DATA RETENTION POLICY

Context and overview

Key details

  • Policy prepared by:​​​​ Nayfe Slusjan, Director, Nought Design Ltd
  • Approved by board / management on: ​01/01/2018.
  • Policy became operational on:​​ 01/01/2018.
  • Next review date:​​​​ 01/01/2024.​​

 

Purpose

The purpose of this Policy is to ensure that necessary records and documents of are adequately protected and maintained and to ensure that records that are no longer needed by Nought Design Ltd or are of no value are discarded at the proper time.  This Policy is also for the purpose of aiding employees of Nought Design Ltd in understanding their obligations in retaining electronic documents – including email, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.

 

Policy

This Policy represents the Nought Design Ltd’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

 

Administration

Attached as Appendix A is a Data Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of Nought Design Ltd and the retention and disposal of electronic documents.  The Data Retention Policy Administrator (the “Administrator”) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Data Retention Schedule is followed.  The Administrator is also authorized to: make modifications to the Data Retention Schedule from time to time to ensure that it is in compliance with U.K laws and includes the appropriate document and data categories for Nought Design Ltd; monitor U.K laws affecting data retention; annually review the data retention and disposal program; and monitor compliance with this Policy.

 

Suspension of Record Disposal In Event of Litigation or Claims

In the event Nought Design Ltd is served with any summons or request for documents or any employee becomes aware of a governmental investigation or audit concerning Nought Design Ltd or the commencement of any litigation against or concerning Nought Design Ltd, such employee shall inform the Administrator and any further disposal of documents shall be suspended until shall time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

 

Applicability

This Policy applies to all physical records generated in the course of The Nought Design Ltd’s operation, including both original documents and reproductions.  It also applies to the electronic documents described above.

This Policy was approved by the Board of Directors of Nought Design Ltd on 01/01/2018.

APPENDIX A  – DATA RETENTION SCHEDULE

The Data Retention Schedule is organized as follows:

SECTION TOPIC

  1. Accounting and Finance
  2. Contracts
  3. Corporate Records
  4. Customer Records
  5. Correspondence and Internal Memoranda
  6. Electronic Documents
  7. Grant Records
  8. Insurance Records
  9. Legal Files and Papers
  10. Miscellaneous
  11. Payroll Documents
  12. Pension Documents
  13. Personnel Records
  14. Property Records
  15. Tax Records
  16. Contribution Records
  17. Programs & Services Records
  18. Fiscal Sponsor Project Records

 

ACCOUNTING AND FINANCE

Record Type Retention Period
Accounts Payable ledgers and schedules 7 years
Accounts Receivable ledgers and schedules 7 years
Annual Audit Reports and Financial Statements Permanent
Annual Audit Records, including work papers and other documents that relate to the audit 7 years after completion of audit
Annual Plans and Budgets 2 years
Bank Statements and Canceled Checks 7 years
Employee Expense Reports 7 years
General Ledgers Permanent
Interim Financial Statements 7 years
Notes Receivable ledgers and schedules 7 years
Investment Records 7 years after sale of investment
Credit card records (documents showing customer credit card number) N/A

 

CONTRACTS

Record Type Retention Period
Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation) 7 years after expiration or termination

 

CORPORATE RECORDS

Record Type Retention Period
Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, bylaws, annual corporate reports) Permanent
Licenses and Permits Permanent

 

CUSTOMER RECORDS

Record Type Retention Period
Enquiry Forms 7 years
Feedback Forms 7 years
Marketing Opt-in Email address Until Opt-out

 

CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document they pertain to or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

  1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within two years. Some examples include:
  • Routine letters and notes that require no acknowledgment or followup, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
  • Form letters that require no follow-up.
  • Letters of general inquiry and replies that complete a cycle of correspondence.
  • Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
  • Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
  • Chronological correspondence files.

Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.

  1. Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently.

 

ELECTRONIC DOCUMENTS

1. Electronic Mail: Not all email needs to be retained, depending on the subject matter.

  • All email—from internal or external sources—is to be deleted after 6 years.
  • Staff will strive to keep all but an insignificant minority of their email related to business issues.
  • Nought Design Ltd will archive email for 3 years after the staff has deleted it, after which time the email will be permanently deleted.
  • All Nought Design Ltd business-related email should be downloaded to a service center or user directory on the server.
  • Staff will not store or transfer Nought Design Ltd Ltd-related email on non-work-related computers except as necessary or appropriate for Nought Design Ltd purposes.
  • Staff will take care not to send confidential/proprietary Nought Design Ltd information to outside sources.
  • Staff with more than 2GB in their email account will be unable to send or receive messages until the size of their account is reduced. Staff will be notified by the IT Department as their account size approaches 2 GB.

2. Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on the subject matter.

  • PDF documents – The length of time that a PDF file should be retained should be based upon the content of the file and the category under the various sections of this policy. The maximum period that a PDF file should be retained is 6 years. PDF files the employee deems vital to the performance of his or her job should be printed and stored in the employee’s workspace.
  • Text/formatted files – Staff will conduct annual reviews of all text/formatted files (e.g., Microsoft Word documents) and will delete all those they consider unnecessary or outdated. After five years, all text files will be deleted from the network and the staff’s desktop/laptop. Text/formatted files the staff deems vital to the performance of their job should be printed and stored in the staff’s workspace.

3. Web Page Files: Internet Cookies

  • All workstations: Browsers should be scheduled to delete Internet cookies once per month.

Nought Design Ltd does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

Each day Nought Design Ltd will run a digital backup copy of all electronic files (including email) on Nought Design Ltd’s servers, as specified in the Nought Design Ltd Disaster Recovery Plan. This backup is a safeguard to retrieve lost information within a one-year retrieval period should documents on the network experience problems. The digital backup copy is considered a safeguard for the data retention system of Nought Design Ltd, but is not considered an official repository of Nought Design Ltd records. All monthly and yearly backups are stored off-site according to Nought Design Ltd’s Disaster Recovery Policy.

In certain cases a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

 

GRANT RECORDS

Record Type Retention Period
Original grant proposal 7 years after completion of grant period
Grant agreement and subsequent modifications, if applicable 7 years after completion of grant period
All requested HMRC/grantee correspondence including determination letters and “no change” in exempt status letters 7 years after completion of grant period
Final grantee reports, both financial and narrative 7 years after completion of grant period
All evidence of returned grant funds 7 years after completion of grant period
All pertinent formal correspondence including opinion letters of counsel 7 years after completion of grant period
Report assessment forms 7 years after completion of grant period
Documentation relating to grantee evidence of invoices and matching or challenge grants that would support grantee compliance with the grant agreement 7 years after completion of grant period
Pre-grant inquiry forms and other documentation for expenditure responsibility grants 7 years after completion of grant period
Grantee work product produced with the grant funds 7 years after completion of grant period

INSURANCE RECORDS

Record Type Retention Period
Annual Loss Summaries 10 years
Audits and Adjustments 3 years after final adjustment
Certificates Issued to Nought Design Ltd Permanent
Claims Files (including correspondence, medical records, injury documentation, etc.) Permanent
Group Insurance Plans – Active Employees Until Plan is amended or terminated
Group Insurance Plans – Retirees Permanent or until 6 years after death of last eligible participant  
Inspections 3 years
Insurance Policies (including expired policies) Permanent
Journal Entry Support Data 7 years
Loss Runs 10 years
Releases and Settlements 25 years

 

LEGAL FILES AND PAPERS

Record Type Retention Period
Legal Memoranda and Opinions (including all subject matter files) 7 years after close of matter
Litigation Files 1 year after expiration of appeals or time for filing appeals
Court Orders Permanent
Requests for Departure from Data Retention Plan 10 years

 

MISCELLANEOUS

Record Type Retention Period
Consultant’s Reports 2 years
Material of Historical Value (including pictures, publications) Permanent
Policy and Procedures Manuals – Original Current version with revision history
Policy and Procedures Manuals – Copies Retain current version only
Annual Reports Permanent

 

PAYROLL DOCUMENTS

Record Type Retention Period
Employee Deduction Authorizations 4 years after termination
Payroll Deductions Termination + 7 years
P45 and P60 Forms Termination + 7 years
Garnishments, Assignments, Attachments Termination + 7 years
Labor Distribution Cost Records 7 years
Payroll Registers (gross and net) 7 years
Time Cards/Sheets 2 years
Unclaimed Wage Records 6 years

 

PENSION DOCUMENTS AND SUPPORTING EMPLOYEE DATA

General Principle: Pension documents and supporting employee data shall be kept in such a manner that Nought Design Ltd can establish at all times whether or not any pension is payable to any person and if so the amount of such pension.

Record Type Retention Period
Retirement and Pension Records Permanent

 

PERSONNEL RECORDS

Record Type Retention Period
Commissions/Bonuses/Incentives/Awards 7 years
Employee Earnings Records Separation + 7 years
Employee Handbooks 1 copy kept permanently
Employee Medical Records Separation + 6 years
Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records) 6 years after separation
Employment Contracts – Individual 7 years after separation
Employment Records – Correspondence with Employment Agencies and Advertisements for Job Openings 3 years from date of hiring decision
Employment Records – All Non-Hired Applicants (including all applications and resumes  whether solicited or unsolicited, results of post-offer, pre-employment physicals, results of background investigations, if any, related correspondence) 2-4 years (4 years if file contains any correspondence which might be construed as an offer)
Job Descriptions 3 years after superseded
Personnel Count Records 3 years
Disclosure and Barring Service (DBS) Certificate Duration of employment

 

PROPERTY RECORDS

Record Type Retention Period
Correspondence, Property Deeds, Assessments, Licenses, Rights of Way Permanent
Original Purchase/Sale/Lease Agreement Permanent
Property Insurance Policies Permanent

 

TAX RECORDS

General Principle: Nought Design Ltd must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of state and local income, franchise, and property tax laws.

Record Type Retention Period
Tax-Exemption Documents and Related Correspondence Permanent
HMRC Rulings Permanent
Excise Tax Records 7 years
Payroll Tax Records 7 years
Tax Bills, Receipts, Statements 7 years
Tax Returns – Income, Franchise, Property Permanent
Tax Workpaper Packages – Originals 7 years
Sales/Use Tax Records 7 years
Annual Information Returns Permanent
HMRC or other Government Audit Records Permanent

 

CONTRIBUTION RECORDS

Record Type Retention Period
Records of Contributions Permanent
Nought Design Ltd’s or other documents evidencing terms of gifts Permanent

 

PROGRAM AND SERVICE RECORDS

Record Type Retention Period
Nought Design Ltd convenings Permanent (1 copy only)
Research & Publications Permanent (1 copy only)

 

FISCAL SPONSOR PROJECT RECORDS

Record Type Retention Period
Sponsorship agreements Permanent