Data Retention Policy

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Table of Contents

Working together to deliver quality homes and a better environment for all

Data Retention Policy

Lead officer: Mark S Thompson Date agreed: December 2013 EIA completed December 2013 Review date: December 2015

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1. Introduction... 3

2. Aims ... 3

3. Scope ... 3

4. Definitions... 4

5. Storage of Documents ... 4

6. Other Documents to be Read in Conjunction ... 6

7. Monitoring and Review ... 6

8. Data Retention Tables ... 7

8.1. Finance – Budgets & Financial Control ... 7

8.2. Finance – Staff ... 7

8.3. Contracts & Orders ... 8

8.4. Capital Assets - Housing ... 9

8.5. M&E Servicing – Houses ... 10

8.6. Aid & Adaptations ... 11

8.7. Flat Blocks and Sheltered Housing ... 11

8.8. Leaseholders ... 12

8.9. EDH equipment and Buildings ... 12

8.10. Health & Safety ... 12

8.11. Governance ... 13

8.12. Audits ... 14

8.13. Insurance ... 15

8.14. Rents & Rent Arrears ... 15

8.15. Anti-Social Behaviour ... 15

8.16. Tenancy Support ... 16

8.17. Tenancy Services and Applications ... 16

8.18. Marketing and Communications ... 17

8.19. Equality and Diversity ... 17

8.20. Performance & Quality ... 18

8.21. Strategy & Policy ... 19

8.22. Human Resources ... 19

8.23. Meetings ... 21

8.24. Business Planning ... 22

8.25. Complaints, Compliments and Surveys ... 23

8.26. Information Security ... 23

8.27. Legal Advice ... 24

8.28. Customer Contact & Correspondence ... 24

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1. Introduction

This policy is to address the question of how long East Durham Homes (EDH) should keep information. This is important for a number of reasons:

1. Information storage has a cost whether it is on paper or on computer. Keeping information when it is no longer required is wasting money. 2. The fifth principle of the Data Protection Act 1998 requires that

personal data processed for any purpose "shall not be kept for longer than is necessary for that purpose".

3. Some information degrades over time and will eventually lose its value e.g. report on the condition of a property or a tenant’s rent arrears. 4. Information requests under the Data Protection Act or the Freedom of

Information Act require EDH to disclose all information held. Holding unnecessary and potentially wrong information will increase the cost of processing such requests and could lead to requests to remove old and incorrect information.

The policy had been written using external guides, examples from similar organisations and in consultation with EDH staff.

2. Aims

The aim of the policy is to advice EDH staff on how they should manage the information that they hold. Its key purposes are to determine what information should be held and how long it should be held for. It also identifies who is responsible for reviewing the information EDH holds and making

arrangements for appropriate disposal.

3. Scope

This Policy applies to all permanent and temporary EDH employees and Board Directors.

Each member of staff is responsible for ensuring that any data they store is, as far as possible, accurate and complete. Staff are also responsible for bringing to the attention of their manager when they notice incorrect or incomplete information held in EDH’s records.

This policy identifies what information is held by EDH. This will change over time and the Data Retention tables will need regular review and updating as the information we hold changes.

Data Retention periods are set for a number of reasons. These include

statutory requirements, Company policy or good practice. Legal requirements will always take precedence. Generally, statutory requirements define the minimum time that information should be kept. The Data Protection Act takes

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necessary. It does not however, make any specific statements on what the necessary period is. This will need to be determined by EDH based on their business need.

If there is no specific guidance, the Limitation Act of 1980 is followed. This act in many cases sets a six year period after an event has occurred for keeping documents. This can be after employment ceases (for employment records and personnel charts) or the resolution date for a whistleblowing event or termination of a contract with suppliers, agents etc.

The policy also considers an intermediate stage where documents that are no longer required for immediate access are stored off-site for a set period before they are disposed of.

4. Definitions

Acronym Meaning

ACOP Approved Code of Practice. HSE Construction (Design and Management) Regulations 2007,

DCC Durham County Council

DPA Data Protection Act 1998

IPD Institute of Personnel and Development

NHF National Housing Federation

PPE Personal Protective Equipment

RIDDOR Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013

RMS Records Management Society

SMPR Statutory Maternity & Pay regulations 1982

5. Storage of Documents

EDH holds a wide range of data on our business, our staff, our tenants and our properties. It will be held in a range of physical and computerised forms. The Data Retention tables in this policy describe what information is held, the retention period and who is responsible for review and disposal of redundant data.

Archiving and deletion of emails

Email is a very effective way of communicating but without regular reviews can quickly clog up your computer and make information difficult to find. If you keep large numbers of emails in your inbox it will slow your computer down.

It is recommended that the following steps are followed to manage your email.

 Immediately delete emails that do not need to be kept. This would include things such as promotional messages, personal messages,

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 Emails containing reports or meeting notes should be deleted having saved the document if it is required. Please try to save documents in shared areas or on SharePoint so that there are not multiple copies of the same document.

 Try to avoid sending emails with large attachments to many people. Put the document on SharePoint and email the link

 Consider if you need to keep emails if you are just ‘copied in’ to the message. Do not unnecessarily copy people in to emails.

 Consider if any emails over a certain age are required. How often do you look back at old emails? Consider if you could set a period after which all emails should be deleted.

 Important emails related to a particular business activity can be saved in the folders where all other related documents are stored. They can then be deleted from the email system.

 If all the information related to a topic is saved on paper, print off the email and save with the other documentation. Then delete the email.

 Consider that emails could be part of a Data Protection Act or Freedom of Information request. If we receive a request we are legally obliged to provide all details we hold. This could take a great deal of time. Note: It is a criminal offence to destroy information after a request for that information has been received.

 Only keep emails where there is a clear business need to have a record.

Disposal of Information

When staff are planning disposal of information, they should take special care to decide if the information could contain confidential or personal information. If there is any doubt, it should be treated as confidential information and disposed of accordingly.

 Confidential paper information must be disposed of in the secure confidential waste bins located at Meridian Court

 Non-confidential paper information must be disposed of in the normal green waste bins located at Meridian Court

 Electronic information held on company computers or servers can be deleted. Please seek advice from the ICT team if you are unsure of the best way of disposing of confidential information

 Confidential information held on DVD’s or CD’s should be disposed of by placing the disks in the confidential waste bins.

 Confidential information held on portable hard drives or memory sticks should be passed to the ICT team for secure wiping.

Disposal of documents stored off-site.

EDH has an off-site storage facility where documents can be stored until no longer needed. The facility is managed by the Finance team who maintain a log of the stored material. At the agreed time the Finance team will make arrangements for disposal and keep a log. Staff wishing to use the facility must contact the Finance team for instructions.

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Consideration when setting up a new information store

Staff need to consider how to archive / delete information when they first set up a new information store. It is much harder to plan at a later date. Planning should consider the frequency of review, the duration that information is to be held and how information will be disposed of.

6. Other Documents to be Read in Conjunction

 EDH Data Protection Policy

 DCC Retention Guidelines 2012

 National Housing Federation – Document Retention for Housing Associations

 Records Management Society – Retention Guidelines for Local Authorities 2003:1

7. Monitoring and Review

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8. Data Retention Tables

8.1. Finance – Budgets & Financial Control

Information Retention Period Justification Responsibility for Information

Bank Accounts 6 years from end

of accounting period or disposal of asset Statutory / EDH recommendation Finance Department

Expenditures As above As above Finance Department

Ledgers As above As above Finance Department

Receipts and Revenue As above As above Finance Department

All Financial Data (that can be audited) As above As above Finance Department

8.2. Finance – Staff

Payroll information 6 years from end

of accounting period

Statutory / EDH recommendation

Finance Department

Staff Tax information As above Statutory / EDH

recommendation

Finance Department

Expenses forms As above Statutory / EDH

recommendation

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Mileage claim forms As above Statutory / EDH

recommendation

Finance Department

Pension information Permanent NHF recommendation Finance Department

Records of proof of insurance and driving licence 7 years RMS recommendation Finance Department

Statutory sick & maternity pay 3 years Statutory, DCC

guidelines

Finance Department

8.3. Contracts & Orders

Information Retention Period Justification Responsibility for Information Tender Documentation – successful tenders 6 years after end

of contract. 12 years after end of contract for contracts under seal Statutory Limitations Act 1980. NHF recommendation Refer to EDH SFI’s

Finance Department

Tender evaluation documentation As above Statutory Limitations Act 1980.

RMS guidelines Refer to EDH SFI’s

Finance Department

Tender Documentation – unsuccessful tenders 2 years after end of contract

Statutory Limitations Act 1980.

NHF recommendation Refer to EDH SFI’s

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Information Retention Period Justification Responsibility for Information Contracts for supply of goods or services 6 years after

completion (incl any defects liability period)

Statutory Limitations Act 1980.

NHF recommendation. Refer to EDH SFI’s

Finance Department

Documentation related to one-off purchases (purchase orders)

6 years Company policy.

Refer to EDH SFI’s Finance Department Rental & Hire Purchase agreements 6 years after expiry Statutory Limitations

Act 1980.

NHF recommendation. Refer to EDH SFI’s

Finance Department

Service Level Agreements with suppliers 6 years Company policy.

Refer to EDH SFI’s Finance Department

8.4. Capital Assets - Housing

Capital budget and expenditure 6 years EDH recommendation Finance Department

Housing Asset register – PIMSS Permanent Decent Homes

Manager

Housing Repairs information – Orchard Permanent EDH recommendation Head of Neigh’d Services R&T Decent Homes programme documents 6 years after

completion

EDH recommendation Decent Homes Manager

Decent Homes reports 6 years EDH recommendation Decent Homes

Manager

Right to Buy purchases 12 years after

purchase

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Plans and drawings of properties Permanent Good practice Adaptations and

Asbestos Manager Asbestos survey records for houses Permanent Good practice Adaptations and

Asbestos Manager

Asbestos removal records Permanent Good practice Adaptations and

Asbestos Manager Void Inspection records e.g. Inspection sheets,

handover documents, recharge info

Permanent Company policy R & M Manager Cyclical maintenance records e.g. painting, one-off

schemes , servicing contracts

Permanent Company policy R & M Manager

Tenant Home improvements Permanent Company policy R & M Manager

R&M Invoicing Permanent Company Policy R & M Manager

8.5. M&E Servicing – Houses

Gas Safety certificates Min 3 years Gas Safety (Inst. &

Use) Regulations 1998

Repairs & Technical

Solid Fuel safety certificates Min 3 years Legal Repairs & Technical

Building Regulations certificates Permanent Legal Repairs & Technical

Electrical periodic inspections 10 years Legal Repairs & Technical

Electrical minor works certificates 10 years Legal Repairs & Technical

Electrical domestic installation certificates 10 years Legal Repairs & Technical

Certificate of compliance 10 years Legal Repairs & Technical

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8.6. Aid & Adaptations

Information Retention Period Justification Responsibility for Information Property adaptation recommendations Permanent Good practice Adaptations and

Asbestos Manager Zurich stair lift / through lift inspection reports 5 years Legal Adaptations and

Asbestos Manager Occupation Therapy reports (currently retain paper

records and computer copy)

TBC Medical records

legislation

Occupational Therapist

8.7. Flat Blocks and Sheltered Housing

Information Retention Period Justification Responsibility for Information Fire Safety checks - Flat Block– Some held on HUB

system and some on paper records

Permanent Fire Brigade Recommendation

H&S Advisor Electrical checks - Flat Blocks & Sheltered Housing

(carried out every 5 years)

Keep latest copy only

Legal Facilities Officer

Fire Risk Assessment - Flat Blocks & Sheltered Housing

Permanent Legal H&S Advisor

Gas Servicing – Sheltered Housing (carried out every year)

Keep only latest copy

Legal Facilities Officer

Weekly Health & Safety checks – Sheltered Housing

Permanent Legal H&S Advisor

Legionella checks – Sheltered Housing 5 years Legionnaire’s Code of Practice

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8.8. Leaseholders

Information Retention Period Justification Responsibility for Information Leases and attached service charge data 12 years EDH recommendation Finance Department Leasehold property information (on Housing

Management system)

Permanent Cannot be removed from system

Finance Department

8.9. EDH equipment and Buildings

Legionella testing records 5 years Legionnaire’s Code of

Practice

Facilities Officer

Asbestos records – EDH offices Permanent Good practice Facilities Officer

PAT testing records 3 years Electrical regulations Facilities Officer

Fire Alarm testing / emergency light testing / fixed wiring testing

3 years Electrical regulations Facilities Officer

Gas safety certificates – EDH offices 2 years ACOP Facilities Officer

Fire Extinguishers – EDH offices 2 years ACOP Facilities Officer

8.10. Health & Safety

Information Retention Period Justification Responsibility for Information Staff Health & Safety assessment (incl workstation

assessments) - as part of employee records

Min 6 years after end of employment

RMS guidelines HR Department Health & Safety policies See Strategy &

Policy section

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Issue of PPE equipment 6 years PPE Regulations 2002 H&S Advisor

Staff medical records related to asbestos – held as part of employee records

Permanent In case of litigation. HR Department

Records of client incidents Assessed on an

individual basis

Health & safety of staff and tenants

H&S Advisor Accidents / Incidents – staff

If accident involves a person under 18, then record must be kept for minimum of 3 years after 21st birthday.

If asbestos exposure then minimum of 40 years with copy to GP

Minimum of 3 years but we keep indefinitely in case of litigation.

RIDDOR H&S Advisor

Accidents / Incidents – tenants

If accident involves a person under 18, then record must be kept for minimum of 3 years after 21st birthday.

If asbestos exposure then minimum of 40 years with copy to GP

Minimum of 3 years but we keep indefinitely in case of litigation.

RIDDOR H&S Advisor

8.11. Governance

Information Retention Period Justification Responsibility for Information Board papers and minutes – Final Permanent for final

papers.

Company Policy Governance Team Board papers and minutes – drafts, working papers Delete when

finalised

Company Policy Governance Team Panel papers and minutes – Final Permanent for final

papers.

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Information Retention Period Justification Responsibility for Information Panel papers and minutes – drafts, working papers Delete when

finalised

Company Policy Governance Team Memorandum and Articles of Association Permanent Company Policy Governance Team

Housing Management Agreement Permanent Company Policy Governance Team

Board Director Appointment letters Permanent Company Policy Governance Team

Board Director Records Min 6 years after

end of directorship

RMS guidelines.

May need to keep past 6 years where there is likelihood of litigation.

Governance Team

Board Director Application forms (unsuccessful) 1 Year Company Policy Governance Team Board Director E&D Profile Questionnaire Until updated Company Policy Governance Team Spreadsheet of Board Director profile data relating

to Board and Panel reports

Delete

spreadsheet when report complete

Equality Act 2010; Public Sector equality duty

E&D Officer

Annual Return – done on-line at Companies House Not kept Legal Governance Team

Financial Statements 6 years Legal Governance Team

Register of Interest Permanent Company Policy Governance Team

Register of seal Permanent Legal Governance Team

Copy of Board Director expenses claim forms 6 years after end of directorship

Company Policy Governance Team Board Director training records 6 years after end

of directorship

Company Policy Governance Team

Deed of Waiver Permanent Legal Governance Team

8.12. Audits

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Information Retention Period Justification Responsibility for Information Internal Audits & correspondence Keep until

superseded

Good Practice Relevant Manager External Audits & correspondence Keep until

superseded

Good Practice Relevant Manager

8.13. Insurance

Information Retention Period Justification Responsibility for Information Claims information. Some cases will need to stay

open beyond 6 years until resolved.

6 years EDH recommendation Finance Department

Policy information Permanent NHF recommendation Finance Department

Employers Liability Insurance 40 years NHF recommendation Finance Department

8.14. Rents & Rent Arrears

Information Retention Period Justification Responsibility for Information Rent Account Information – Orchard HMS Permanent Good Practice Tenancy Support

Correspondence related to arrears Permanent Good Practice Tenancy Support

Court Papers for rent arrears Permanent Good Practice Tenancy Support

Housing benefit information Permanent Good Practice Tenancy Support

8.15. Anti-Social Behaviour

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ASB case material – HUB Caseworks Permanent Legal ASB Team

ASB case material – paperwork Permanent Legal ASB Team

High Level Domestic violence cases (MARAC) 1 Year Good Practice ASB Team

Public Protection cases (MAPPA) TBC Legal ASB Team

ASB action plan risk assessments Permanent Legal / good practice ASB Team

8.16. Tenancy Support

Furniture scheme information TBC Legal Tenancy Support

Welfare Debt Advice case notes TBC Legal / good practice Tenancy Support

Sustainment Service agreements and risk assessments

Permanent Legal / good practice Tenancy Support

Confidential safeguarding information Permanent Legal Tenancy Support

8.17. Tenancy Services and Applications

Information Retention Period Justification Responsibility for Information Application information and forms (paper) 5 years Company Policy Tenancy Services

Application information and forms (Abritas) 7 years Tenancy Services

Tenancy information (Orchard system) Permanent Cannot remove from Orchard

Tenancy Services Tenant information (Orchard system) Permanent Cannot remove from

Orchard

Tenancy Services House file information (Document Management) Permanent Required whilst they Tenancy Services

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Information Retention Period Justification Responsibility for Information are still tenants

Customer profile information - current tenants (computer)

Permanent Required whilst they are still tenants

E&D Manager Customer profile information -Former tenants Permanent Still required to do

analysis of former tenants

E&D Manager

Customer profile forms (paper) Destroy when input to computer systems

No longer required. Customer Services Manager

Former tenant house file information (Document Management)

Permanent Still required to do analysis of former tenants

Tenancy Services

Estate Management information ( HUB) Permanent Tenancy Services

Welfare visit info (HUB) Permanent Tenancy Services

House cards Permanent Really useful at times Tenancy Services

8.18. Marketing and Communications

Mailing lists for Insight Permanent Marketing Officer

Photographs – featuring customers Permanent Marketing Officer

8.19. Equality and Diversity

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Information Retention Period Justification Responsibility for Information Spreadsheet of customer profile data relating to

individual service uptake reports e.g. BRG and Panel reports

Delete

E&D Officer

Reports on customer complaints related to E&D or Human Rights [as part of complaints paperwork)

Permanent Company Policy Performance & Quality Manager Notes related to customer complaints related to

E&D or Human Rights

Notes destroyed when complaint complete

Company Policy E&D Officer

Equality Impact Assessments (EqIA) Destroy when subject of EqIA is no longer required

Good Practice E&D Officer

8.20. Performance & Quality

Information Retention Period Justification Responsibility for Information Customer complaints – computer records Permanent Company Policy Performance &

Quality Manager Customer complaints – working papers Discard when case

resolved

Company Policy Performance & Quality Manager

VMS surveys Only keep latest

survey

Good Practice Performance & Quality Manager

KPI reports 5 years DCC policy Performance &

Quality Manager

Housemark reports 5 years Suggestion Performance &

Quality Manager

Statutory returns 7 years RMS guidelines Performance &

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8.21. Strategy & Policy

Company Policies 5 years for

previous versions

RMS Guidelines Strategy & Policy Manager

Company Strategies 5 years for

previous versions

RMS Guidelines Strategy & Policy Manager

8.22. Human Resources

Employee Records Min 6 years after

end of employment

RMS guidelines.

May need to keep past 6 years where there is likelihood of litigation.

HR Department

Job Application – successful applicants – as part of employee records

RMS guidelines HR Department Job Application – unsuccessful applicants 6 months RMS guidelines HR Department References for employees– as part of employee

records

NHF recommendation HR Department Staff profile information – current staff (computer) Permanent Required whilst they

are still tenants

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Information Retention Period Justification Responsibility for Information Staff profile information - Former staff Permanent Still required to do

analysis of former tenants

HR Department

Staff profile forms (paper) Destroy when

input to computer systems

No longer required. HR Department

Spreadsheet of staff profile data relating to individual service uptake reports e.g. BRG and Panel reports

Delete

E&D Officer

Staff training records – as part of employee records Min 6 years after end of employment

RMS guidelines HR Department Statutory training records (e.g. Gas engineer) – as

part of employee records

Permanent to prove historical work was done by qualified person.

Good Practice HR Department

CRB/DBS records– as part of employee records As long as necessary

Section 122(2) of the Police Act 1997.

HR Department Disciplinary information – oral warning– as part of

employee records - Only live for the duration of the warning.

RMS guidelines HR Department

Disciplinary information – written warning– as part of employee records - Only live for the duration of the warning.

Disciplinary information – final written warning– as part of employee records - Only live for the duration of the warning.

Grievance information – proven– as part of employee records

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Information Retention Period Justification Responsibility for Information Grievance information – unfounded– as part of

employee records

RMS guidelines HR Department Equal Opportunities claims– as part of employee

records

RMS guidelines HR Department Sickness records including Return to Work and

Welfare meetings– as part of employee records Min 6 years after end of employment

RMS guidelines HR Department Occupational Health information– as part of

employee records

RMS guidelines HR Department Maternity / paternity records– as part of employee

records

SMPR regulations HR Department Redundancy records– as part of employee records Min 6 years after

end of employment

IPD recommendation HR Department Annual leave records– as part of employee records Min 6 years after

end of employment

RMS guidelines HR Department Appraisal & One-to-One meeting – Managers notes Destroy when

complete

suggestion HR Department

Appraisal & One-to-One meeting – agreed copies– as part of employee records

6 years RMS guidelines HR Department

Trade Union agreements 10 years after

ceasing to be effective

IPD recommendation HR Department

Trade Union consultations 20 years RMS guidelines HR Department

Trade Union Meetings 10 years RMS guidelines HR Department

8.23. Meetings

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Board Meetings See Governance -

Panel Meetings See Governance -

Directorate Team meetings 4 years DCC policy Director

Team Meetings 4 years DCC policy Team Manager

External meetings organised by EDH (e.g. Housing Partnership, Resident )

6 years RMS guidelines EDH lead

External meetings not organised by EDH 3 Years RMS guidelines EDH attendee

Trade union meetings See HR section

8.24. Business Planning

EDH Business Plans 6 years after plan

completion

RMS guidelines Performance & Quality Manager

Annual Service Plans 6 years after plan

completion

RMS guidelines Departmental Head

Annual Reports 6 years RMS guidelines Performance &

Quality Manager

Emergency Plans Destroy when

updated

Good Practice Head of Neigh’d Services R&T Records of emergency plan invocation Permanent May be required for

litigation

Head of Neigh’d Services R&T

Business Continuity Plan Destroy when

updated

Good Practice Business Continuity Lead

Record of Business Continuity Plan invocation Permanent May be required for litigation

Business Continuity Lead

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Information Retention Period Justification Responsibility for Information Public consultation information (e.g. Stock Options) 5 years after

completion

DCC guidelines Admin Manager Project documentation including progress and

closedown reports

6 years DCC policy Project Lead

8.25. Complaints, Compliments and Surveys

Complaints Permanent Company Policy Performance Team

VMS Surveys Only keep latest Good Practice Performance Team

8.26. Information Security

Information Retention Period Justification Responsibility for Information Data Protection Act – subject access requests 3 years from date

received

DCC policy ICT Manager

Freedom of Information requests 6 years RMS guidelines ICT Manager

Records of Information security breaches Permanent May be required for future litigation.

ICT Manager Consent to providing personal data to another

person or organisation

Until no longer required

DPA Customer Services

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8.27. Legal Advice

Legal Advice Retain whilst

relevant

Good Practice Department that received advice

8.28. Customer Contact & Correspondence

Information Retention Period Justification Responsibility for Information Customer Contact Records – Keyfax Permanent Cannot be removed

from system

Customer Services Manager

Customer phone call recordings 1 year DCC policy Customer Services

Manager

CCTV surveillance 1 month unless

required for evidence.

Common practice Facilities Manager

General EDH correspondence 2 years DCC policy Sender of letter

EDH correspondence – with MP’s & councillors 6 years RMS guidelines Sender of letter Internal emails

(See guidance in Section 5)

Retain whilst required

RMS guidelines Staff responsible for own email Email correspondence with tenants

RMS guidelines Staff responsible for own email Email correspondence with partners / suppliers

RMS guidelines Staff responsible for own email Email correspondence with other parties

RMS guidelines Staff responsible for own email

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8.29. Customer Involvement

Resident Association files 5 years Good practice Involvement Team

Hard to engage group files Permanent Good practice Involvement Team

Service Review Panel records & members 5+ years Good practice Involvement Team

Resident Scrutiny records 5 years Good practice Involvement Team

Photos records from events Permanent Good practice Involvement Team

Patch meeting records Permanent Good practice Involvement Team

Active Learning for residents 3+ years Good practice Involvement Team

STAR scheme Permanent Good practice Involvement Team

Resident Group Incentive scheme Permanent Good practice Involvement Team

Impact assessments Permanent Good practice Involvement Team