Data Retention Policy
1. Purpose, Scope, and Users
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 IRIS Connect (further: the “Company”).
This Policy applies to all business units, processes, and systems in all countries in which the Company conducts business and has dealings or other business relationships with third parties.
This Policy applies to all Company officers, directors, employees, agents, affiliates, contractors, consultants, advisors 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 at the Company. Examples of documents include:
- Emails
- Hard copy documents
- Soft copy documents
- Video and audio
- Data generated by physical access control systems
2. Retention Rules
2.1.Retention General Principle
In the event, for any category of documents not specifically defined elsewhere in this Policy (and in particular within the Data Retention Schedule) and unless otherwise mandated differently by applicable law, the required retention period for such document will be deemed to be 3 years from the date of creation of the document.
2.2.Retention General Schedule
The Data Protection Officer defines the time period for which the documents and electronic records should to be retained through the Data Retention Schedule.
As an exemption, retention periods within Data Retention Schedule can be prolonged in cases such as:
- Ongoing investigations from Member States authorities, if there is a chance records of personal data are needed by the Company to prove compliance with any legal requirements; or
- When exercising legal rights in cases of lawsuits or similar court proceeding recognized under local law.
2.3. Safeguarding of Data during Retention Period
The possibility that data media used for archiving will wear out shall be considered. If electronic storage media are chosen, any procedures and systems ensuring that the information can be accessed during the retention period (both with respect to the information carrier and the readability of formats) shall also be stored in order to safeguard the information against loss as a result of future technological changes. The responsibility for the storage falls to the Data Protection Officer.
2.4. Destruction of Data
The Company and its employees should therefore, on a regular basis, review all data, whether held electronically on their device or on paper, to decide whether to destroy or delete any data once the purpose for which those documents were created is no longer relevant. See Appendix for the retention schedule. Overall responsibility for the destruction of data falls to the Data Protection Officer.
Once the decision is made to dispose according to the Retention Schedule, the data should be deleted, shredded or otherwise destroyed to a degree equivalent to their value to others and their level of confidentiality. The method of disposal varies and is dependent upon the nature of the document. For example, any documents that contain sensitive or confidential information (and particularly sensitive personal data) must be disposed of as confidential waste and be subject to secure electronic deletion; some expired or superseded contracts may only warrant in-house shredding. The Document Disposal Schedule section below defines the mode of disposal.
In this context, the employee shall perform the tasks and assume the responsibilities relevant for the information destruction in an appropriate way. The specific deletion or destruction process may be carried out either by an employee or by an internal or external service provider that the Data Protection Officer subcontracts for this purpose. Any applicable general provisions under relevant data protection laws and the Company’s Personal Data Protection Policy shall be complied with.
Appropriate controls shall be in place that prevents the permanent loss of essential information of the company as a result of malicious or unintentional destruction of information – these controls are described in the company’s IT Security Policy.
The Data Protection Officer shall fully document and approve the destruction process. The applicable statutory requirements for the destruction of information, particularly requirements under applicable data protection laws, shall be fully observed.
2.5. Breach, Enforcement and Compliance
The person appointed with responsibility for Data Protection, the Data Protection Officer has the responsibility to ensure that each of the Company’s offices complies with this Policy. It is also the responsibility of the Data Protection Officer to assist any local office with enquiries from any local data protection or governmental authority.
Any suspicion of a breach of this Policy must be reported immediately to Data Protection Officer. All instances of suspected breaches of the Policy shall be investigated and action taken as appropriate.
Failure to comply with this Policy may result in adverse consequences, including, but not limited to, loss of customer confidence, litigation and loss of competitive advantage, financial loss and damage to the Company’s reputation, personal injury, harm or loss. Non-compliance with this Policy by permanent, temporary or contract employees, or any third parties, who have been granted access to Company premises or information, may therefore result in disciplinary proceedings or termination of their employment or contract. Such non-compliance may also lead to legal action against the parties involved in such activities.
3. Document Disposal
3.1. Routine Disposal Schedule
Records which may be routinely destroyed unless subject to an on-going legal or regulatory inquiry are as follows:
- Announcements and notices of day-to-day meetings and other events including acceptances and apologies;
- Requests for ordinary information such as travel directions;
- Reservations for internal meetings without charges / external costs;
- Transmission documents such as letters, fax cover sheets, e-mail messages, routing slips, compliments slips and similar items that accompany documents but do not add any value;
- Message slips;
- Superseded address list, distribution lists etc.;
- Duplicate documents such as CC and FYI copies, unaltered drafts, snapshot printouts or extracts from databases and day files;
- Stock in-house publications which are obsolete or superseded; and
- Trade magazines, vendor catalogues, flyers and newsletters from vendors or other external organizations.
In all cases, disposal is subject to any disclosure requirements which may exist in the context of litigation.
3.2. Destruction Method
Level I documents are those that contain information that is of the highest security and confidentiality and those that include any personal data. These documents shall be disposed of as confidential waste (cross-cut shredded and incinerated) and shall be subject to secure electronic deletion. Disposal of the documents should include proof of destruction.
Level II documents are proprietary documents that contain confidential information such as parties’ names, signatures and addresses, or which could be used by third parties to commit fraud, but which do not contain any personal data. The documents should be cross-cut shredded and then placed into locked rubbish bins for collection by an approved disposal firm, and electronic documents will be subject to secure electronic deletion.
Level III documents are those that do not contain any confidential information or personal data and are published Company documents. These should be strip-shredded or disposed of through a recycling company and include, among other things, advertisements, catalogues, flyers, and newsletters. These may be disposed of without an audit trail.
4. Managing Records Kept on the Basis of this Document
Record name | Storage location | Person responsible for storage | Controls for record protection | Retention time |
Data Retention Schedule | Data Protection Officer’s Google Drive | Data Protection Officer | Only authorized persons may access this document | Permanently |
5. Validity and document management
This document is valid as of April 2021
The owner of this document is the Data Protection Officer who must check and, if necessary, update the document at least once a year.
6. Appendices
Appendix – Data Retention Schedule
Financial Records
Personal data record category | Mandated retention period | Record owner |
Payroll records | Seven years after audit | Finance |
Supplier contracts | Seven years after contract is terminated | Finance |
Chart of Accounts | Permanent | Finance |
Fiscal Policies and Procedures | Permanent | Finance |
Permanent Audits | Permanent | Finance |
Financial statements | Permanent | Finance |
General Ledger | Permanent | Finance |
Investment records (deposits, earnings, withdrawals) | 7 years | Finance |
Invoices | 7 years | Finance |
Cancelled checks | 7 years | Finance |
Bank deposit slips | 7 years | Finance |
Business expenses documents | 7 years | Finance |
Check registers/books | 7 years | Finance |
Property/asset inventories | 7 years | Finance |
Credit card receipts | 3 years | Finance |
Petty cash receipts/documents | 3 years | Finance |
Business Records
Personal data record category | Mandated retention period | Record owner |
Article of Incorporation to apply for corporate status | Permanent | Finance |
Board policies | Permanent | Finance |
Board meeting minutes | Permanent | Finance |
Tax or employee identification number designation | Permanent | Finance |
Office and team meeting minutes | Finance | |
Annual corporate filings | Permanent | Finance |
HR: Employee Records
Personal data record category | Mandated retention period | Record owner |
Disciplinary, grievance proceedings records, oral/verbal, written, final warnings, appeals | As per legal requirement | HR |
Applications for jobs, interview notes – Recruitment/promotion panel Internal Where the candidate is unsuccessful Where the candidate is successful | Deleted immediately Duration of employment |
HR |
Payroll input forms, wages/salary records, overtime/bonus payments Payroll sheets, copies | 7 years | HR |
Bank details – current | Duration of employment | HR |
Payrolls/wages | Duration of employment | HR |
Job history including staff personal records: contract(s), Ts & Cs; previous service dates; pay and pension history, pension estimates, resignation/termination letters | As per legal requirement | HR |
Employee address details | Duration of employment | HR |
Expense claims | As per legal requirement | HR |
Annual leave records | Duration of employment | HR |
Accident books
Accident reports and correspondence |
As per legal requirement | HR |
Certificates and self-certificates unrelated to workplace injury; statutory sick pay forms | As per legal requirement | HR |
Pregnancy/childbirth certification | As per legal requirement | HR |
Parental leave | Duration of employment | HR |
Maternity pay records and calculations | As per legal requirement | HR |
Redundancy details, payment calculations, refunds, notifications | As per legal requirement | HR |
Training and development records | Duration of employment | HR |
Contracts
Personal data record category | Mandated retention period | Record owner |
Signed | Permanent | Finance |
Contract amendments | Permanent | Finance |
Successful tender documents | Permanent | Finance |
Unsuccessful tenders’ documents | Permanent | Finance |
Tender – user requirements, specification, evaluation criteria, invitation | Permanent | Finance |
Contractors’ reports | Permanent | Finance |
Operation and monitoring, eg complaints | Permanent | Finance |
Customer Data
Personal data record category | Mandated retention period | Record owner |
Platform data – inclusive of Video data, comments, attachments, profile picture, email address, first and second name | Retained whilst organisation remains a customer or deleted by user. Once a user/organisation requests record/s to be deleted, data will be removed from the back-ups within 9 months (Data is held in a trashed state for 90 days then a further 180 days in data back-ups) |
Customer |
Live chat history | Until no longer needed or requested to be deleted | Support |
Screen recordings from support session | Automatically deleted after 90 days | Support |
CRM data – inclusive of Name, Email address, mobile number, address, emails and phone call summaries | Until no longer needed or requested to be deleted | Support |
Metrics data | Retained whilst organisation remains a customer or deleted by user. Once an organisation requests all records to be deleted, data will be anonymised | Development Team |
Non – Customer Data
Personal data record category | Mandated retention period | Record owner |
Name, email address | Kept until person unsubscribes / requests to be removed from system | Marketing & Sales |
Call recordings | Automatically deleted after 6 months | Sales |
IT
Personal data record category | Mandated retention period | Record owner |
Recycle Bins | Cleared monthly | Individual employee |
Downloads | Cleared monthly | Individual employee |
Inbox | All emails containing PII attachments deleted after 3 years. | Individual employee |
Deleted Emails | Cleared monthly | Individual employee |
Local Drives & files | Moved to network drive weekly, then deleted from local drive | Individual employee |
Google Drives, drop box | Reviewed monthly, any record/file containing PII deleted by employee after maximum of 3 years, or as soon as no longer needed | Individual employee |