Our data retention and disposal policy.

1. Purpose

1.1 The purpose of this policy is to detail the procedures for the retention and disposal of information to ensure that we carry this out consistently and that we fully document any actions taken. Unless otherwise specified the retention and disposal policy refers to both hard and soft copy documents.

2. How long we should keep our paper records

2.1 Records should be kept for as long as they are needed to meet the operational needs of takepayments, together with legal and regulatory requirements.

2.2 We should regularly review the retention periods for different categories of information to determine whether they should be destroyed or retained for a further period. However, detailed in the record retention schedule below are the retention periods we should apply to the relevant information, unless otherwise advised by takepayments’ Data Protection Officer or members of the Senior Management team.

3. Destruction of records

3.1 Records can be destroyed in the following ways:

Non-sensitive information – can be placed in a normal rubbish bin
Confidential information – cross cut shredded and pulped or burnt.
Electronic equipment containing information - destroyed using killdisc and for individual folders, they will be permanently deleted from the system.

3.2 Destruction of electronic records should render them non-recoverable even using forensic data recovery techniques.

4. Records of destructions

4.1 We do not need to document the disposal of records which have been listed on the records retention schedule. Documents disposed of other than in accordance with that schedule (either by being disposed of earlier or kept for longer than listed) will need to be recorded for audit purposes.

5. Review

5.1 Responsibility for reviewing this policy (including reviewing the retention periods for different categories of information) rests with the Data Protection Officer. The policy should be reviewed annually.

Disposal Schedule - Customer/Merchant Operational Information

Business Function	Description	Retention Period	Comments
Pre-Sales
	Customer details: Name	7 years
	Customer details: Date of Birth	7 years
	Customer details: Address	7 years
	Customer details: Telephone Number (Landline)	7 years
	Customer details: Telephone Number (Mobile)	7 years
	Customer details: Application rejected by Acquirer (Credit Referencing) – Card Acceptance Merchants only	7 years	This information will only be held where the acquirer has rejected an application from a merchant resulting from the credit reference report
	Customer details: Experian Credit Reference – Successful applications (Convenience)	Contract term + 7 years
	Customer details: Experian Credit Reference – Unsuccessful applications (Convenience)	7 years
	Customer details: Application rejected by takepayments (Credit Referencing) – Convenience (Bill Payment) Only or Convenience (Bill Payment) plus Card Acceptance service merchants only	7 years	This information will only be held where takepayments has rejected an application from a merchant resulting from the credit reference report
Sales Enablement
Boarding	Customer details: Name	Contract term + 7 years
Boarding	Customer details: Date of Birth	Contract term + 7 years
Boarding	Customer details: Address	Contract term + 7 years
Boarding	Customer details: Telephone Number (Landline)	Contract term + 7 years
Boarding	Customer details: Telephone Number (Mobile)	Contract term + 7 years
Boarding	Customer details: Email address	Contract term + 7 years
Boarding	Customer details: Identity Verification Document 1	Contract term + 7 years	Any document from the following list: 1) Unexpired passport 2) Driving licence 3) National Identity Card
Boarding	Customer details: Identity Verification Document 2	Contract term + 7 years	Any document from the following list: 1) Unexpired passport 2) Driving licence 3) National Identity Card
Boarding	Customer details: Address Verification Document	Contract term + 7 years	Any document from the following list: 1) Notification for Tax Credit 2) Notification for entitlement to pension from DWP 3) Notification to a government grant 4) Utility Bill 5) HMRC Tax Statement 6) Mortgage statement 7) Council Tax Bill 8) Business Insurance Certificate 9) VOA Business rates document 10) Credit Card Statement 11) Marriage certificate 12) Deed poll certificates (Change of name)
Boarding	Customer details: Bank details	Contract term + 7 years
Boarding	Customer details: Bank confirmation	Contract term + 7 years	Bank statement, voided cheque or paying in slip
Boarding	Business details: Business Plan	Contract term + 7 years
Boarding	Business details: Financial record from Companies House	Contract term + 7 years
Boarding	Business details: Audited Company Accounts	Contract term + 7 years
Boarding	Business details: Solicitors or accounts letters showing personal details of owners/shareholders	Contract term + 7 years
Boarding	Business details: Owners / shareholders list	Contract term + 7 years
Boarding	Business details: Official Partnership Agreement	Contract term + 7 years
Boarding	Business details: Tenancy Agreement for business premises	Contract term + 7 years
Boarding	Business details: Customer bank details for taking payments	Contract term + 7 years
Boarding	Business details: Acquirer Contract	Contract term + 7 years
Boarding	Business details: Acquirer statement (for Merchants who are changing merchant acquirers)	Contract term + 7 years

Disposal Schedule - Governance and Operations: Finance Records

Business Function	Description	Retention Period	Comments
Finance	Finance Documents	7 years
Financial management – bank, petty cash and creditors records, misc.	Paid/presented cheques and records of all cheques drawn for payment	6 years
	All other cheque records – cheque books received, butts, cancelled etc	2 years
	Bank statements and reconciliations	6 years
	Electronic banking – transactions, payment files, deposits, withdrawals and audit trail	As per paper records
	All petty cash records	6 years
	Creditors history records, lists and reports	6 years
	Statements of accounts	2 years
	Fraud and theft	6 years (minor matters) / 10 years (non-minor matters)
Financial management – ledger records	General ledger produced for purposes of preparing certified financial statements	6 years
	Creditor ledger	6 years
	Other ledgers and related audit trails	6 years
	Journals – prime record for raising charge	6 years
	Journals -adjustments	6 years
	Reconciliations Year End	6 years
	Assets and depreciation registers	6 years on disposal of last asset
	Annual and quarterly financial statements	6 years
	Periodic financial statements	Destroy when cumulated into quarterly or annual reports
Financial management – PO (Purchase Order) records	PO records	6 years
Financial management - Income	Debtors records and invoices	6 years
	Credit notes and refunds	6 years
	Records relating to unrecoverable revenue (bad debts, overpayments)	6 years (minor matters) / 10 years (non-minor matters)
	Revenue records	6 years
Merchant Information	Contact data Bank details Legal proceeding docs Contract info	Contract length plus 6 years
	Bank details	Contract length plus 6 years
	Legal proceeding documents	Contract length plus 6 years
	Contract information	Contract length plus 6 years
Financial management – internal and external audit	External audit investigations	6 years after completion
	Audit report that includes long-term contracts	6 years
	Report papers used in course of fraud investigation	6 years
	Other audit reports	3 years
	Internal audit guides, manuals, and guides relating to departmental procedures and local auditing standards	Indefinitely, replaced with updates as and when necessary

Disposal schedule - Governance and Operations: Human Resources and Payroll Records

Business Function	Description	Retention Period	Comments
Human Resources	Human Resources Documents
Employee Files	Paper and hardcopy employee files	6 years after the employee leaves the organisation.	The Limitations Act 1980 (to reflect that legal proceedings must start within 6 years)
Income Tax Records and Wages	Income tax and NI returns, income tax records and correspondence with the Inland Revenue	Not less than 3 years after the end of the financial year to which they relate	The Income Tax (Employments) Regulations 1993 (SI 1993/744) as amended, for example by The Income Tax (Employments) (Amendment No. 6) Regulations 1996 (SI 1996/2631)
	Wage/salary records (also overtime, bonuses, expenses)	6 years	Taxes Management Act 1970
	National minimum wage records	3 years after the end of the pay reference period following the one that the records cover	National Minimum Wage Act 1998
Pension and Retirement	Retirement Benefits Schemes – records of notifiable events, for example, relating to incapacity	6 years from the end of the scheme year in which the event took place	The Retirement Benefits Schemes (Information Powers) Regulations 1995 (SI 1995/3103)
Payroll and HR Policies	Staff handbook, clear desk policies etc	Perpetual	Retain most recent / updated version
Sickness Records	Statutory Maternity Pay records, calculations, certificates (Mat B1s) or other medical evidence	3 years after the end of the tax year in which the maternity period ends	The Statutory Maternity Pay (General) Regulations 1986 (SI 1986/1960) as amended
	Statutory Sick Pay records, calculations, certificates, self- certificates	3 years after the end of the tax year to which they relate	The Statutory Sick Pay (General) Regulations 1982 (SI 1982/894) as amended
Employee Files – General Exceptions	Records relating to working time	2 years from date on which they were made	The Working Time Regulations 1998 (SI 1998/1833)
	Accident books, accident records/reports	3 years after the date of the last entry	The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) (SI 1995/3163) as amended.
Financial management – Payroll/Pension	Employee current and pay histories (equal Pay register)	7 years after the employee leaves the organisation
	Internal Payroll Spreadsheet	7 years after the employee leaves the organisation
	Sage reports	7 years after the employee leaves the organisation
	Internal Pension Report Pension for Aegon	7 years after the employee leaves the organisation
	Child care vouchers, CSA payments	7 years after the employee leaves the organisation
	HMRC tax deduction data (P45 & P60 data)	7 years after the employee leaves the organisation
	P11d’s Car and medical benefits	7 years after the employee leaves the organisation
	Office of national statistics data	7 years after the employee leaves the organisation
	Company Loan data	7 years after the employee leaves the organisation