Data Retention and Disposal Policy

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