IP8 Document and Data Retention Principles - CIMA

1 1 Procedure IP8 Document and data Retention Principles Eligibility All CIMA staff and Council/Committee members Principles status To inform employees and appropriate members of the Principles for the Document and data Retention Principles , both hard and electronic copies Procedure statement 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.

2 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.

3 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. 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.

4 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 email 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 email 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 Head of Corporate Affairs Author Process Analyst/Corporate Affairs Manager Principles date 13 May 2008 Issue 7 Version Control Issue Applicable from/to 1 1st March 2008 (first draft) 2 8th May 2008 (following consultation with Heads of Departments) 3 13th May 2008 (following approval at CPRB)

5 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 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 Life of CIMA Head of Corporate Affairs Agenda papers (for Council and Committee meetings) 7 years minimum Life of CIMA for papers required to understand the minutes Head of Corporate Affairs Proxy forms no poll One month after meeting Head of Corporate Affairs Proxy forms / polling cards poll One year after meeting Head of Corporate Affairs Area Coordinator Committee minutes and Regional Board minutes Life of CIMA Manager, Members and Students Network Services Insurance Accident/claims correspondence 6 years after settlement Finance Manager Insurance schedules/policies 7 years Finance Manager Public/product/employers liability policies Life of CIMA Finance Manager Claims correspondence 3 years after settlement Finance Manager Other policies Until claims under policies are barred Finance Manager Human Resources Assessment notes, equal opportunities forms and interview notes for unsuccessful candidates 12 months Director of Human Resources Date of confinement (MATB1), maternity details (ML1)

6 , career development information, date of confinement paternity (SC3) )3 years ) )1 year ) Director of Human Resources General practitioner certificates, appraisals, P11D correspondence, performance plans 3 years Director of Human Resources Tax enquiries, tax general 4 years Director of Human 4 correspondence, tax P45, P46, P6, P9 Resources Healthcare correspondence, disciplinary correspondence, disciplinary report, grievance correspondence 5 years ) ) 6 years after employment ) ends Director of Human Resources Sickness self certification form, leaver/resignation notice, pay increase letter, promotion letter, redundancy letter 6 years Director of Human Resources 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* Life of CIMA *Publisher s recommended shelf life Director of Human Resources Facilities Agreements with architects / builders keep Retain for as long as we occupy the premises and for 10 years after we have left Head of Logistics Leases 12 years after termination and any terminal queries have been settled.

7 (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.) Head of Logistics Accident books 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 5 Finance Accounting records 10 years Senior Finance Business Partner Budgets and periodic internal financial reports 6 years Senior Finance Business Partner VAT records 6 years Senior Finance Business Partner Tax records 7 years Senior Finance Business Partner Financial Promotions/Advertisements Employer/Student Recruitment Material Indefinitely International Customer Marketing Manager Product Marketing Material Indefinitely Product Marketing Manager Brand and Identity Guidelines Indefinitely Head of Brand and Marketing Services Other areas Legal documents Retain all that are still in force Head of Corporate Affairs Contracts and agreements 10 years after expiry Head of Corporate Affairs Complaints 7 years Head of Professional Conduct Financial promotions/advertisements Indefinitely Head of Brand and Marketing Services Intellectual property rights, certificates of registration.

8 Agreements and licences 7 years after cessation of registration. Head of Corporate Affairs Published intellectual material - Applied Research Unit Life of CIMA Head of Research & Development Published Intellectual Material - Knowledge Unit Life of CIMA Head of Profile & Communications CIMA s syllabi all versions Life of CIMA Director Examinations Professional Conduct Conduct Committee Rules (Establishing policies & procedures) Permanent Head of Professional Conduct Conduct Committee Notes of Cases/Decisions 7 years Head of Professional Conduct 6 Conduct Committee/case hearing transcripts 7 years Head of Professional Conduct Conduct Committee reference & guidance manuals Permanent- archive once administrative use has concluded Head of Professional Conduct Case Files (hard copy only) 7 years (minimum) Head of Professional Conduct Legal advice documents Superceded + 5 years Head of Professional Conduct Conduct Committee case lists/bundles/case papers 7 years (one complete copy)

9 Other copies to be destroyed via secure means Head of Professional Conduct Hearing/Meeting Box 7 years minimum (one complete copy archived) Head of Professional Conduct Conduct Committee training materials Superseded + 3 years One copy to be retained. Other copies to be destroyed via secure means Head of Professional Conduct Active Case Log Transitory Document ; names retained for duration of process. Head of Professional Conduct Closed Case Log Permanent Head of Professional Conduct Watching Brief Log Names retained for 3 years from point of initial notification Head of Professional Conduct Potential Complaints Log 1 year from receipt of initial correspondence Head of Professional Conduct Key CIMA publications relevant to conduct work ( all editions): Charter, Byelaws & Regulations Ethical Guidelines Code of Ethics Permanent Head of Professional Conduct CIMA Enterprises Limited Registers of: - members - mortgages and charges - directors and secretaries - directors interest in shares or debentures Certificate of incorporation Life of the company for all Head of Corporate Affairs 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 7 years minimum Life of the company for papers required to understand the minutes Head of Corporate Affairs Notice of general meetings Circulars to shareholders 12 years Life of the company for papers required to understand the minutes Head of Corporate Affairs Certificate of posting of notices 2 years Head of Corporate Affairs Annual returns 3 years Senior Finance Business Partner Finance records (private company)

10 7 years Senior Finance Business Partner VAT records 6 years Senior Finance Business Partner Tax records 7 years Senior Finance Business Partner Local laws* Finance records in China 15 years Divisional Director, China Finance records in Australia 7 years Australia National Manager Finance records in Hong Kong 7 years Hong Kong Divisional Director Finance records in Ireland 7 years Ireland Divisional Director Finance records in Malaysia 7 years Malaysia , Regional Director of South East Asia Finance records in Sri Lanka 5 years Sri Lanka Regional Director Finance records in South Africa 5 years Southern Africa Regional Director Finance records in Singapore 10 years Singapore Branch Representative Finance records in India 8 years 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.