Data Retention Policy
Welcome
Native is a trading name of Native Places Limited.
This policy is effective from and was last revised 6th Dec 2021. The next review date is 1st August 2023 or first working day thereafter.
Please read this data retention policy carefully as it sets out the basis and timeframes on which we retain and dispose of data produced by or through the
- www.nativeplaces.com website
- Corporate portals or web pages managed by Native on behalf of our corporate clients
- Web pages offering payment or booking services from our booking apps
- Staff functions including asset management, direct, agent & partner, corporate and key account client services, HR, operations & estates, finance, business development, marketing and IT team personnel
- Incoming emails or data transfers from colleagues or third parties
The purpose of this Policy is to ensure that data controlled or processed by Native are adequately protected and maintained and to ensure that records that are no longer needed are discarded at the proper time.
This Policy is also for the purpose of aiding employees of Native in understanding their obligations in retaining electronic documents – including e-mail, Web files, text files, sound and movie files, PDF documents, Microsoft Office or other formatted files and database records.
Native is committed to compliance with Data Processing Laws and respecting your privacy. “Data Processing Laws” means (a) the Data Protection Act 1998 and any laws or regulations implementing Directive 95/46/EC; and/or (b) the General Data Protection Regulation (GDPR); and/or any corresponding or equivalent national laws or regulations; and any applicable laws replacing, amending, extending, re-enacting or consolidating any of the above DP Laws from time to time; For the purposes of the Data Processing Laws Native is the data controller. Native’s Privacy Policy can be viewed at https://www.nativeplaces.com/privacy-policy
Administration
Attached as Appendix A is a Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of Native and the retention and disposal of electronic documents. The Data Protection Officer (DPO) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The Administrator is also authorised to: make modifications to the Record Retention Schedule from time to time to ensure that itis in compliance with national and international laws.
Suspension of Record Disposal In Event of Litigation or Claims
In the event Native is served with any data access request, court proceedings, legal claim, request for documents or any employee becomes aware of a governmental investigation or audit concerning Native or the commencement of any litigation against or concerning Native, such employee shall inform the DPO and any further disposal of documents shall be suspended until such time as the DPO, with the advice of counsel, determines otherwise. The DPO shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of data.
APPENDIX A – RETENTION SCHEDULE
The Retention Schedule is organised as follows:
- Personal Data that falls under the terms of our Privacy Policy
- Accounting and Finance
- Contracts
- Corporate Records
- Correspondence and Internal Memoranda
- Electronic Documents
- Insurance Records
- Legal Files and Papers
- Payroll Documents
- Pension Documents
- Personnel Records
- Health & Safety Records
- Property Records
- Tax Records
A. Personal Data that falls under the terms of our Privacy Policy
Sign-ups for news, offers or marketing campaigns – If you have provided your contact details and confirmed that you have provided consent to receive news, offers or marketing campaigns, we will retain your personal information for no longer than 5 years from the point you last expressed an interest/opened a communication without unsubscribing/provided consent/contacted us/subscribed or unsubscribed. We retain information derived from cookies and other tracking technologies for no longer than 5 years.
Personal Information related to Enquiries and Orders – If you have made an enquiry about or order for products or services or a third party has done so on your behalf, we will retain your information for no longer than 7 years from the point of your last enquiry or order.
Billing – If you have been billed by Native for any products or services, we will retain your information for no longer than 7 years from the point of billing of your last invoice.
Account Information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our products and services.
Client contracts – If you’re an employee of a corporate client that specifies in our contract that data must be retained for reporting purposes on their behalf for a particular period, we will comply with that length of time where possible and where they have confirmed their responsibility as data controller in that regards.
Job Applicant details – CVs, covering letters, application forms and interview notes for unsuccessful candidates will be retained for no longer than 1 year. Successful candidates will have these files transferred to their personnel file, for which our retention period will not be covered by this document.
Other files and emails: We retain active, undeleted electronic files and emails for a period of no longer than 7 years, unless they have been identified as business critical and set to not be deleted.
Complaints: We retain complaints and responses to them for no longer than 6 years from closure.
In other cases we’ll store personal information for the periods needed for the purposes for which the information was collected or for which it is to be further processed. And sometimes we’ll keep it for longer if we need to by law. Otherwise we delete it.
B. Accounting and Finance
Record Type
Retention Period
Accounts Payable ledgers and schedules
7 years after end of financial year
Accounts Receivable ledgers and schedules
7 years after end of financial year
Annual Accounts, 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
7 years after end of financial year
Bank Statements and Cancelled Checks
7 years after end of financial year
Employee Expense Reports
7 years after end of financial year
General Ledgers
Permanent
Interim Financial Statements
7 years after end of financial year
Investment Records
7 years after sales of investment/asset
Credit card records (documents showing customer credit card number)
No longer than 3 years. Company practice is to enter credit card details into secure, encrypted system and cut out and shred from original document as soon as possible. No credit card numbers are permitted to be stored in paper files in our offices or electronic files on our networks beyond timeframe for entry and disposal discussed above.
C. Contracts
Record Type
Retention Period
Contracts and Related Correspondence (including any
proposal that resulted in the contract and all other supporting documentation)
7 years after expiration or termination
D. 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
E. Correspondence and Internal Memoranda
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:
- Those pertaining to routine matters and having no significant, lasting consequences should be discarded within two years.
We retain active, undeleted electronic files and emails for a period of no longer than 7 years, unless they have been identified as business critical and set to not be deleted.
- Those pertaining to non-routine matters or having significant lasting consequences
We retain such files permanently
F. Email & Digital Documents
- Not all email needs to be retained, depending on the subject matter.
- All e-mail—from internal or external sources—is to be deleted after 12 months unless there is a legitimate business reason for retaining it.
- Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
- Native will archive e-mail 120 days after the email was created unless it has been deleted. It is the staff member’s responsibility to ensure emails have been deleted prior to this time if they should not be retained.
- Native will delete emails and email archives 30 days after an employee has left Native unless their line manager or a director of Native has requested their emails or email archives should be retained for a period.
- Native will not store or transfer Native-related e-mail on non-work-related computers except as necessary or appropriate for Native purposes.
- Staff will take care not to send confidential/proprietary Native information to outside sources unless necessary for legitimate business purposes.
- Staff with more than 1.3GB in their e-mail account will be unable to send or receive messages until the size of their account is reduced, unless authorised by a director of Native. Staff will be notified by the Native IT Dept as their account size approaches 1.3 GB.
- Any e-mail a staff member deems vital to the performance of their job should be copied to the staff’s Z: drive
- folder, and printed and stored in the employee’s workspace.
- Native will retain active, unarchived, undeleted emails for a period of no longer than 7 years, unless they have been identified as business critical and set to not be deleted.
- Digital Documents
- The length of time that a digital document should be retained should be based upon the content of the file and the category under the various sections of this policy.
- Native will retain active, unarchived, undeleted electronic files and emails for a period of no longer than 7 years, unless they have been identified as business critical and set to not be deleted.
- Staff will conduct annual reviews of all digital documents and will amend any they consider to be outdated or inaccurate, but still required.
- Staff will delete all those they consider unnecessary to retain in accordance with this policy. After five years, all
- Web Page Files: Internet Cookies
- Users should schedule the manual clearing of their internet cookies and cache a minimum of once per month
- It is company policy that passwords should not be set to be retained by devices or browsers
- Native 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.
- Disaster Recovery Plan. This backup tape is a safeguard to retrieve lost information within a one-year
retrieval period should documents on the network experience problems. The tape backup copy is considered a safeguard for the record retention system of Native, but is not considered an official repository of Native records. All monthly and yearly tapes are stored offsite according to Native’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.
G. Insurance Records
Record Type
Retention Period
Annual Loss Summaries
10 years
Audits and Adjustments
3 years after final adjustments
Certificates Issued to Native
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
7 years
Releases and Settlements
25 years
H. Legal Files and Papers
Record Type
Retention Period
Legal Memoranda and Opinions
7 years after close of matter
Litigation Files
Litigation Files
Court Orders
Permanent
Requests for Departure from Records Retention Plan
10 years
I. Payroll Documents
Record Type
Retention Period
Salary records (also overtime, bonuses, expenses)
6 years
Income tax and NI returns, income tax records and correspondence with HMRC
6 years
Inland Revenue/HMRC approvals
Permanent
Statutory Sick Pay records, calculations, certificates, self-certificates
6 years
J. Pension Documents
Record Type
Retention Period
Pension scheme investment policies and contributions
12 years from the ending of any benefit payable under the policy.
Pensioners’ records
12 years after benefit ceases.
K. Personnel Records
Record Type
Retention Period
CVs. Cover notes, application forms and interview notes (for unsuccessful candidates)
1 year
Redundancy details, calculations of payments, refunds, notification to the Secretary of State
Recommended retention period:
6 years from the date of redundancy
Parental leave
6 years after employment ceases.
Working time records
2 years
Retirement Benefits Schemes – records of notifiable events, for example, relating to incapacity
6 years from the end of the scheme year in which the event took place
Records relating to children and young adults
Until the child/young adult reaches the age of 21
Statutory Maternity Pay records, calculations, certificates (Mat B1s) or other medical evidence
3 years after the end of the tax year in which the maternity period ends
National minimum wage records
3 years after the end of the pay reference period following the one that the records cover.
L. Health & Safety Records
Record Type
Retention Period
Accident books, accident records/reports
3 years from the date of the last entry (or, if the accident involves a child/ young adult, then until that person reaches the age of 21)
Assessments under health and safety regulations and records of consultations with safety representatives and committees
Permanent
Medical records and details of biological tests under the Control of Lead at Work Regulations
40 years from the date of the last entry
Medical records as specified by the Control of Substances Hazardous to Health Regulations (COSHH)
40 years from the date of the last entry
Medical records under the Control of Asbestos at Work Regulations: medical records containing details of employees exposed to asbestos and medical examination certificates
40 years from the date of the last entry; (medical examination certificates) 4 years from the date of issue
Medical records under the Ionising Radiations Regulations 1999
until the person reaches 75 years of age, but in any event for at least 50 years
M. Property Records
Record Type
Retention Period
Management agreements, leases, licences to operate
Permanent
Building services statutory certificates and documents
6 years after end of agreement
Original Purchase/Sale Agreements
Permanent
Property Insurance Policies
Permanent
N. Tax Records
Record Type
Retention Period
Company tax returns, incl profit and loss for corporation tax
7 years
VAT returns
7 years
Capital gains tax returns
7 years
How you can request further information
If you have any questions or require details related to this Data Retention Policy, get in touch with our Data Protection Officer by
Emailing: dataprotection@nativeplaces.com
Or write to us at:
Data Protection Officer
Native
11-13 Bayley St
Bedford Square
London
England
WC1B 3HD
