Retention Policy
1. Introduction
- TALENT INTERNATIONAL UK LTD (”We, our, us”) are committed to protecting and respecting your privacy.
- These guidelines support our Privacy Notices and Data Protection
- The guidelines are intended to ensure that we process personal data in accordance with the personal data protection principles, that:
- Personal data must be collected only for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes.
- Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is When personal data is no longer needed for specified purposes, it is deleted or anonymised as provided by these guidelines.
- Personal data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when
- Personal data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.
- Personal data must be secured by appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
- The Data Protection Compliance Team is responsible for overseeing these
2. Records
- We hold the information set out in our Privacy Notices and can be contacted with any enquiries relating to this personal
- We accept that we need to ensure that your personal details are up to date and
- These provisions are intended to complement the data subject rights referred to in our Privacy Notices.
3. General Principles of Retention and Erasure
- Our approach to retaining records is to ensure that it complies with the data protection principles referred to in these guidelines and, in particular, to ensure that:
- Our records are regularly reviewed to ensure that they remain adequate, relevant and limited to what is necessary to facilitate our relationship with
- Our records are kept secure and are protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Where appropriate we use anonymization to prevent identification of individuals.
- When records are destroyed, whether held as paper records or in electronic format, we will ensure that they are safely and permanently
4. Retention and erasure Periods
We have regard to recommended retention periods for particular records set out in legislation, referred to in the table below. However, we also have regard to legal risk, best practice, insurance recommendations and have therefore set our retention periods as below:
| Type of employment record | Retention period |
| Given our industry, recruitment records will be retained as follows, for all types of recruitment candidates (whether permanent, temporary, contractor):
These may include: Completed online application forms or CVs. Equal opportunities monitoring forms. Assessment exercises or tests. Notes from interviews and short-listing exercises. Pre-employment verification of details provided by the successful candidate. For example, checking qualifications and taking up references. (These may be transferred to a successful candidate’s employment file.) Criminal records checks. (These may be transferred to a successful candidate’s employment file if internal they are relevant to the ongoing relationship.) |
Six months after notifying candidates of the outcome of the recruitment exercise is our minimum legal base. However, given our business and placements, we have determined that for prospective candidates with no contact, 2 years. For successful candidates placed we will hold limited information for 7 years. |
| Immigration checks | |
| Immigration checks, copies of passports, right to work. | Three years after the termination of employment. While employment continues and for seven years after employment ends. |
| Type of employment record | Retention period |
| Contracts | |
| These may include:
Written particulars of employment. Contracts of employment or other contracts. Documented changes to terms and conditions. |
While employment continues and for seven years after the contract ends. |
| Collective agreements | |
| Collective workforce agreements and past agreements that could affect present employees. | Any copy of a relevant collective agreement retained on an employee’s record will remain while employment continues and for seven years after employment ends. |
| Payroll and wage records | |
| Payroll and wage records Details on overtime.
Bonuses. Expenses. Benefits in kind. |
These must be kept for at least three years after the end of the tax year to which they relate. However, given their potential relevance to pay disputes they will be retained for seven years after employment ends. |
| Current bank details | Bank details will be deleted as soon after the end of employment as possible once final payments have been made |
| PAYE records | These must be kept for at least three years after the end of the tax year to which they relate. However, given their potential
relevance to pay disputes they will be |
| Type of employment record | Retention period |
| retained for seven years after employment ends. | |
| Payroll and wage records for companies | These must be kept for six years from the financial year-end in which payments were made. However, given their potential relevance to pay disputes they will be retained for seven years after employment ends. |
| Records in relation to hours worked and payments made to workers | These must be kept for three years beginning with the day on which the pay reference period immediately following that to which they relate ends. However, given their potential relevance to pay disputes they will be retained for seven years after the working relationship ends. |
| Travel and subsistence. | While employment continues and for seven years after employment ends. |
| Record of advances for season tickets and loans to employees | While employment continues and for seven years after employment ends. |
| Personnel records | |
| These include: Qualifications/references.
Consents for the processing of special categories of personal data. Annual leave records. Annual assessment reports. Disciplinary procedures. Grievance procedures. Death benefit nomination and revocation |
While employment continues and for seven years after employment ends. |
| Type of employment record | Retention period |
| forms.
Resignation, termination and retirement. |
|
| Records in connection with working time | |
| Working time opt-out | Three years from the date on which they were entered into. However, given potential relevance, while employment continues and for seven years after employment ends. |
| Records to show compliance, including: Time sheets for opted-out workers.
Health assessment records for night workers. |
Three years after the relevant period. However, given potential relevance, while employment continues and for seven years after employment ends. |
| Maternity records | |
| These include:
Maternity payments. Dates of maternity leave. Period without maternity payment. Maternity certificates showing the expected week of confinement. |
Four years after the end of the tax year in which the maternity pay period ends.
However, given potential relevance, while employment continues and for seven years after employment ends. |
| Accident records | |
| These are created regarding any reportable accident, death or injury in connection with work. | For at least four years from the date the report was made. However, given potential relevance, while employment continues and for seven years after employment ends. |
| Type of employment record | Retention period |
5. Internal Document Retention Periods
| Type of Document | Recommended Period of Retention |
| Annual report and accounts (signed copy) | Permanently* |
| Agreements with architects, builders, etc | 6 years after contract completion |
| Accounting records required by the Companies Act | 6 years |
| Accident books and RIDDOR notifications | Permanently* |
| Actuarial valuation records | Permanently |
| Bank statements and reconciliations | 7 years (i.e. 6 years + 1 year) |
| Board minutes | Permanently |
| Carbon Reduction Commitment (“CRC”) records of power usage | Permanently* (for government audit) |
| Certificates of incorporation/company name | Permanently* |
| Certificate to commence business (public company only) | Permanently* |
| Circulars to shareholders including notices of meetings (signed copies) | Permanently |
| Cancelled share or stock certificates | 1 year |
| Cheques, bills of exchange etc | 7 years (i.e. 6 years + 1 year) |
| Contract or Memorandum to purchase a company’s own shares | 10 years |
| Contracts with customers, suppliers or | 6 years after expiry |
| Contracts under seal | 12 years |
| Copyright material | Permanently |
| Court orders (including wage stoppages) | Permanently* |
| Claims correspondence (insurance/legal) | 3 years after settlement or a reasonable period of time if the matter does not settle. |
| Certificates and other documents of title | Permanently, or until investment disposed |
| Deeds of Covenant | 12 years |
| Dividend and interest bank mandate forms | Original to be kept until account closed + 1 year |
| Type of Document | Recommended Period of Retention |
| Deeds of title | Permanently |
| Disciplinary proceedings relating to Health & Safety breaches | Permanently ** |
| Expense accounts | 7 years (i.e. 6 years + 1 year) |
| Employers’ liability policies | Permanently; legal requirement is 40 years* minimum |
| Forms of application for shares, | Permanently |
| Forms of acceptance and transfers of | Permanently |
| Group health policies | 12 years after final cessation of benefit |
| Group personal accident policies | 12 years after cessation of benefit |
| Health & Safety risk assessments, issue of PPE, training records, committee minutes, policy documents | Permanently*, ** (old and new) |
| Internal financial reports and records | 7 years (i.e. 6 years + 1 year) (including ledgers) |
| Investment records | Permanently (specifically for capital gains |
| Insurance schedules and sundry insurance policies | 12 years after lapse |
| Indemnities and guarantees | 6 years after expiry |
| Intellectual property and licence | 12 years after expiry |
| Job applications and interview records | 6 months* after notifying unsuccessful candidates |
| Letters of indemnity for lost share certificates | Permanently |
| Leases | 12 years after lease has terminated (and dilapidation and burdens settled) |
| Minutes of general and class meetings | Permanently |
| Memorandum and Articles of Association | Permanently |
| Powers of attorney | Permanently for shareholder matters |
| Patent and trade mark records | Permanently |
| Pension administration records | Permanently |
| Pension fund annual accounts and Inland Revenue approvals | Permanently |
| Pension scheme investment policies | 12 years after cessation |
| Public and product liability insurance | Permanently |
| Type of Document | Recommended Period of Retention |
| Register of Directors and Secretaries | Permanently* |
| Register of Directors’ Interests | Permanently* |
| Register of Charges | Permanently* |
| Register of Members | Permanently* |
| Register of debentures or loan stock | 7 years after redemption of stock |
| Rental and hire purchase agreements | 6 years after expiry |
| Statements and instructions to banks | 6 years |
| Stock transfer forms | 12 years after date of transfer |
| Salary and wages records* | 7 years (i.e. 6 years + 1 year); longer as necessary where employer’s liability claims possible |
| Trust deeds and rules (pension schemes) | Permanently |
| Taxation records and returns (corporation tax and income tax) | Permanently |
| Trade Mark Certificates of Registration | 6 years after cessation of registration |
| Trust Deeds and rules (pension schemes) | Permanently* |
| Trustees’ minute book | Permanently |
| VAT accounting records | Permanently |
| Vehicle registration records, MOT
certificates and vehicle maintenance |
2 years after disposal of vehicle |
6. For Further Information
- For further information do get in touch with us as follows:
- You can write to us at the following address: Compliance Operations Team, Talent International UK Limited, Alpha Tower, 21st, Suffolk Street Queensway, Birmingham 138 Edmund Street, Birmingham, B1 2TT; or
- Alternatively, you can send an email to: complianceuk@talentinternational.com