Published 26th of August 2020

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 timeframe it has.

Shredall SDS Group storage services allow businesses to store their documents off-site until the end of the 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.

What is a document retention policy?

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.

What is a retention period?

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.

What are the benefits of a document retention policy?

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.

Retention periods for different documents types

Below are some common document types retention periods explained in detail.

How long to keep payroll data?

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.

How long to keep employee records after termination?

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.

What is the retention period for tax records?

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.

How long to keep business documents?

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.

Document Retention Periods

Here’s some further common recommended period of retention dates and the minimum 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

Tips for organising your records retention schedule

The thought of knowing where to start with all your document 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.