All CIMA staff and Council/Committee members. To explain the need for a document and data retention principles at CIMA

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1 Procedure IP8 Document and Data Retention Principles Eligibility All CIMA staff and Council/Committee members Principles status Procedure statement To inform employees and appropriate members of the principles for the document and data retention principles, both hard and electronic copies To explain the need for a document and data retention principles at CIMA Value alignment Guidelines IP8 DOCUMENT AND DATA RETENTION PRINCIPLES Introduction An inevitable part of business activity is the generation and circulation of documents and records, for a variety of purposes and reasons. However, the retention of files and papers for longer than necessary has legal and risk management implications and creates storage and cost issues in respect of both paper and computer-based records. It is good legal and risk management practice to destroy documents and files as soon as is reasonable, whether hard or electronic copies. In the absence of any formal principles most individuals would be inclined to keep everything forever. This not only avoids the need to review files, but also ensures the retention of anything that might possibly be required at a later date. Whilst this might appear to be the safest option, it may in fact be illegal in some circumstances. Under the Data Protection Act personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or purposes. Data protection law does not specifically prescribe how long data should be retained. In other words it is not reasonable to keep documents and data just in case. There must be a specific, identifiable need to keep documents and data. The responsibility is with the organisation to identify how long it needs to keep data and, by implication, the documents of which the data forms part. Furthermore, the act requires appropriate technical and organisational measures to be taken to prevent unauthorised or unlawful processing of personal data and accidental loss or destruction of, or damage to, personal data through, for example, a breach of security or inadequate training of staff. In extreme circumstances, if no paper records are ever destroyed, storage will eventually have an impact on the physical office space and operational efficiency. Ultimately, a business may have to choose between moving premises and implementing a retention and disposal Principles. Whilst electronic records occupy less physical space, unnecessary retention will result in similar problems regarding retrieval of information. Moreover, stored data may require conversion to new formats as a result of technological progress or may become corrupt through deterioration of the storage media. 1

2 Principles statement General documents and files should not be retained for any longer than seven years after the date of the most recent item filed. They should then be destroyed unless there are exceptional business reasons for keeping them longer and a record should be maintained of what has been destroyed (file name and date destroyed). Appendix 1 outlines appropriate exceptional retention periods for a range of specific documents and records maintained within CIMA* There is an obligation for all staff to review what is stored every twelve months and comply with the indicated retention periods in appendix 1. If there is no further need to retain the documents or data, they should be removed and destroyed. Student and member records are kept indefinitely, including exam and exemptions history Specific requirements exist regarding the retention and storage of credit/debit cardholder data. Please refer to the PCI Policy for details. These proposals should be extended to include Members of Council and Institute Committees in order to protect the security of information Any older than 3 years gets deleted automatically unless a work group are subject to an exception and differing time period (these are listed in the appendix).. In 2008, our system was upgraded and there now exists a centralised archiving system. *Please note the retention periods may change due to legislation changes or other changes and the appendix is a live document Principles owner Author Process Analyst/Corporate Manager Principles date 13 May 2008 Issue 7 Version Control Issue Applicable from/to 1 1 st March 2008 (first draft) 2 8 th May 2008 (following consultation with Heads of Departments) 3 13 th May 2008 (following approval at CPRB) 4 October 2010 submission to BPRB for approval 5 December 2010 BPRB approved 6 26 July 2011 HR retention periods updated 7 8 August 2012 Inclusion of PCI Policy requirements 2

3 Appendix 1 Exceptional retention periods for special documents Item Retention Period Guardian Council, Committees and AGMs Minutes of all Council and other CIMA committee meetings Written resolutions Minutes of general meetings Annual review and financial statements Register of Interests Register of documents sealed Agenda papers (for Council and Committee meetings) Proxy forms no poll Proxy forms / polling cards poll Area Coordinator Committee minutes and Regional Board minutes Insurance minimum for papers required to understand the minutes One month after meeting One year after meeting Manager, Members and Students Network Services Accident/claims correspondence 6 years after settlement Finance Manager Insurance schedules/policies Finance Manager Public/product/employers liability policies Finance Manager Claims correspondence 3 years after settlement Finance Manager Other policies Human Assessment notes, equal opportunities forms and interview notes for unsuccessful candidates Date of confinement (MATB1), maternity details (ML1), career development information, date of confinement paternity (SC3) General practitioner certificates, appraisals, P11D correspondence, performance plans Until claims under policies are barred 12 months )3 years ) )1 year ) Finance Manager 3 years Tax enquiries, tax general 4 years 3

4 correspondence, tax P45, P46, P6, P9 Healthcare correspondence, disciplinary correspondence, disciplinary report, grievance correspondence Sickness self certification form, leaver/resignation notice, pay increase letter, promotion letter, redundancy letter Healthcare dependants cover form, healthcare dd mandate, healthcare opt out forms, pensions correspondence, transferred pension rights, copy of death certificate, declaration of secrecy, deedpoll, overseas services details, health and safety incident report, medical report, PHI correspondence, car correspondence, change of hours notice, contract of employment, notice of change in marital status, application form, CV, references, psychometric test* Facilities Agreements with architects / builders keep Leases Accident books 5 years ) ) 6 years after employment ) ends 6 years *Publisher s recommended shelf life Retain for as long as we occupy the premises and for 10 years after we have left 12 years after termination and any terminal queries have been settled. (Bear in mind that when leases are assigned, liability can be retained by the assignee until the original lease term has expired. After two assignments, the original leaseholder loses liability.) 3 years after date of last entry (unless involving chemical agents under the Control of Substances Hazardous to Health Regulations 2002 (COSHH), in which case a minimum of 10 years and possibly up to 40 years) Head of Logistics Head of Logistics Head of Logistics 4

5 Finance Accounting records Budgets and periodic internal financial reports VAT records Tax records 10 years 6 years 6 years Financial Promotions/Advertisements Employer/Student Recruitment Material Product Marketing Material Brand and Identity Guidelines International Customer Marketing Manager Product Marketing Manager Head of Brand and Marketing Services Other areas Legal documents Contracts and agreements Complaints Financial promotions/advertisements Retain all that are still in force 10 years after expiry Head of Brand and Marketing Services Intellectual property rights, certificates of registration, agreements and licences Published intellectual material - Applied Research Unit Published Intellectual Material - Knowledge Unit after cessation of registration. Head of Research & Development Head of Profile & Communications CIMA s syllabi all versions Director Examinations Professional Committee Rules (Establishing policies & procedures) Committee Notes of Cases/Decisions Permanent 5

6 Committee/case hearing transcripts Committee reference & guidance manuals Case Files (hard copy only) Legal advice documents Committee case lists/bundles/case papers Hearing/Meeting Box Committee training materials Active Case Log Closed Case Log Watching Brief Log Potential Complaints Log Key CIMA publications relevant to conduct work ( all editions): Charter, Byelaws & Regulations Ethical Guidelines Code of Ethics CIMA Enterprises Limited Registers of: - members - mortgages and charges - directors and secretaries - directors interest in shares or debentures Certificate of incorporation Permanent- archive once administrative use has concluded (minimum) Superceded + 5 years (one complete copy) Other copies to be destroyed via secure means minimum (one complete copy archived) Superseded + 3 years One copy to be retained. Other copies to be destroyed via secure means Transitory document; names retained for duration of process. Permanent Names retained for 3 years from point of initial notification 1 year from receipt of initial correspondence Permanent Life of the company for all 6

7 Memorandum & articles of association resolutions filed at companies house Board minutes Written resolutions Minutes of general meetings Statutory written resolutions Record of decision of sole member Report & Accounts signed Agenda papers Notice of general meetings Circulars to shareholders Certificate of posting of notices Annual returns Finance records (private company) VAT records Tax records Local laws* Finance records in China Finance records in Australia Finance records in Hong Kong Finance records in Ireland Finance records in Malaysia Finance records in Sri Lanka Finance records in South Africa Finance records in Singapore Finance records in India minimum Life of the company for papers required to understand the minutes 12 years Life of the company for papers required to understand the minutes 2 years 3 years 6 years 15 years 5 years 5 years 10 years 8 years Divisional Director, China Australia National Manager Hong Kong Divisional Director Ireland Divisional Director Malaysia, Regional Director of South East Asia Sri Lanka Regional Director Southern Africa Regional Director Singapore Branch Representative India Chief Representative *if the local law is stricter than the UK law, the local law should be adhered to. If not, the UK law should be followed. 7