-site Hard copy storage for 12 months then transferred to off-site secure storage facility (Finance & Payroll records only)


Method Of Disposal

Data will be disposed of securely by one of the following methods:

  • Manual deletion
  • Electronic deletion
  • Confidential waste bins
  • Secure waste
  • Shredded and recycled by secure third party provider (Secure Storage Service Ltd) (Finance & Payroll records only)


Information Held By Us

We hold personal information about:

  • Clients – former, current and prospective
  • Work-seekers
  • Employees
  • Suppliers

We also hold information about financial transactions relating to:

  • Employees
  • Work-seekers/Temporary workers
  • Suppliers


How Long Is Personal Data Held For?

We aim not to hold personal data longer than necessary. Unless requested by an individual, the following types of data will be held for the periods shown below, after which it will be securely deleted or destroyed:

Personnel Records

Document type

How long to keep for (and source of requirement)

Responsibility


Work-seeker records including application form/CV, ID checks, terms of engagement (see also below), details of assignments, opt-out notices and interview notes

1 year from the last date of supply or introduction to any client (Conduct of Employment  Agencies and Employment Businesses Regulations 2003 (Conduct Regulations)

Recruitment Support


Client records including client details, terms and conditions of business, assignment/vacancy details



Terms of engagement with temporary worker and terms of business with clients

6 years in order to deal with any civil action in the form of contractual claim (Limitation Act 1980) (5 years in Scotland)

Recruitment Support


Hirer records including client details, terms of business (see below also), assignment/ vacancy details

1 year from the last date of supply or introduction to any client (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations)

Recruitment Support


Working time records:               48 hour opt out notice         Annual leave record

2 years from the time they were created

Recruitment Support


Annual appraisal/assessment records.

5 years (Under the DPA no specific period is detailed so records should only be kept as long as necessary)

Recruitment Support


Staff records including CV, ID, bank details, reference information and other personnel information (e.g. absence & disciplinary records)

2 years from employee termination date

Recruitment Support


References

2 years following the introduction to a client OR 2 years after engagement has ended, whichever is the later (Under the DPA records are only to be kept as long as necessary however the Conduct Regulations require references to be kept for 1 year)

Recruitment Support


Terms of Engagement with temporary worker and Terms of Business with clients

6 years in order to deal with any civil action in the form of contractual claim (Limitation Act 1980). Although this is only 5 years in Scotland we maintain 6 years.

Recruitment Support


Records held relating to right to work in the UK

2 years after employment or engagement has ended.

Recruitment Support


Criminal records checks/ Disclosure Barring checks

6 months following the introduction to a client OR 2 years after engagement has ended, whichever is later

Recruitment Support


National Minimum Wage Documentation:
Total pay by the worker and the hours worked by the worker

Overtime/ shift premium;

Any deduction or payment of accommodation;

Any absences e.g. rest breaks, sick leave, holiday;

Any travel or training during working hours and its length;

Total number of hours in pay reference period – this sets the averaging period to calculate whether a worker has been paid

NMW e.g. workers paid weekly have a pay reference period of one week

For HMRC purposes: 7 years after the end of the pay reference period following the one that the records cover (National Minimum Wage Act 1998)                                (We must keep them for 5 years in Scotland, and 6 years for the rest of the UK, in order to show that we have paid at least national minimum wage rates if a civil claim is brought against us)

Payroll


Sickness records – statutory sick pay

7 years

Payroll


Statutory maternity, paternity, adoption pay

7 years from the end of the tax year to which it relates

Payroll


Pensions auto-enrolment (including auto-enrolment date, joining date, opt in and opt out notices, contributions paid)

Payroll


Gender pay gap reporting (if applicable)

 1 year

Payroll




Company Records

Document type

How long to keep for (and source of requirement)

Responsibility


VAT

7 years

Finance



Company Accounts

7 years

Finance



Payroll Information

7 years from the end of the year

Finance




Further Information

Further information or assistance is available from the Scantec Data Protection Officer:

Email: DPO@scantec.co.uk

Tel: 0151 666 8903


Or from the Information Commissionaire’s Office (ICO): www.ico.gov.uk