INTRODUCTION

As part of the day-to-day running of our business, we collect and process personal data from a variety of sources. This personal information is collated in several different formats including letters, emails, legal documents, employment records, operations records, images and statements. The personal data is stored both as a hard copy and in electronic form. 

AIMS OF THE POLICY 

Our business will ensure that the personal data that we hold is kept secure and that it is held for no longer than is necessary for the purposes for which it is being processed. In addition, we will retain the minimum amount of information to fulfil our statutory obligations and the provision of goods or/and services – as required by data protection legislation, including the General Data Protection Regulation (GDPR). 

RETENTION

This retention policy (along with its schedule) is a tool used to assist us in making decisions on whether a particular document should be retained or disposed of. In addition, it takes account of the context within which the personal data is being processed and our business practices.

Decisions around retention and disposal are to be taken in accordance with this policy.

As and when the retention period for a specific document has expired, a review is always to be carried out prior to the disposal of the document. This does not have to be time-consuming or complex. If a decision is reached to dispose of a document, careful consideration is to be given to the method of disposal.

RESPONSIBILITY 

Gatotech Ltd is responsible for keeping this retention schedule up to date in order to reflect changing business needs, new legislation, changing perceptions of risk management and new priorities for our business.

Gatotech Ltd is responsible for determining (in accordance with this Policy) whether to retain or dispose of specific documents.

Gatotech Ltd may delegate the operational aspect of this function to its appropriately qualified and vetted staff.

Gatotech Ltd should inform its Data Protection Officer (DPO) or Data Representative if there is any doubt about the minimum retention periods or if the retention of a document is necessary for a potential claim. 

DISPOSAL

Our business must ensure that personal data is securely disposed of when it is no longer needed. This will reduce the risk that it will become inaccurate, out of date or irrelevant.

The methods of disposal are to be appropriate to the nature and sensitivity of the documents concerned and include: 

• Non-Confidential records: place in waste paper bin for disposal.

• Confidential records: shred documents.

• Electronic Records: Deletion of Computer records and backups.

The table below contains the retention period that we have assigned to each type of record. This will be adhered to wherever possible, although it is recognised that there may be exceptional circumstances which require documents to be kept for either shorter or longer periods. 

Exceptional circumstances should be reported to Gatotech Ltd without delay. 

SCHEDULE

(excerpt from internal schedule)

• Customer Data: to be retained for the life of an account and for seven (07) years after an accounts closure.

• Providers Data: to be retained for the life of an account and for seven (07) years after an accounts closure.

• Technical Support: emails and records to be retained for two (02) years after last usage.

• Staff Recruitment: applications and documents to be retained for twelve (12) months after conclusion of hiring process.

Date Created: 16 May 2024.

Last updated: 16 May 2024.