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17 March 2022
PJH Law Demo
Company House
Company Road
ComapyCity PE9 2AZ


  • Data retention policy New
  • Equal opportunities policy
  • Sickness and attendance policy

Data retention policy New


    1. The Employer holds many different types of documents containing a variety of data, including customer details, employee information as well as confidential information about the organisation and how it operates. These documents are a vital part of our business and it is important that we ensure that we protect the documents and information contained in them in order to ensure the smooth running of the business and also to comply with the requirements laid down by law.
    2. We have outlined the procedures laid down for retention, review and destruction of documents held by us. The purpose of this policy is to ensure that we only hold documents for as long as necessary and that once they are no longer required, they are destroyed in accordance with the procedures laid down in this policy.
    3. This policy supplements our Data Protection Policy.

    1. This policy sets out The Employer’s approach to managing its information to ensure that records and documents are preserved in line with business and legislative requirements and that data is not retained for any longer than necessary.
  3. SCOPE

    1. This Data Retention Policy applies to:

      • all staff, volunteers, consultants, contractors, trustees and, as appropriate,partnership organisations, partner staff and third parties of The Employer.
      • all records that are created, handled, stored, or processed by The Employer,electronically (soft copy) or in paper (hard copy) form.
      • All those people or groups to whom this policy applies should, as appropriate, be aware of this policy.

    1. Any exceptions or variations to compliance with this policy must be approved by the HR department.
    2. When preparing tender documents and/or negotiating contracts with third parties for services thatinvolve retaining and managing records, reference to this policy will help ensure that consistent data retention obligations are met.
    3. The intention is that only one copy of a record is retained but ensure that before you destroy any records in circumstances where you believe multiple copies of a record exist that at least one copy (or the original) is retained.
    4. Suppliers and their subcontractors must have their own defined retention policy, which must be supported by documented retention requirements and procedures and which mirrors this policy in all material respects.
    5. Unless suppliers (where they act as Data Processors) have a legal obligation to do so, they should not retain The Employer’s data after they have finished providing services to The Employer.

    1. The relevant types of record are:

      • Accounting and Finance.
      • Contracts.
      • Corporate Records.
      • Correspondence and Internal Memoranda.
      • Personal Information.
      • Electronic Records.
      • Grant Records.
      • Insurance Records.
      • Legal.
      • Miscellaneous.
      • Personnel Records.
      • Tax Records.

      • Annual Audit Reports and Financial Statements:Permanent.
      • Annual Audit Records, including work papers and other documents that relate to the audit: 7 years after completion of audit.
      • Annual Plans and Budgets:7 years.
      • Bank Statements and Cancelled Cheques:7 years.
      • Employee Expense Reports:7 years.
      • Interim Financial Statements:7 years.

      • Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation): 7 years after expiration or termination.

      • Corporate Records (minutes, signed minutes of the Board and all committees, record of incorporation, articles of incorporation, annual corporate reports):Permanent.
      • Licenses and Permits:Permanent.

      • General Principle: Most correspondence and internal memoranda should be retained for the same period as the document to which they pertain or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.
      • Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

        • Those pertaining to routine matters and having no significance. These should be discarded within five years. Some examples include:

          • Routine letters and notes that require no acknowledgment or follow up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
          • Form letters that require no follow up.
          • Letters of general inquiry and replies that complete a cycle of correspondence.
          • Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
          • Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
          • Chronological correspondence files.
          • Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed unless that information provides reference to or direction to other documents and must be kept for project traceability.
        • Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently.

      • This section sets out the data retention policies and procedure of The Employer, which are designed to help ensure compliance with legal obligations in relation to the retention and deletion of personal information.
      • Personal information that is processed by The Employer for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
      • Without prejudice to the point immediately above, The Employer will usually delete personal data falling within the categories set out below at the date/time set out below:

        • Information about a computer and about visits to and use of this website (including an IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths:2 years.
        • Information provided when registering with our website (including email address): 2 years
        • Information provided when completing a profile on our website (including a name, gender, date of birth, interests and hobbies, educational details):2 years.
        • Information provided for subscribing to email notifications and/or newsletters (including a name and email address): Indefinitely or until the client chooses to ‘unsubscribe’
        • Information provided when using the services on the website, or that is generated during the use of those services (including the timing, frequency and pattern of service use): Indefinitely.
        • Information relating to any subscriptions made (including name, address, telephone number, email address and sector sought):2 years or until consent is withdrawn
        • Information posted to our website for publication on the internet: 5 years after post.
        • Information contained in or relating to any communications sent through the website (including the communication content and meta data associated with the communication): 2 years following contact.
        • Any other personal information chosen to be sent:2 years following contact.
      • Notwithstanding the other provisions of this section, The Employerwill retain documents (including electronic documents) containing personal data:

        • to the extent that The Employer is required to do so by law;
        • if The Employer believes that the documents may be relevant to any ongoing or prospective legal proceedings;and to establish, exercise, or defend The Employer’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
        • if explicit consent is given by the data subject. Consent is requested at least every 2 years from candidates seeking contract roles and at least every 12 months for candidates seeking permanent employment.

      • Electronic Mail: Not all email needs to be retained, depending on the subject matter.

        • All e-mail—from internal or external sources – is to be deleted after 12 months.
        • Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
        • The Employer will archive e-mail for 90 days after the staff has deleted it, after which time the e-mail will be permanently deleted.
        • Staff will take care not to send confidential/proprietary information held by The Employerto outside sources.
      • Electronic Documents: including Office 365 and PDF files, retention also depends on the subject matter.
      • The Employer does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.
      • In certain cases, a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

      • Certificates issued to The Employer: Permanent
      • Claims Files (including correspondence, medical records, etc.): Permanent
      • Insurance Policies (including expired policies): Permanent

      • Legal Memoranda and Opinions (including all subject matter files): 7 years after close of matter
      • Litigation Files:1 year after expiration of appeals or time for filing appeals
      • Court Orders: Permanent

      • Policy and Procedures Manuals – Original:Current version with revision history
      • Annual Reports:Permanent

      • Employee personnel records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records):6 years after separation
      • Employment contracts – Individual: 6 years after separation
      • Employment records correspondence with employment agencies and advertisements for job openings:3 years from date of hiring decision

      • General principle: The Employer must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.
      • These documents and records shall be kept for as long as the contents thereof may become material in the administration of state, and local income, franchise, and property tax laws.
      • Tax-exemption documents and related correspondence:Permanent
      • Tax bills, receipts, statements:7 years
      • Tax returns:Permanent
      • Sales/use tax records:7 years
      • Annual information returns:Permanent

Equal opportunities policy


    1. It is The Employer’s policy not to discriminate against its workers and/or employees because of their gender, marriage and civil partnership, sexual orientation, marital status, any gender reassignment, race, religion or philosophical belief, colour, nationality, ethnic or national origin, disability or age, pregnancy and maternity or trade union membership or the fact that they are a part-time worker or a fixed-term employee. The Employer will not tolerate discrimination by association and/or by perception and will not tolerate discrimination arising from disability. The Employer will not tolerate discrimination, because of any of the above grounds, of customers and/or clients in the provision of goods and services.
    2. The following paragraphs deal with the specific categories of workers and areas of work which we have identified as potentially giving rise to equal opportunities issues and provides more specific guidance on the parameters of our policy and approach to equal opportunities.

    1. This policy applies to The Employer’s employees, whether permanent, temporary, or casual, part-time or on fixed-term contracts, and to individuals such as agency staff and consultants.
    2. In addition, all workers have a duty to act in accordance with this policy, and therefore to treat colleagues with dignity at all times, and not to discriminate against or harass other members of staff, whether junior or senior to them. The Employer will not tolerate any discriminatory practices or behaviour and any such conduct may be viewed as gross misconduct entitling The Employer to dismiss you summarily.

    1. The Human Resources department has overall responsibility for the effective operation of this equal opportunities policy and for ensuring compliance with the relevant statutory framework prohibiting discrimination.
    2. All members of staff are responsible for the success of this policy and must ensure that they familiarise themselves with the policy and act in accordance with its aims and objectives.

    1. The Employer will not unlawfully discriminate because of gender, sexual orientation, marriage and civil partnership, gender reassignment, race, religion or philosophical belief, colour, nationality, ethnic or national origin, disability or age, pregnancy and maternity, trade union membership, or part-time or fixed-term status (“Protected Characteristics”).
    2. This policy applies, without limitation, to the advertising of jobs and recruitment and selection; to training and development; opportunities for promotion; to conditions of service, benefits and facilities and pay; to health and safety and to conduct at work, to grievance and disciplinary procedures and to termination of employment including redundancy.
    3. You are also prohibited from harassing another employee and/or worker on any of the grounds under 4.1. Harassment is defined as any unwanted conduct, related to any of the Protected Characteristics set out in paragraph 4.1 above, that has the purpose or effect of violating your dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. It is not the intention of the perpetrator that is important when considering whether harassment has taken place but your perception of the behaviour. Harassment can range from extremes such as violence to less obvious forms such as ignoring someone. Forms of harassment might include (without limitation):

      • Physical contact;
      • Bullying;
      • Unwelcome remarks about someone’s race or marital status or any other Protected Characteristic;
      • Persistent criticism;
      • Jokes, offensive language, gossip, lewd or suggestive comments;
      • Posters, obscene gestures, graffiti;
      • Isolation, non-co-operation, and exclusion from social activities;
      • Coercion for sexual favours;
      • Failure to safeguard personal confidential information;
      • Unnecessary body contact; threatened or actual assault or violence;
      • Deliberate exclusion from conversations or work activities because of any Protected Characteristic;
      • Display of “pin ups”, pornography, inflammatory or abusive literature or graffiti:
      • Using email or the internet for the purpose of bullying or making abusive or offensive remarks related to any Protected Characteristic.
    4. You should be aware that, as well as committing a disciplinary offence, an individual found to have discriminated against a fellow employee/worker in the course of their employment may be personally liable to compensate the victim. In addition, harassment for whatever reason may constitute a crime under the Protection from Harassment Act 1997 punishable by imprisonment and/or a fine.

    1. Discrimination may be direct or indirect and it may occur intentionally or unintentionally. Direct discrimination occurs where someone is treated less favourably because they have one of the Protected Characteristics or are thought to have a Protected Characteristic as set out in paragraph 4.1 or because they associate with someone who has a Protected Characteristic.
    2. Indirect discrimination occurs when an unjustifiable requirement, condition or practice is imposed, apparently to all individuals, but has the effect that certain groups of individuals (who share a Protected Characteristic as set out in paragraph 4.1) cannot comply with it or are put at a particular disadvantage.
    3. Discrimination also includes victimisation (less favourable treatment because of action taken to assert legal rights against discrimination or to assist a colleague in that regard) and harassment.

    1. If you believe that you may have been disadvantaged because of any of the Protected Characteristics listed at paragraph 4.1 (or for any other reason) you are encouraged to raise the matter through The Employer’s grievance procedure. If you believe that you may have been harassed because of any Protected Characteristic listed at paragraph 4.1 (or for any other reason), you are encouraged to raise the matter through our grievance policy. Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure.
    2. Workers who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations of a breach in this policy, which are found to have been made in bad faith will, however, be dealt with under our disciplinary procedure and may result in summary dismissal on grounds of gross misconduct.
    3. The Employer will not tolerate retaliation against, or victimisation of any employee involved in bringing of a complaint of harassment or bullying under The Employer’s procedure. Such retaliation or victimisation will itself constitute a disciplinary offence, which may in appropriate circumstances lead to dismissal.
    4. If, after investigation, you are proven to have harassed any other worker or otherwise act in breach of this policy, you will be subject to disciplinary action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. The Employer will always take a strict approach to serious breaches of this policy.
    5. As this policy applies equally to The Employer workers’ relations with clients and suppliers, if, after investigation, you are proven to have discriminated against or harassed a client or supplier you will also be subject to disciplinary action.

Sickness and attendance policy


    1. Time off is permitted for maternity, paternity, adoption, and dependency matters.
    2. Apart from Statutory Sick Pay (SSP) at the prevailing rate for over 3 qualifying days absences, subject to eligibility, any payment made to you for periods when you are absent from work for reasons other than the above will be entirely at the discretion of your line manager.
    3. In exercising such discretion, they may consider whether there is any evidence of the system being abused, the level and pattern of absence and the steps taken to hasten a return to work, together with any other factors considered to be relevant.
    4. Prolonged or frequent absence may render you liable to dismissal.

    1. When you return to work after a period of absence in excess of [ ] days , a return-to-work interview will be conducted to ensure you are fully recovered and to help you avoid future absences.
    2. Subject to medical consent, you will be expected to make yourself available for light duties if you are not fit for your ordinary job. The Employer reserves the right to alter your salary to a level commensurate with the duties actually undertaken.

    1. If you cannot attend work, or expect to be late for work, for any reason then you must let us know as soon as possible.
      • You must phone your line manager by [ ] to let us know of your absence.
      • If you are unable to phone personally, you must ensure that a message is passed to the above on your behalf;
      • Communications by text message are unacceptable;
      • On a day that you report in sick, you will notify as above by the end of the day if you expect to be off work on the next working day (including on-call days) so that work can be re-scheduled;
      • For each day that you can’t work after the first day, that you phone in each day as above unless you have been issued with a medical certificate for a longer period, when you must convey this to the office;
      • If you are sick for more than three consecutive days, you must submit a Self-Certification Form. If your sickness lasts longer than seven consecutive days, you must submit a Medical Certificate signed by your doctor. The certificate should cover all days of illness, not just working days;
      • When you return to work, a return-to-work interview will be conducted where any medication being taken will be noted. Where medication is prescribed, you are also required to fill in amedication notification form.
      • The Employer reserve the right to withdraw employee self-certificated sick leave entitlement where abuse is suspected. Where that right has been withdrawn a doctor’s certificate will be required for any sick leave taken.

    1. You must have disclosed to The Employer at the time your employment commenced or as soon as you are aware after this, all and any past or existing medical conditions, which may now, or at any time in the future, affect your ability to perform your duties. If it transpires that you have not disclosed any such conditions, you may, in appropriate circumstances, be liable to summary dismissal for gross misconduct.
    2. The Employer reserves the right to require you to undergo a medical examination by a qualified medical practitioner at The Employer’s expense. You have consented to this requirement and also to the disclosure of the results of that medical in your application for employment. The Employer will treat such results in confidence at all times.

    1. Where absences are short term but multiple in nature and the employee’s attendance record is unacceptable, The Employer’s capability procedure may be initiated, which can include the giving of warnings and possibly dismissal. Whether or not such action is taken will in part depend on whether there is an underlying long-term health problem causing the absences or whether the absences are for unconnected reasons.

    1. The Employer will comply with its obligations to make reasonable adjustments under Equality legislation.
    2. The Employer will, wherever possible, consider all reasonable adjustments which could be made in respect of an employee’s work in order to facilitate their return to work or to assist them after a return to work. Such adjustments may include a reduction in hours, the transfer of certain duties to other employees, physical adjustments, and retraining. Such adjustments may be adopted on a temporary or permanent basis depending on the circumstances of each case.

    1. Absences due to pregnancy-related illness, maternity leave and time off for antenatal appointments, paternity leave, parental leave, and other statutory leave will not be taken into account when reviewing an individual’s attendance record. Please see the relevant policies or the HR department for details of time off rights.

    1. Employees will be entitled to be accompanied by a trade union representative or a work colleague to any meetings which could result in a formal warning or some other disciplinary action. This will not normally include the attendance reviews described above unless a possible outcome of that meeting is a formal warning or other disciplinary action in which case the employee will be advised in advance so that they can arrange for a companion.