Retention of records

1.  Set and follow standard retention times for categories of information held on the records of employees, workers and former workers.  Base the retention times on your business needs,  taking into account any relevant professional guidelines and a risk analysis approach.  Records should only be retained for a particular purpose and should not be kept for longer than is necessary for that purpose.  Refer to the Information Commissioner: Employment Practices Codes: Part 1: Recruitment and Selection and Part 2: Employment Records for further guidance on retention times.

2.  Be aware of statutory requirements to retain records, for example in relation to income tax or certain aspects of health and safety, as those requirements override data protection guidance on retention of records. 

3.  Identify  who, within the Company, retains employment records.   Provide training on the retention of records to those persons.   

4.  Ensure no one retains information beyond the standard retention times, unless there is a sound business reason for doing so.   

5.  Consider establishing a computerised system that flags when information has been retained for more than a certain time.    

6.  Anonymise any data about former and current employees and workers,  where this is practicable.   If necessary, create new documents setting out only the information that needs to be retained. 

7.  In relation to recruitment records: ensure that recruitment records are not held beyond the statutory period in which a claim arising from the recruitment process may be brought, unless there is a clear business reason for exceeding this period.