1. ABOUT THIS NOTICE

1.1 Our corporate information, records and data are important to how we conduct and manage our business and business relationships.

1.2 There are legal and regulatory requirements and other contractual retention obligations, which require us to retain certain data, usually for a specified amount of time. We also retain data to help our business operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to our business.

1.3 We are committed to complying with our duties by retaining those records securely and ensuring that they are destroyed in a timely and confidential manner.

2. SCOPE

2.1 This notice covers all data that we hold or have control over. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings and CCTV recordings. It applies to both personal data and non-personal data. In this notice we refer to this information and these records collectively as “data”.

2.2 This notice covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage.

2.3 This notice explains the differences between our formal or official records, disposable information, confidential information belonging to others, personal data and non-personal data. It also gives guidance on how we classify our data.

3. TYPES OF DATA

3.1 Formal or official records. Certain data is more important to us and is therefore listed in our Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business.

3.2 Disposable information. Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record. Examples may include:

• Duplicates of originals that have not been annotated.
• Preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record.
• Books, periodicals, manuals, training binders, which are retained primarily for reference purposes.
• Spam and junk mail.

3.3 Personal data. Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed.

4. RETENTION PERIODS

4.1 Formal or official records. Any data that is part of any of the categories listed in the Retention Schedule attached, will be retained for the amount of time indicated in the Retention Schedule. We will not retain a record beyond the period indicated in the Retention Schedule, unless a valid business reason (or notice to preserve documents for contemplated litigation or other special situation) calls for its continued retention.

4.2 Disposable information. The Retention Schedule will not set out retention periods for disposable information. This type of data should only be retained as long as it is needed for business purposes. Once it no longer has any business purpose or value it will be disposed of securely.

4.3 Personal data. We retain personal data for no longer than is necessary for the purposes for which it is processed. Where data is listed in the Retention Schedule, we have taken into account the principle of storage limitation and balanced this against our requirements to retain the data.

5. SPECIAL SITUATIONS

5.1 There will be occasions when certain records are relevant to litigation or disputes, government investigation, financial audit, compliance audit or other situations.

5.2 In these cases, we will preserve and not delete, dispose, destroy, or change those records, including emails and other electronic documents, until it is determined that those records are no longer needed. In these situations, we will suspend the requirements in the Retention Schedule and preserve the integrity of the electronic files or other format in which the records are kept.

5.3 We will also suspend any routine data disposal procedures in connection with certain other types of events, such as our merger with another organisation or the replacement of our information technology systems.

6. OTHER RELEVANT POLICIES

6.1 This notice should be read in conjunction with our other policies and procedures in force from time to time, including without limitation our:

• Information security policy
• Information handling and storage policy
• Privacy standard
• Confidentiality policy.
• And other IT, security and data related policies, which are available on request or to view

This privacy notice may change from time to time so we recommend that you review it periodically. This version of the privacy notice was last updated on 6^th June 2018.