Organisational Policy on Data Retention and Secure Deletion

1. Purpose

This policy establishes the principles and procedures for the retention and secure deletion of data within the organisation. It ensures that all personal, confidential, and business-critical data is retained only as long as necessary to fulfil its intended purpose, meet legal/regulatory obligations, and is securely deleted when no longer required.

2. Scope

Applies to all employees, contractors, and third parties who process, manage, or store data on behalf of the organisation. It covers all forms of data—electronic files, emails, paper documents, and data held within systems, applications, and devices.

3. Definitions

• Data: Any information held or processed by the organisation, including personal data, confidential business information, and operational records.
• Retention Period: The length of time data must be kept to meet business, legal, or regulatory requirements.
• Secure Deletion: Permanent erasure of data so it cannot be reconstructed or retrieved.

4. Policy Principles

1. Data Minimisation: Collect and retain only data necessary for specified, legitimate purposes.
2. Retention Schedules: Define and maintain retention periods for each data category in line with legal, regulatory, and business needs.
3. Review & Disposal: Review data regularly. Data that has reached the end of its retention period, or is no longer required, must be securely deleted or destroyed without delay.
4. Secure Deletion Methods: For electronic data, use overwriting, degaussing, or physical destruction of storage media. For paper records, use cross-cut shredding or incineration.
5. Documentation: Record all deletion/destruction activities; obtain witness signatures or system logs for audit purposes when appropriate.
6. Third-Party Compliance: Contracts with vendors or processors must require adherence to this policy and verification of secure deletion practices.

5. Roles & Responsibilities

• Data Owners: Define retention periods, ensure regular reviews, and oversee secure deletion.
• IT Department: Provide/maintain secure deletion tools, support users, and verify technical compliance.
• All Staff: Comply with this policy and report any concerns or breaches to the Data Protection Officer (DPO) or relevant manager.

6. Legal & Regulatory Compliance

Ensures compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and any other applicable legislation or contractual obligations.

7. Policy Review

Reviewed at least annually, or sooner if legislation, business practices, or audit findings require. Updates will be communicated to all staff.

8. Breach of Policy

Non-compliance may result in disciplinary action and could constitute a breach of legal or regulatory obligations.

9. Further Information

For guidance or clarification, contact the Data Protection Officer at [DPO-email@example.com].