We are aware of current scams impersonating recruitment agencies including ourselves targeting jobseekers over whatsapp and asking them to supply personal details.
Please be aware that The Recruitment Group will never ask you for your personal information via Whatsapp and anyone claiming to be from The Recruitment Group doing so is part of a scam. We also never advertise jobs through Whatsapp.
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Retention Policy
Introduction
This policy sets out how Records / Documents will be stored, managed, and protected. It will also set out how long employment, recruitment-related information will normally be held by us and when that information will be confidentially destroyed.
It assesses the risks to Records management and how the risks are managed. This policy sets out The Recruitment Groups plans for the next 6 years regarding Records Management.
Responsibility
Compliance is responsible for implementing and monitoring this policy. Branch Managers are responsible for day-to-day Records management for their office or departments as directed by Compliance.
Compliance will undertake an annual review of this policy to verify that it is in effective operation.
Compliance will deliver training on this policy for all new internal employees as part of the induction process.
All current and existing staff members will be made aware of this policy and how to effectively implement the policy and ensure compliance with Records Management and Retention.
Our process and Risk Management
Information (hard copies and electronic) will be retained for the period specified in our Records Retention Schedule.
Hard and electronic Records will be stored securely in line with ICO recommendations and GDPR guidelines.
All electronic records including emails, files are stored securely on company laptops and our servers. This data is protected by multi factor authentication, randomly created passwords (which are a minimum of 8 characters), anti-malware software, security firewalls on our servers, computers, and laptops. Our data security is managed by an outsourced IT company, and they complete regular checks and security updates where necessary. Our security complies with the Cyber Essentials scheme, and we have a certificate of assurance to demonstrate the strength of our data security.
Any records that are stored as physical/hard copies are kept securely away from members of the public and stored securely.
When a candidate no longer requires our work finding services, all hard copies of their contact data are stored securely for the period of retention. The records are stored for the required time as mentioned in the Retention Policy below.
To be able to keep hard copies of records secure after working hours, all our offices are locked and have alarms fitted.
This Policy assess the risks associated with Records Management and how The Recruitment Group aim to minimise and control these risks.
The Recruitment Group Acknowledges that there are risks associated with storing data electronically and physically. There is a risk that both hard copies and electronic copies can be lost during an emergency or crisis. If this was to happen, we would follow the necessary steps set out in the company’s Business Continuity Plan. All electronic data is Backed-up to a remote server in the event of a crisis. If data is lost from the current CRM or server, it can therefore be recovered.
There is no back up for the paper/hard copies of records that are kept in branches. If this data is lost in an emergency there would be no way to recover the information.
There is a greater risk of keeping hard copies of records compared to storing them electronically. The Recruitment group is committed to managing this risk by removing all hard copies/physical records from our offices and to only store them electronically on the CRM and server. All branches are asked to place documents into the confidential shredding bins at branch.
All information must be reviewed before destruction to determine whether there are special factors that mean destruction should be delayed, such as potential litigation, complaints, or grievances.
Hard copy and electronically held documents and information must be deleted at the end of the retention period unless there is a requirement to delay deletion.
Hard copy documents and information must be disposed of by placing into confidential shredding bins.
Records Retention Schedule
This Record Retention Schedule sets out the time periods that different types of records must be retained for business and legal purposes.
The retention periods are based on business needs and legal requirements and should be read in accordance with The Recruitment Group’s data protection policy. If you maintain any types of records that are not listed in this schedule and it is not clear what retention period should apply, please contact compliance for guidance.
Any deviance from the retention periods in this schedule must be approved in advance by the Group Managing Director of the business.
The first section of this policy will address employment records, the second section will address work-seeker records.
Internal employee/applicants for internal roles
Record | Retention Period | Storage Format | Lawful basis and reference |
---|---|---|---|
Rejected job applicant records, including: Contact details. CV/Applications References Test results Interview notes Right to work checks Proof of ID / Address |
12 months after applicant is notified of rejection. The application forms should give applicants the opportunity to object to their details being retained | Paper or electronic | Legitimate business interest To ensure that you do not accept multiple applications from the same rejected candidate. To consider alternative roles for the candidate To demonstrate fair and nondiscriminatory recruitment process Kept in line with the Equality Act 2010 (s.123) |
Application records of successful candidates, including: Contact details. CV/Applications References Test results Interview notes Right to work checks Proof of ID / Address |
Up to the end of 6 years after employment ceases | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract Kept in line with the Limitation Act 1980 (s.5) To demonstrate compliance with a fair and nondiscriminatory recruitment process |
Employment contracts including: Training records Written particulars of employment (CFS, KID etc) Changes to terms and conditions |
Up to the end of 6 years after employment ceases if document executed as a deed- this should be 13 years after employment ceases- s.8 Limitation Act 1980] |
Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract Kept in line with the Limitation Act 1980 (s.5) Confirmation of rights and obligations owed and due by employee- employer |
Employee performance and conduct records: Probationary reviews Review and appraisal notes Promotions/demotions 1-2-1 documents |
Up to 7 years after employment ceases | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract Kept in line with the Limitation Act 1980 (s.5) Confirmation of rights and obligations owed and due by employee- employer |
Other employment records Redundancy records Annual leave records Parental leave records Sickness records Return to work meetings |
Up to the end of six years after employment ceases | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract Kept in line with the Limitation Act 1980 (s.5) Confirmation of rights and obligations owed and due by employee- employer |
Directors’ service contracts and any variations | Up to the end of six years after employment ceases if document executed as a deed- this should be 13 years after employment ceases- s.8 Limitation Act 1980] |
Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract Confirmation of rights and obligations owed and due by employee- employer. Legal obligation Retained for one year from the date of termination or expiry. Kept in line with Companies Act 2006 (s.228) |
Copies of identification documents/right to work | Kept for two years from date of termination of employment | Paper or electronic | Legal obligation Kept in line with the Immigration (Restrictions on Employment) Order (Art 6(1)(b)) |
Records relating to/demonstrating compliance with Working Time Regulations 1998: Registration of work and rest periods Working time opt-out forms |
Kept for two years from the date on which the record was made | Paper or electronic | Legal obligation Kept in line with the Working Time Regulations 1998 (Regulation 9) |
Criminal records information Information forms DBS check forms DBS certificates |
6 months from end of last employment date | Paper or electronic | Legitimate business interest To demonstrate that safeguarding processes were followed. |
Gender pay gap reporting information | Kept available for a period of at least 3 years beginning with the date of publication | Paper or electronic | Legal obligation Kept in line with Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (Regulation 15) |
Work-seeker records
Record | Retention Period | Storage Format | Lawful basis and reference |
---|---|---|---|
Work-seeker records ·Name/address and if under 22, date of birth Any terms between recruitment business and the work-seeker and any variations Details of the work-seeker’s training, experience, qualifications, and any authorisation to undertake work. Names of hirers to whom the work-seeker is introduced or supplied. Details of any resulting engagement and date from which it takes effect. Details of any enquiries made under Regulations 19, 20 and 22 about the workseeker and the position concerned |
Kept for 1 year after you last provided your work-finding service. The maximum this data should be kept for is up to the end of six years from the date of your workfinding services in line with the Limitation Act 1980 but only if a real possibility of legal action being taken by a worker] |
Paper or electronic | Legal obligation Kept in line with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Reg 29) Legitimate business interest To protect the business against any legal claims for breach of contract Kept in line with the Limitation Act 1980 (s.5) To keep records to demonstrate that safeguarding processes are adhered to and followed. To contact the candidate for any further work-finding services To protect your business against any legal claims |
Records relating to/demonstrating compliance with Working Time Regulations 1998: Registration of work and rest periods Working time opt-out forms |
Kept for two years from the date on which the record was made | Paper or electronic | Legal obligation Kept in line with the Working Time Regulations 1998 (Reg 9) |
Copies of identification documents/right to work | Kept for two years from date of termination of employment | Paper or electronic | Legal obligation Kept in line with the Immigration (Restrictions on Employment) Order (Art 6(1)(b)) |
Criminal records information Information forms DBS check forms DBS certificates |
It would be advisable to consider six months as the maximum time frame (unless safeguarding issues or other similar extenuating circumstances are raised). | Paper or electronic | Legitimate business interest To demonstrate that safeguarding processes were followed |
Gender pay gap reporting information | Kept available for a period of at least three years beginning with the date of publication | Paper or electronic | Legal obligation Kept in line with Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (Regulation 15) |
Payroll and salary records
Record | Retention Period | Storage Format | Lawful basis and reference |
---|---|---|---|
Payroll information | Kept for three years after the end of the tax year to which they relate | Paper or electronic | Legal obligation Kept in line with Income Tax (Pay as You Earn) Regulation 2003 (Regulation 97) |
Intermediary reporting information HMRC have produced guidance on the different information required |
Kept for three years after the end of the tax year to which they relate | Paper or electronic | Legal obligation Kept in line with Income Tax (Earnings and Pensions Act 2003) (Section 716B) as well as The Income Tax (Pay as You Earn) (Amendment No.2) Regulations 2015 |
VAT records Keep records of sales and purchases Keep a separate summary of VAT called VAT account. Issue correct VAT invoices |
Kept for six years or 10 years if using the VAT MOSS service | Paper or electronic | Legal obligation Please see government guidance |
Company accounts | Kept for six years from the end of the last company financial year they relate to (there are circumstances that this would need to be kept shorter/ longer for-please see government guidance for more information) |
Paper or electronic | Legal obligation Please see government guidance |
CIS records | Kept for at least three years after the end of the tax year that they relate to | Paper or electronic | Legal obligation Kept in line with The Income Tax (Construction Industry Scheme) Regulations 2005 (Regulation 51) |
National minimum wage records Records demonstrating compliance with national minimum wage requirements including hours worked |
Kept for three years beginning with the day upon which the pay reference period immediately following that to which they relate ends | Paper or electronic | Legal obligation Kept in line with National Minimum Wage Regulations 2015 (Regulation 59) |
Sickness records | Should not be kept for longer than three years | Paper or electronic | Legitimate business interest To demonstrate that statutory sick pay has been paid/demonstrate why it was not paid in the event that HMRC investigate |
Statutory Maternity/paternity and adoption pay | Kept for three years after the end of the tax year in which the period of statutory pay ends | Paper or electronic | Legal obligation Kept in line with Statutory Maternity Pay (General) Regulations 1986 (and other corresponding legislation) (Regulation 26) |
Pensions auto- enrolment | Kept for a minimum of six years, some records will need to be kept for a longer period | Paper or electronic | Legal obligation Please consider Pensions Regulator guidance |