The purpose of this policy is to detail procedures for the retention and disposal of information and personal data. This policy refers to both hard and soft copy documents, unless specifically stated otherwise.
This policy covers all data collected by and stored on the Company owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).
The Company retains only that data that is necessary to effectively conduct its program activities, fulfil its mission and comply with applicable laws and regulations. Reasons for data retention include:
Each department processing personal data must go through its ‘closed records’ at least every 6 months to determine whether the records should be destroyed, retained for a further period or transferred to an archive for permanent preservation.
Is it necessary as a source of information for operations at Top Impact Limited? | Is it necessary as evidence of business activities and decisions? | Is it necessary because of legal or regulatory retention requirements? |
No destruction of a record should take place without assurance that:
Records should be destroyed in the following ways:
Non-sensitive information | Information/records that are clearly in the ‘public domain’ can be placed in a normal recycling rubbish bin |
Confidential information | Must be cross cut shredded and placed in paper rubbish sacks for collection by an approved disposal firm. |
Electronic devices containing information (must be overseen by the Head of IT) | Option 1 – ‘Factory’ system restoreOption 2 – destroy all information using specialised software programs. Top Impact Limited may work with approved contractors to recycle redundant IT equipment and must securely sanitise all hard drives. A certificate confirming the complete destruction of records must be provided by the contractors. Equipment must be kept in a secure location until collected. Managers of each department must ensure locally stored confidential information is removed as appropriate before a device is reassigned to another person in their team. |
Disposal Schedule (Should you become aware of any records missing from the schedule, please notify the Company so that they may be added at the next opportunity). | |||
Heading | Description | Retention Period | Comments |
Payroll | Employee pay records | for the period of employment plus six 6 years after the employee leaves the organisation | |
Salary records | for the period of employment plus six 6 years after the employee leaves the organisation | ||
Copy of payroll sheets | for the period of employment plus six 6 years after the employee leaves the organisation | ||
Employee Files | Paper and hardcopy employee files | for the period of employment plus six 6 years after the employee leaves the organisation | Limitations Act 1980 |
Income Tax Records and Wages | Income Tax and NI returns, Income tax records and correspondence with the Inland Revenue | At least 3 years after the end of the financial year to which they relate. | The Income Tax (Employments) Regulations 1993 |
Wages/salary records (including overtime, bonuses, expenses) | for the period of employment plus six 6 years after the employee leaves the organisation | Taxes Management Act 1970 | |
National minimum wage records | 3 years after the end of the pay reference period following the one that the records cover | National Minimum Wage Act 1998 | |
Pensions and Retirement | Autoenrollment member and scheme details | for the period of employment plus six 6 years after the employee leaves the organisation | Autoenrollment regulations |
Sickness records | 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 | The Statutory Maternity Pay (General) Regulations 1986 |
Statutory Sick Pay records, calculations, certificates, self-certificates | 3 years after the end of the tax year to which they relate | The Statutory Sick Pay (General) Regulations 1982 | |
Employee Files – General Exceptions | Records relating to working time | 2 years from the date on which they were made | The Working Time Regulations 1998 |
Accident books, accident records/report | 3 years after the date of the last entry | The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995. |
Questions, comments, complaints and requests regarding this policy are welcomed and should be addressed to our office address, The Ivories, 6-18 Northampton Street, London, England, N1 2HY or to our Data Protection Officer at dpo@topimpact.co.uk. In addition, please do not hesitate to contact us if you suspect any privacy or security breaches.
This policy supplements and should be read in conjunction with our other policies and procedures in force from time to time, including without limitation our: