1. Purpose
1.1 The purpose of this policy is to detail the procedures for the retention and disposal of information to ensure that we carry this out consistently and that we fully document any actions taken. Unless otherwise specified the retention and disposal policy refers to both hard and soft copy documents.
2. How long we should keep our paper records
2.1 Records should be kept for as long as they are needed to meet the operational needs of Payzone, together with legal and regulatory requirements.
2.2 We should regularly review the retention periods for different categories of information to determine whether they should be destroyed or retained for a further period. However, detailed in the record retention schedule below are the retention periods we should apply to the relevant information, unless otherwise advised by Payzone’s Data Protection Officer or members of the Senior Management team.
3. Destruction of records
3.1 Records can be destroyed in the following ways:
• Non-sensitive information – can be placed in a normal rubbish bin
• Confidential information – cross cut shredded and pulped or burnt.
• Electronic equipment containing information - destroyed using killdisc and for individual folders, they will be permanently deleted from the system.
3.2 Destruction of electronic records should render them non-recoverable even using forensic data recovery techniques.
4. Records of destructions
4.1 We do not need to document the disposal of records which have been listed on the records retention schedule. Documents disposed of other than in accordance with that schedule (either by being disposed of earlier or kept for longer than listed) will need to be recorded for audit purposes.
5. Review
5.1 Responsibility for reviewing this policy (including reviewing the retention periods for different categories of information) rests with the Data Protection Officer. The policy should be reviewed annually.
Disposal Schedule - Customer/Merchant Operational Information
|
Business Function |
Description |
Retention Period |
Comments |
|
Pre-Sales |
Prospect data. |
As appropriate and 12 Months |
Retained as necessary dependent on the stage in the sales process. Negative data will be destroyed within a 12-month period |
|
|
Customer details: Name |
7 years |
|
|
|
Customer details: Date of Birth |
7 years |
|
|
|
Customer details: Address |
7 years |
|
|
|
Customer details: Telephone Number (Landline) |
7 years |
|
|
|
Customer details: Telephone Number (Mobile) |
7 years |
|
|
|
Customer details: Application rejected by Acquirer (Credit Referencing) – Card Acceptance Merchants only |
7 years |
This information will only be held where the acquirer has rejected an application from a merchant resulting from the credit reference report |
|
|
Customer details: Experian Credit Reference – Successful applications (Convenience) |
Contract term + 7 years |
|
|
|
Customer details: Experian Credit Reference – Unsuccessful applications (Convenience) |
7 years |
|
|
|
Customer details: Application rejected by Payzone (Credit Referencing) – Convenience (Bill Payment) Only or Convenience (Bill Payment) plus Card Acceptance service merchants only |
7 years |
This information will only be held where Payzone has rejected an application from a merchant resulting from the credit reference report |
|
Sales Enablement |
|
|
|
|
Boarding |
Customer details: Name |
Contract term + 7 years |
|
|
Boarding |
Customer details: Date of Birth |
Contract term + 7 years |
|
|
Boarding |
Customer details: Address |
Contract term + 7 years |
|
|
Boarding |
Customer details: Telephone Number (Landline) |
Contract term + 7 years |
|
|
Boarding |
Customer details: Telephone Number (Mobile) |
Contract term + 7 years |
|
|
Boarding |
Customer details: Email address |
Contract term + 7 years |
|
|
Boarding |
Customer details: Identity Verification Document 1 |
Contract term + 7 years |
Any document from the following list:
1) Unexpired passport 2) Driving licence 3) National Identity Card |
|
Boarding |
Customer details: Identity Verification Document 2 |
Contract term + 7 years |
Any document from the following list:
1) Unexpired passport 2) Driving licence 3) National Identity Card |
|
Boarding |
Customer details: Address Verification Document |
Contract term + 7 years |
Any document from the following list:
1) Notification for Tax Credit 2) Notification for entitlement to pension from DWP 3) Notification to a government grant 4) Utility Bill 5) HMRC Tax Statement 6) Mortgage statement 7) Council Tax Bill 8) Business Insurance Certificate 9) VOA Business rates document 10) Credit Card Statement 11) Marriage certificate 12) Deed poll certificates (Change of name) |
|
Boarding |
Customer details: Bank details |
Contract term + 7 years |
|
|
Boarding |
Customer details: Bank confirmation |
Contract term + 7 years |
Bank statement, voided cheque or paying in slip |
|
Boarding |
Business details: Business Plan |
Contract term + 7 years |
|
|
Boarding |
Business details: Financial record from Companies House |
Contract term + 7 years |
|
|
Boarding |
Business details: Audited Company Accounts |
Contract term + 7 years |
|
|
Boarding |
Business details: Solicitors or accounts letters showing personal details of owners/shareholders |
Contract term + 7 years |
|
|
Boarding |
Business details: Owners / shareholders list |
Contract term + 7 years |
|
|
Boarding |
Business details: Official Partnership Agreement |
Contract term + 7 years |
|
|
Boarding |
Business details: Tenancy Agreement for business premises |
Contract term + 7 years |
|
|
Boarding |
Business details: Customer bank details for taking payments |
Contract term + 7 years |
|
|
Boarding |
Business details: Acquirer Contract |
Contract term + 7 years |
|
|
Boarding |
Business details: Acquirer statement (for Merchants who are changing merchant acquirers) |
Contract term + 7 years |
|
Finance Records
|
Business Function |
Description |
Retention Period |
Comments |
|
Finance |
Finance Documents |
7 years |
|
|
Financial management – bank, petty cash and creditors records, misc. |
Paid/presented cheques and records of all cheques drawn for payment
|
6 years |
|
|
|
All other cheque records – cheque books received, butts, cancelled etc |
2 years |
|
|
|
Bank statements and reconciliations |
6 years |
|
|
|
Electronic banking – transactions, payment files, deposits, withdrawals and audit trail |
As per paper records |
|
|
|
All petty cash records |
6 years |
|
|
|
Creditors history records, lists and reports |
6 years |
|
|
|
Statements of accounts |
2 years |
|
|
|
Fraud and theft |
6 years (minor matters) / 10 years (non-minor matters) |
|
|
Financial management – ledger records |
General ledger produced for purposes of preparing certified financial statements |
6 years |
|
|
|
Creditor ledger |
6 years |
|
|
|
Other ledgers and related audit trails |
6 years |
|
|
|
Journals – prime record for raising charge |
6 years |
|
|
|
Journals -adjustments |
6 years |
|
|
|
Reconciliations Year End |
6 years |
|
|
|
Assets and depreciation registers |
6 years on disposal of last asset |
|
|
|
Annual and quarterly financial statements |
6 years |
|
|
|
Periodic financial statements |
Destroy when cumulated into quarterly or annual reports |
|
|
Financial management – PO (Purchase Order) records |
PO records |
6 years |
|
|
Financial management - Income |
Debtors records and invoices |
6 years |
|
|
|
Credit notes and refunds |
6 years |
|
|
|
Records relating to unrecoverable revenue (bad debts, overpayments) |
6 years (minor matters) / 10 years (non-minor matters) |
|
|
|
Revenue records |
6 years |
|
|
Merchant Information |
Contact data Bank details Legal proceeding docs Contract info |
Contract length plus 6 years |
|
|
|
Bank details |
Contract length plus 6 years |
|
|
|
Legal proceeding documents |
Contract length plus 6 years |
|
|
|
Contract information |
Contract length plus 6 years |
|
|
Financial management – internal and external audit |
External audit investigations
|
6 years after completion |
|
|
|
Audit report that includes long-term contracts |
6 years |
|
|
|
Report papers used in course of fraud investigation |
6 years |
|
|
|
Other audit reports |
3 years |
|
|
|
Internal audit guides, manuals, and guides relating to departmental procedures and local auditing standards |
Indefinitely, replaced with updates as and when necessary |
|
Disposal Schedule - Governance and Operations: Human Resources and Payroll Records
|
Business Function |
Description |
Retention Period |
Comments |
|
Human Resources |
Human Resources Documents |
|
|
|
Employee Files |
Paper and hardcopy employee files |
6 years after the employee leaves the organisation. |
The Limitations Act 1980 (to reflect that legal proceedings must start within 6 years) |
|
Income Tax Records and Wages |
Income tax and NI returns, income tax records and correspondence with the Inland Revenue |
Not less than 3 years after the end of the financial year to which they relate |
The Income Tax (Employments) Regulations 1993 (SI 1993/744) as amended, for example by The Income Tax (Employments) (Amendment No. 6) Regulations 1996 (SI 1996/2631) |
|
|
Wage/salary records (also overtime, bonuses, expenses) |
6 years |
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 |
|
Pension and Retirement |
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 |
The Retirement Benefits Schemes (Information Powers) Regulations 1995 (SI 1995/3103) |
|
Payroll and HR Policies |
Staff handbook, clear desk policies etc |
Perpetual |
Retain most recent / updated version |
|
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 (SI 1986/1960) as amended |
|
|
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 (SI 1982/894) as amended |
|
Employee Files – General Exceptions |
Records relating to working time |
2 years from date on which they were made |
The Working Time Regulations 1998 (SI 1998/1833) |
|
|
Accident books, accident records/reports |
3 years after the date of the last entry |
The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) (SI 1995/3163) as amended. |
|
Financial management – Payroll/Pension |
Employee current and pay histories (equal Pay register) |
7 years after the employee leaves the organisation |
|
|
|
Internal Payroll Spreadsheet |
7 years after the employee leaves the organisation |
|
|
|
Sage reports |
7 years after the employee leaves the organisation |
|
|
|
Internal Pension Report Pension for Aegon |
7 years after the employee leaves the organisation |
|
|
|
Child care vouchers, CSA payments |
7 years after the employee leaves the organisation |
|
|
|
HMRC tax deduction data (P45 & P60 data) |
7 years after the employee leaves the organisation |
|
|
|
P11d’s Car and medical benefits |
7 years after the employee leaves the organisation |
|
|
|
Office of national statistics data |
7 years after the employee leaves the organisation |
|
|
|
Company Loan data |
7 years after the employee leaves the organisation |
|
