retention & disposal policy

This policy sets out:

• the general timescales for which we will retain relevant records;
• requirements for the disposal of relevant records.

This policy only relates to records we hold containing or relating to personal data. Other records are covered by other policies.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, please contact our Data Protection Officer using the contact details set out at the bottom of this policy.

This version of the retention and disposal policy is effective as of 12 July 2021.

We reserve the right to amend this policy at our sole discretion, without prior notice to you. However, this does not affect your applicable rights as set out in our privacy policy.

This policy applies to relevant records applicable to personal data held by Warrant Group:

• relating to any person in connection with the employment or engagement of people by us, including:
  • our employees, former employees and prospective employees (including temporary workers);
  • certain existing, former and prospective contractors or consultants; and
  • individuals who have a family relationship or other connection with the above people, whose details we obtain from those people in connection with their employment or engagement;
• relating to others, such as the customers and suppliers of Warrant Group; and
• which we obtained through use of our website.

Unless otherwise specified, this policy refers to both paper records and ‘soft copy’ records.

Records will ordinarily only be kept for as long as is necessary for the purposes for which the relevant personal data is to be used, as set out in our privacy policy. However, the retention period may be longer:

• in accordance with any applicable provisions of our privacy policy; or
• if permitted or required by legal and regulatory requirements.

The Record Retention Schedule below sets out the applicable retention periods we normally apply to relevant records.

Notwithstanding the Record Retention Schedule below, our Data Protection Officer will from time to time review the retention periods for records or different categories of information and will determine whether they should be destroyed or retained for a further period, having regard to applicable legal and regulatory requirements or the provisions of our privacy policy.

Relevant records will be destroyed in the following ways:

• records held in paper format will be cross-cut shredded and pulped or burnt;
• electronic or soft-copy records will be destroyed using means appropriate to render them non-recoverable;
• where applicable, individual folders will be permanently deleted from the system; and
• electronic equipment which is disposed of which contains relevant records will be destroyed after fist using killdisk (or similar) to permanently erase the relevant records.

We will not be obliged to document the disposal of records when doing so in accordance with the Record Retention Schedule.

Where we dispose of relevant records other than in accordance with the Record Retention Schedule (either by being disposed of earlier or kept for longer than listed), we will ordinarily document such disposal for audit purposes (but without referring to any identifiable individual to which the records related).

If you have any questions about this policy, please contact us by:

• If you have any questions about this policy, please contact us by:

Lynsey Morrison, Data Protection Officer

Warrant Group Limited

157 Regent Road

Liverpool

Merseyside

L5 9TF

or:

emailing our Data Protection Officer by sending an email to: lynsey.morrison@warrant-group.com.