Retention Schedule
A........... Company Records. 2
B........... Employee HR records. 3
F............ Insurance Records. 11
G........... Miscellaneous Internal Processes. 13
A. Company Records
Type of Material
Minimum Retention Period
Reason
Register of directors/trustees’ residential addresses
This register is stored for the life of the company (Section 162 CA 2006) and there is no provision to remove entries of former directors/trustees. This register will not be available for public inspection.
Companies Act 2006, Companies Act 1985
Directors’ service contracts
A copy of the contract or a memorandum of its terms will be stored for 6 years (for tax purposes and to account for the 6-year limitation period for contracts) from the expiry or termination date (Section 228 CA 2006).
Companies Act 2006, Companies Act 1985
Board minutes
For board meetings held on or after the 1 October 2007, will be stored for 10 years from the date of the meeting (section 248 CA 2006). After this, minutes containing personal data, will be deleted
For meetings held before 1 October 2007 minutes will be stored permanently (section 382 Companies Act 1985).
Companies Act 2006, Companies Act 1985
Certificate of Incorporation and Memorandum of Association
As these documents are evidence of the company’s compliance with the registration requirements of the CA 2006 (section 15 CA 2006), they will be stored for the life of the company.
Companies Act 2006, Companies Act 1985
B. Employee HR records
Type of Material
Minimum Retention Period
Reason
Material that is constantly updated, such as an employee’s home address
Personal employee details will be stored and updated. Previous records will be deleted.
Data Protection Principles
Recruitment and selection materials of rejected candidates
12 months after the decision
The time limit for claim of discrimination, Employment Practices Code Part 1
Job Applications and selection materials of successful candidates
Length of employment plus 6 years.
Company Policy
Criminal Background Checks (CBC) (where you are allowed to collect this data)
Length of employment plus 6 years.
Checks on unsuccessful candidates: approximately 6 to 18 months. This will depend on the context.
Company Policy
Identification documents of foreign nationals (obligation to retain copies to perform immigration checks)
Minimum 2 years
Article 6 Immigration Restriction on Employment Order 2007
Expat records and other records relating to foreign employees (e.g. Visa work permit)
6 years after employment ceases
Section 5 Limitation Act 1980
Checks (such as references) made before taking someone on and any required copies of documents
6 years after the contract ends
Evidence that checks were made
Copy of identification documents for Right to Work Checks
6 years after employment ceases
Section 5 Limitation Act 1980
Correspondence
When this contains personal data, this should be deleted as soon as personal data processed
GDPR principle, DPA 5th principle
Incidental correspondence with staff members
One year after the matter is closed
Data Protection Principles
Material forming part of an employment contract, changes to T&C’s
6 years after the contract ends (or after that provision is superseded
The time limit for legal claim Section 5 Limitation Act 1980
Data concerning a temporary worker
6 years after employment ceases
Section 5 Limitation Act 1980
Leave and absence, including sick leave records
6 years
May be relevant to claims of under-payment, unlawful deductions or breach of contract Section 5 Limitation Act 1980
Registration of work and rest periods if required if an obligation exists to show compliance
Minimum retention period 2 years
Working Time Regulations 1998
Essential medical data required for employment purposes
Length of employment plus 6 years.
DPA 2018
Occupational health data and referrals
Length of employment plus 6 years.
The Health and Safety at Work Act 1974
Pension-related records
12 years from the end of any payable benefit.
Consult pension provider
Performance records (such as training or appraisal)
6 years after employment ends
The time limit for a legal claim
Maternity and paternity records
5 years from birth or adoption
Employment Rights Act 1996
TUPE records (for employees who have transferred employer)
Length of employment plus 6 years
Transfer of Undertakings (Protection of Employment) Regulations 2006
Disciplinary records
6 years after employment ends
The time limit for a legal claim
C. Finance
Type of Material
Minimum Retention Period
Reason
Accounting records (including; bank statements and reconciliations; payment and receipt records; supplier/accounts payable invoices; customer/accounts receivable invoices; customer debit notes; purchase and sales ledger; and employee expense records)
6 years past the end of the financial year to which they relate
Companies Act 1985 as amended by the Companies Acts 1989 & 2006. Generally Accepted Accounting Practice (UK GAAP).
Accounting record (including audit): Taxation
10 years from tax year end or as required in the event of a tax investigation
As above
Annual audited financial statements and report
Life of Group entity
As above
Interim financial statements
Life of Group entity
As above
Internal financial statements
7 years from financial year end
As above
Annual plans and budgets
7 years from financial year end
As above
VAT records
7 years from tax year end
Value Added Tax Act 1994 (as amended).
Insurance premium tax records
7 years from tax year end
The Insurance Premium Tax Regulations 1994.
Banking records:
Cheques and other negotiable instruments
Paying-in counterfoil
Bank statements and reconciliations
Instructions to bank
Originals
Originals
Original if provided in hardcopy or otherwise if statements obtained via internet banking, on-line printouts
Both
6 years from date of issuance
6 years from date of issuance
Public Companies: 6 years
Private Companies: 3 years
6 years after ceasing to be effective
Contracts (underhand) and relevant correspondence and other related documents (such as PO, credit checks)
End of contract plus 7 years (or to the end of any warranty or service periods, if longer)
Limitation Act 1980.
Contracts (executed as a deed) and relevant correspondence and other related documents (such as PO, credit checks)
End of contract plus 13 years (or to the end of any warranty or service periods, if longer)
Limitation Act 1980.
D. Payroll
Type of Material
Minimum Retention Period
Reason
Pay records and relevant supporting documents
7 years from financial year end (statutory limitation period).
The time limit for a legal claim of under-payment or unlawful deductions
Material related to income tax and National Insurance
3 years after the end of the tax year they relate to
Statutory: Income Tax Regulations
Working time records
Date on which they were made plus 2 years
The Working Time Regulations 1998.
Records concerning pay due to employees during absence from work due to illness
End of the tax year to which they relate plus 3 years
The Statutory Sick Pay (General) Regulations 1982 as amended.
Records concerning parental leave / maternity pay or equivalent
End of the tax year in which the parental leave / maternity period ends plus 3 years
The Statutory Maternity Pay (General) Regulations 1986 as amended.
Minimum wage records
End of the pay reference period following the one that the records cover plus 3 years
National Minimum Wage Act 1998.
E. Marketing
Type of Material
Minimum Retention Period
Reason
Personal data used to contact existing subscribers (this may include email, telephone number, postal address) or select marketing audiences from the existing customers (this may include demographic information, marketing preferences and permission, communication history, and variables derived from the individual’s transactional))
24 months from last interaction with (depending on context). Will be removed immediately when unsubscribed
Company Policy
Personal data used to contact prospective subscribers based on consent (this may include email and telephone number) or select audiences from prospective customers for marketing through electronic channels (this may include demographic information, marketing preferences, and communication history)
If the contact took place, 3 months from the contact date; if the contact did not take place, 6 months after initial collection. Will be removed immediately when unsubscribed
Company Policy
Personal data used to carry out suppression requests (this may include email, telephone number, and postal address)
Minimise the record to minimum information necessary to identify the individual for suppression purposes, therefore removing the risk of sourcing the contact details and inadvertently contacting the individual again,
Company Policy
Anonymised data used for analytical or statistical purposes
Indefinitely (but review every 5 years to make sure retention remains useful, even if anonymised data is out of scope of GDPR).
Company Policy
Images, photography, film, case studies and related consent forms linked to the said media coverage for use in marketing materials and campaigns
5 years from consent expiry for use in marketing materials.
Company Policy
Media coverage – records held consisting of news stories placed or press coverage received.
5 years to determine if the coverage is historically important; part of a crisis piece; or relates to an organisational priority that needs further retention.
Company Policy
F. Insurance Records
Type of Material
Minimum Retention Period
Reason
Insurance policy, proposal forms, renewal notices and certificates. purchase and sales ledger; employee expense records)
Until claims under the policy are barred, all outstanding claims are settled, the policyholder can no longer bring legal proceedings against the insurer or broker and, if legal proceedings have started, the appeals process has been exhausted. end of any tax enquiry, if longer.
Companies Act 1985 as amended by the Companies Acts 1989 & 2006. Generally Accepted Accounting Practice (UK GAAP).
Records relating to the suitability and appropriateness of an insurance-based investment product for the customer
You must keep records for at least 5 years or if necessary, for the length of the relationship between the insurance intermediary / insurance undertaking and the customer.
Financial Conduct Authority SYSC 9.1.2AR
Article 19 (EU) 2017/2359 and, COBS 9A.4.3 and COBS 10A.7.2A.
Claim documents: records of incidents giving rise to a claim, claim correspondence and records of payouts
Until claims under the policy are barred, all outstanding claims are settled, the policyholder can no longer bring legal proceedings against the insurer or broker and, if legal proceedings are commenced, the appeals process has been exhausted.
Company Policy
Records relating to Insurance Premium Tax (including policy documents, copies of invoices, credit or debit notes and business and accounting records)
For tax purposes you must keep these records for a period of six years.
Regulation 16 of the Insurance Premium Tax Regulations 1994, SI 1994/1774.
G. Miscellaneous Internal Processes
Type of Material
Miscellaneous
Minimum Retention Period
Reason
Confidentiality and non-competition agreements (if a penalty is attached to the non-competition or confidentiality clause
Minimum for the length of contract or agreement, but 6 years after contract expires.
Section 5 Limitation Act 1980
Intellectual property records
The recommendation is to retain documents for the life of the intellectual property and 6 years after
Section 5 Limitation Act 1980
Complaints Process
6 years from the final recorded communication from the complainant about the complaint.
Required as part of the Limitation Act 1980
Whistleblowing Process
6 years from the final recorded communication from the person raising the issue about the case. Where a case is raised anonymously, 6 years from the date the case is concluded.
Required as part of the Limitation Act 1980
Data Protection Impact Assessments
6 years
Company Policy
Breach Reporting
3 years after the investigation and remedial action were completed.
Company Policy
DSARs Request
1 year after the DSAR is complete.
Company Policy
Finance Internal emails
Financial Year + 3 Months
Company Policy
Staff Mailboxes and Outlook (inbound and outbound emails)
10 Years
Company Policy
Housing Applications
Waiting List 5 Years
Company Policy
Commercial Unit Applications
Waiting List 5 Years
Company Policy
Enquiry Emails for Shoots and Filming
5 Years
Company Policy
Tennant information
10 years after vacating property
Company Policy