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Data Retention Policy

1. Introduction

This Policy sets out the obligations of High Octane Action Sport, of 39-43 Monument Hill, Belgrave House, Weybridge, KT13 8RN ("the Company") regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation ("GDPR").
The GDPR defines "personal data" as any information relating to an identified or identifiable natural person (a "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
The GDPR also addresses "special category" personal data (also known as "sensitive" personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.
Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).
In addition, the GDPR includes the right to erasure or "the right to be forgotten". Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

  1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
  2. When the data subject withdraws their consent;
  3. When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
  4. When the personal data is processed unlawfully (i.e. in breach of the GDPR);
  5. When the personal data has to be erased to comply with a legal obligation; or
  6. Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company, the period(s) for which that personal data is to be retained, and when and how it is to be deleted or otherwise disposed of.
For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy.

2.1 The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR.

2.2 In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.

3.1 This Policy applies to all personal data held by the Company and by third-party data processors processing personal data on the Company’s behalf.

3.2 Personal data, as held by the Company is stored in the following ways and in the following locations:

  1. The Company’s servers located in the Company’s premises at Unit 17, IO Centre, 57a Croydon Road, Beddington, Croydon, CR0 4WQ;
  2. Third-party servers, operated on our behalf;
  3. The Company’s computers permanently located in the Company’s premises at Unit 17, IO Centre, 57a Croydon Road, Beddington, Croydon, CR0 4WQ;
  4. Laptop computers and other mobile devices provided by the Company to its employees;
  5. Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with the Company’s Bring Your Own Device ("BYOD") Policy;
  6. Physical records stored in the Company’s premises at Unit 17, IO Centre, 57a Croydon Road, Beddington, Croydon, CR0 4WQ.

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy.

4.1 Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

4.2 Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, and further rights relating to automated decision-making and profiling.

Upon the expiry of the data retention periods set out below in Part 6 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

5.1 Personal data stored electronically (including any and all backups thereof) shall be deleted;

5.2 Personal data stored in hardcopy form shall be shredded.

6.1 As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

6.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

6.3 When establishing and/or reviewing retention periods, the following shall be taken into account:

  1. The objectives and requirements of the Company;
  2. The type of personal data in question;
  3. The purpose(s) for which the data in question is collected, held, and processed;
  4. The Company’s legal basis for collecting, holding, and processing that data;
  5. The category or categories of data subject to whom the data relates.

6.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

6.5 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).


Type of Data Purpose of Data Retention Period
Company records Certificate of incorporation, share certificates, etc Permanently
Agreements All contracts with: customers, suppliers, agents 10 years after expiry
Agreements Licensing agreements 10 years after expiry
Agreements Rental & hire purchase 10 years after expiry
Agreements Indemnities & guarantees 10 years after expiry
Agreements Any other agreement or contract 10 years after expiry
Property Records Deeds of title Until sold or transferred
Property Records Leases 12yrs after termination & any terminal queries (e.g. Dilapidations) have been settled 6yrs after completion
Property Records Agreements with architects, builders 6yrs after completion
Property Records Reports and opinions 10yrs after correspondence
Pension records All trust deeds & rules Permanently or, if merged with another fund, 12yrs after merging
Pension records Accounts & supporting documents 6yrs from date accounts signed
Pension records Inland Revenue approvals Permanently or, if merged with another fund, 12yrs after merging
Pension records Records of pensioners 12yrs after benefit ceases
Pension records Records of ex-pensioners Permanently or, if merged with another fund, 12yrs after merging
Pension records Group health policies 12yrs after cessation of benefit
Pension records Group personal accident policies 6yrs after yr.in which event occurred
Banking records Cheques, bills of exchange & other negotiable instruments 6 yrs
Banking records Paying-in counterfoils 6 yrs
Banking records Bank statements & reconciliations 6 yrs
Banking records Foreign exchange rates 15 yrs
Banking records Instructions to banks 6yrs after ceasing to be effective
Insurance records Public liability polices Permanently
Insurance records Product liability Permanently
Insurance records Employers’ liability policies Permanently
Insurance records Insurance schedules 7 yrs
Insurance records Group Health policies 12 yrs after cessation of benefit
Insurance records Group personal accident policies 12yrs after cessation of benefit
Insurance records Personal claims 7yrs from date of claim
Insurance records Other policies Until claims under policy are barred
Accounting and tax records To comply with the Companies Act 1985 (this includes all subsidiary records to support annual accounts) 3yrs
Accounting and tax records Budgets & Periodic internal financial reports e.g. to board (Master) 2yrs
Accounting and tax records Taxations returns and records 10yrs
Accounting and tax records VAT Records 6yrs
Accounting and tax records Income Tax & NI returns, including correspondence with Tax Office 3yrs after end of FY to which records relate
Accounting and tax records Income & expenditure 7yrs
Employee records Personal & training records (including disciplinary & grievance hearing notes) 6yrs after employment ceases; could be longer with agreement of individual
Employee records Appointment & staff appraisal records 5yrs
Employee records Redundancy records 12yrs from date of redundancy
Employee records Senior executive records Permanently
Employee records Contact details kept on personal files (e.g. card index, MS Outlook) Until it is apparent the person is no longer at the named location
Employee records Personal information of any sort on a web page or site No longer than the period specifically agreed with the individual
Employee records Payrolls & wage records (including overtime, bonuses and expenses) 6yrs
Employee records Statutory Sick pay records & calculations 3yrs after end of FY to which records relate
Employee records Income Tax records (e.g. P45, P60, P58, P48) 6yrs
Employee records Annual return of taxable pay & tax paid 6yrs
Contractual agreements Contracts 12yrs after expiry
Health and safety records Record of consultations with safety representatives & committees Permanently
Health and safety records Training records relating to safety at work Permanently
Health and safety records Occupational Health records During employment
Health and safety records Under COSHH Regulations 40yrs
Health and safety records Classifications data under Chemicals (Hazard Information & Packaging for Supply) Regulations 1994 3yrs
Transport records Drivers log books 5 years after completion
Transport records Vehicle mileage records 2 years after vehicle disposed of unless liability claims
Transport records Vehicle maintenance records 2 years after vehicle disposed of unless liability claims
Transport records MOT records 2 years after vehicle disposed of unless liability claims
Transport records Registration records 2 years after vehicle disposed of unless liability claims

7.1 The data protection lead shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.

7.2 The data protection lead shall be directly responsible for ensuring compliance with the above data retention periods throughout the Company.

7.3Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the data protection lead.

This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.


V1.0

23.05.2018