A document retention policy is crucial when managing and protecting important records to avoid any criminal, civil and financial penalties that are mostly caused by bad data management practices. Although GDPR does not dictate how long you should keep personal data, organisations are encouraged to set their deadlines based on the personal information they hold. The only requirement under the GDPR is that the organisation must document and justify why it has set the time frame it has. Shredall SDS Group storage services allow businesses to store their documents off-site until the end of the statutory retention periods while having easy access to their documents. Each document can be indexed, giving a complete inventory, which can then be securely shredded at the end of its retention date.
A document retention policy is a set of internal guidelines created by a business to regulate how sensitive documents should be handled from the moment they’re created, through to a specified disposal date.
A retention period is the required amount of time you should keep your document before securely disposing of it. The minimum retention period depends on the type of document and what the document contains.
If your employees are regularly handling sensitive documents and information, there are several benefits to implementing a document retention policy. The main reason many companies create a DRP is for clarity in legal and regulatory investigations. Should your company ever be audited or investigated by a body like HMRC, being able to provide access to all current documents and show evidence of timely destruction of old documents is vital. Missing documents or records destroyed outside of a schedule can complicate these processes. More generally, a document retention policy helps a business to be compliant with data security regulations, at both an industry and national level. With GDPR imminent, compliance is more important than ever. Even if you already do things by the book, implementing a concrete policy helps to preserve compliance for the future and can help build trust with prospective clients or future customers. Finally, there is also a notable business benefit to a DRP. A detailed storage system and destruction schedule removes a lot of ambiguity around what to do with documents, cutting the time it takes to locate them and allowing you to plan for destruction dates. The clearer your business’s processes are, the easier it is for employees to work efficiently. A document retention policy is an important piece of that puzzle.
Data relating to PAYE, maternity pay, or statutory mandatory pay only needs to be kept for 3 years after an employee leaves your company. Beyond this, it’s unlikely you will have a legitimate reason for holiday pay information for ex-employees.
Employee data such as personal records, performance appraisals, employment contacts, etc. Should be stored for 6 years after the employee has left. Under the GDPR, the condition for processing would be a legal obligation or legitimate interest.
Tax returns should be kept for 3 years from the date you filed your original return or 2 years from the date you paid the tax, whichever is later.
In general, company records must be retained for around six years, however, some documentation needs to be kept for 10 years, including companies’ statutory books, VAT MOSS records and minutes of board meetings.
Here’s some further common recommended periods of retention dates and the minimum statutory retention period required for multiple document types.
| Type of Document | Statutory Minimum Retention Period | Recommended Period of Retention |
| Incorporated Documents | ||
| Certificate of Incorporation and Certificate on Change of Name | N/A | Permanently |
| Certificate to Commerce Business (Public Company) | N/A | Permanently |
| Statutory Returns, Records and Registers | ||
| Annual Return (copy) | N/A | Permanently |
| Return of Allotments (copy) | N/A | Permanently |
| Directors’ Service Contracts | 6 years after cessation | 6 years after cessation |
| Unpaid dividend records | N/A | 3 years from the instruction |
| Notification of address change by member | N/A | 2 years after notification |
| Share Registration Documents | ||
| Register of Members | N/A | Permanently |
| Powers of Attorney | N/A | Permanently |
| Contacts for purchase of own shares by company | N/A | Period of retention 10 years from date of contract |
| Dividend and interest payments lists | N/A | Until audit of the dividend payment is complete |
| Paid dividend and interest warrants | N/A | 6 years after date of payment |
| Bank Records | ||
| Annual report and accounts (signed) | N/A | Permanently |
| Annual report and accounts (unsigned) | N/A | Permanently (keep sufficient copies to meet requests) |
| Taxation records and tax returns | Inspection possible up to 6 years after tax/accounting period | Permanently |
| VAT Records and Customs & Excise Returns | Inspection may be conducted up to 6 years after tax/accounting period | Permanently |
| Public Company | 6 years | 10 years |
| Limited Company | 3 years | 10 years |
| Expense Accounts | N/A | 7 years |
| Cheques, bills of exchange and other negotiable instruments | N/A | 6 years |
| Statements from and instructions to the bank | N/A | 6 years after ceasing to be effective |
| Budgets, forecasts and periodic internal financial reports | N/A | 5 years |
| Contracts | ||
| Trust deeds and rules (pension schemes) | N/A | Permanently |
| Contracts with customers, suppliers, agents or others | N/A | 6 years after expiry or contract completion |
| Rental and hire purchase agreements | N/A | 6 years after expiry |
| Licensing agreements | N/A | 6 years after expiry |
| Insurance | ||
| Product/public liability policies | N/A | Permanently |
| Employers’ liability policies | 40 years | Permanently |
| Accident report book and relevant records | 3 years from date of entry (Health & Safety at work Act 1974 S7) | Permanently |
| Health & Safety policy documents | Implied permanently by Health & Safety at work Act (1974 S2(3) | Permanently |
| Group health policies | N/A | 12 years after final cessation of benefit |
| Medical Records- general | N/A | 12 years |
| Employee Records | ||
| Employment Agreements | N/A | Permanently |
| Income tax records (P45/P60/P58/P48 etc.) & Annual return of taxable pay and tax paid | 6 years | 12 years |
| Payroll and wage records (including details of overtime, bonuses and expenses) | 6 years | 12 years |
| Personnel Record | N/A | 7 years after employment ceases, with permanent microfilmed record |
| Training Records | N/A | 6 years after employment ceases |
| Salary Records | N/A | 5 years |
| Job applications and interview records | N/A | Up to 1 year |
| Material with Copyright Protection | ||
| Literary, dramatic and musical works | N/A | Life plus 50 years |
| Artistic works, recordings, films, photos and broadcasts | N/A | 50 years |
| Property Documents | ||
| Leases | N/A | 12 years after lease and liabilities under the lease have terminated |
| Title deeds for property | N/A | Permanently or until sold or transferred |
| Medical Records | ||
| X-Ray Registers | 30 years | |
| Child Protection Registers | 26 years | |
| Audiology, Dietetic and Nutrition, District Nursing, Occupational Therapy, Physiotherapy, Podiatry and Language Therapy | 20 years | |
| Dental Records | 11 years | |
| X-Rays | 8 years | |
| Incident forms | 8 years | |
| Admission/Discharge books | 8 Years | |
| Personnel records | 6 years | |
The thought of knowing where to start with all your documents can be overwhelming. It all starts with a good clear out and document management. Below are our top three tips to help you get started with your document retention: Prepare your documents- Depending on the industry, the rules for audit procedures vary. To ensure a successful audit, identify what you will be expected to provide and be prepared to comply with these requirements. Inventory- Each department should be responsible for a complete inventory of their records, identifying which records can be sent to storage and which can be securely shredded. Keep on top of your inventory to ensure it is up to date and accurate so you can retrieve records promptly. Retention Schedule- A retention schedule is a policy document that defines a business’s legal and compliance recordkeeping requirements. It is intended to ensure that employees adhere to approved record keeping requirements. This should apply to both electronic and paper documents and should be updated every 12 to 18 months. If your business needs support with storing documents for the duration of their retention periods or shredding them when possible, get in touch with our team today.
