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Data Retention Policy

1. Purpose

Understanding Recruitment Ltd needs to gather and process information pertaining to individuals. These individuals can include employees, candidates, contractors and other people that Understanding Recruitment may have a relationship with.

This policy outlines how long Understanding Recruitment retains personal information that is collected, processed and stored in compliance with Understanding Recruitment’s Data Protection Policy and all Data Protection legislation.

2. Internal Personnel Records

Document Type

Length of Retention and legal basis

Candidate records including application form/CV and interview notes for unsuccessful candidates

1 year from the last date of supply or introduction to any client (Conduct of Employment  Agencies and Employment Businesses Regulations 2003 (Conduct Regulations))

Employee passport, home address, national insurance number, references, emergency contact details,

6 years past the date of termination based on CIPD recommendation

Working time records:

48 hour opt out notice

Annual leave records

Absence records

6 years past the date of termination based on the time limitation to bring a claim

Bank details/payroll details/National Minimum Wage documentation

7 years past the date of termination based on the time limitation to bring a criminal/civil claim

Contract of employment

6 years past the date of termination based on the time limitation to bring a claim

Annual appraisal/ assessment records/ training and development records

6 years past the date of termination based on the time limitation to bring a claim

Criminal Declaration form/medical form

6 years past the date of termination based on the time limitation to bring a claim

Pension documents

6 years past the date of termination based on the Pension regulators recommendation

3. Candidate/Contractor Records

Document Type

Length of Retention and legal basis

Unplaced candidate records including application form/CV, notes from phone calls/ email correspondence

 

2 years past the last contact or   end of an introduction/interview process whichever is the later, based on legitimate interest for the work finding services we provide.

Permanent candidate’s passport/work Visa/ right to work in the UK  and other compliance and referencing paperwork collected.

 

6 years past start of employment or fixed term contract

in order to deal with any civil/criminal/financial action.

Successfully placed candidate records

6 years past the date of termination based on the time limitation to bring a claim

Contractor’s Limited Company/Right to Work/National Insurance number/home address/Bank Details and other compliance and referencing paperwork collected.

6 years past the end of the engagement in order to deal with any civil/criminal/financial action.

Terms of Engagement with temporary worker and Terms of Business with clients

6 years past the end of the engagement in order to deal with any civil action in the form of contractual claim (Limitation Act 1980).

4. Client Contact Records

Document Type

Length of Retention and legal basis

Contact name and number

Period of 6 years from the last placement in order to deal with any civil action or 2 years after our last contact, whichever expires last

5. Expiration of Retention Period

Upon expiration of the applicable retention period, the personal shall be reviewed by Understanding Recruitment and deleted, unless such retention is necessary for our legitimate business interests,  compliance with a legal obligation to which we are subject, or in order to protect the data subject’s vital interests or the vital interests of another natural person.

Where the personal data is stored in paper form, it will be disposed of using our confidential waste system.

Electronically stored information shall, where possible, be permanently deleted from both our live system and our back up  system.

Where a retention period has expired and the individual does not wish for Understanding Recruitment to contact them in the future or an individual no longer wishes for Understanding Recruitment to contact them but Understanding Recruitment has a legitimate business interest or legal obligation to hold that data, an anonymised record referencing an id number shall be kept to prevent future contact.

We may update this policy from time to time by publishing a new version

Edited: 10th April 2018

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