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Data Retention Policy


FPR Group collects and processes personal information “Data Records” relating to its employees, workers, work-seekers, job applicants and other people that FPR Group may have a relationship with.  For the purpose of this policy the term “Data Record” includes information in both hard copy and electronic form e.g. text messages, emails, PDF documents.

This policy outlines what data records FPR Group holds, how long we hold them, the disposal of and, is also for the purpose of aiding employees of FPR Group in understanding their responsibilities under GDPR and of adhering to the guidelines specified in this policy.

Data Retention Schedule

Data Record

Document Type

Sourced From

Retention Period

Basis for Processing/Holding Data


Work-seeker records


Application Forms;

I.D Checks;

Driving Licence;

Qualification Certificates;

Terms of Engagement;


Emergency Contact Details;




Job Boards;

Advert Applications;

Company Website;


Email Correspondence;

Telephone Conversations;

2 Years (from the last date of engagement or providing work finding services) unless, if no service is provided then it will be retained for 6 months.

Legitimate Interest;


Necessary for the performance of a contract

Client Records

Contact Information;


Terms of Business;

Health & Safety documents;

Induction documents;

Vacancy details;

Assignment Details

Canvass Calls;

Social Media;


Telephone Conversations;

Hiring Preferences;

Job Descriptions;


Health Declaration Form

2 Years (from the last date of engagement or providing work finding services) unless, if no service is provided then it will be retained for 6 months.


Legitimate Interest;

Necessary for the performance of a contract

Client IR35 Records

Status Determination Statement

Exemption Declaration


6 years

Legal – HMRC


Working Time Records

48 Hours Opt out notice;

Annual Leave records;




2 Years (from the last date of engagement or providing work finding services)

Legal – in relation to Working Time Regulations 1998.

Right to Work Records


National I.D Card;

Birth Certificate;

National Insurance Number;

Visa (if applicable)

Employees ;



2 Years (from the last date of engagement or providing work finding services)

Legal – In relation to Immigration Act 2016 and Compliance with Equality Act 2010

Criminal Record Checks

Disclosure Barring Form

Disclosure Barring Service;


From date of check, then for no longer than is necessary. This retention allows for the consideration and resolution of any disputes, complaints or for the purpose of completing safeguarding audits.


Legal – in relation to working with children

&/or vulnerable adults 

Sensitive Personal Data

Criminal Record Declaration Form;

Health Declaration;

Night Workers Health Declaration Form;

Health Questionnaire;




2 Years (from the last date of engagement or providing work finding services) unless request to be forgotten is received


Necessary for the performance of a contract

Payroll Records



Bank details;





Former Employers;

6 Years

Legal – HMRC obligation

Pensions Records

Auto enrolment date;

joining date;

opt in and opt out notices;

Contributions paid;


Pension Providers

6 Years

Legal – HMRC obligation

National Minimum Wage Records

Total Pay & Hours worked;



Any absences: Sickness, holiday etc.;

Travel or training

Payroll records

3 Years

Legal – HMRC obligation (National Minimum Wage Act 1998)

Statutory Pay Records

Sick Pay & Certificates;



Shared Parental;


Payroll records;



3 Years

Legal – HMRC obligations

Gender Pay Gap Reporting

Payroll Reports

Payroll Records

1 Year (but statement must be kept on Government and Company website for 3 Years


Accounting Records

Company Accounts;


PAYE & N.I returns

Finance Records;

6 Years


Quality Records

Quality Control Forms;





3 Years

ISO Quality Accreditation


Retention Rules

The Company; monitor legislation affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

In the event, for any category of data record not specifically defined elsewhere in this Policy (and in particular within the Data Retention Schedule)  they should be destroyed once the purpose and usefulness of the content ceases or at a maximum period of, 2 years from the date of creation of the document, unless otherwise mandated differently by applicable law.

Suspension of Record Disposal

There are certain occasions when information needs to be preserved beyond any limits set out in this Policy.

  • If the Company is served with any legal request for records or information;
  • If any employee becomes subject of an audit or investigation, or;
  • We are notified of the commencement of any litigation against our firm;

We will suspend the disposal of any scheduled records until we are able to determine the requirement for any such records.

Security & Storage

The Company will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of the Data Records held.

Data records are grouped together in clear date order when stored and/or archived, in a secure location, with authorised personnel being the only ones to have access.


Destruction & Disposal of Data Records

All data records must be securely destroyed and the Company is committed to the secure and safe disposal of;

Paper Records - Due to the nature of our business, the Company retains paper based data records and as such, has a duty to ensure that these are disposed of in a secure, confidential and compliant manner.  The Company utilise onsite shredding and a professional shredding service provider to dispose of all paper materials.

Electronic Data - The Company and its employees should review at regular intervals and delete any data once the purpose for which is was created is no longer relevant.

Electronic & IT Records and Systems -The Company uses numerous systems, computers and technology equipment in the running of the business.  From time to time, such assets must be disposed of and due to the information processed and held on them, whilst they are active, the disposal must be handled in an ethical and secure manner.

I.T Equipment - to be disposed of must be dealt with by our external IT Facility Managers, who will ensure that all data is removed from the media prior to destruction.

Mobile Phones -   All obsolete mobile phones must have the data erased and then returned to Head Office for disposal.

Roles & Responsibilities

All staff have a duty to make sure that they comply with the data protection principles, which are set out in the Company Data Protection Policy. In particular all staff must ensure that records are: 

  • Accurate;
  • Up-to-date;
  • Fair;
  • Kept and disposed of safely, and in accordance with the Company policy;

 All staff are responsible for ensuring that all data records held are; 

  • Kept in a locked filing cabinet; or in a locked drawer, or if computerised, be password protected;
  • Never stored at staff members homes, whether in manual or electronic form;
  • Not disclosed either orally or in writing or accidentally or otherwise to any unauthorised third party, including other members of staff.
  • Report any suspicion of a breach of this Policy immediately to a Adele Walker. 

Before processing any data records, all staff should consider the checklist below;              

  • Do you really need to record the information?
  • Is the information “standard” or is it “sensitive”
  • If it is sensitive, do you have the data subjects express consent?
  • Has the data subject been told that this type of data will be processed?
  • You are authorised to collect/store/process the data?
  • Are you sure that the data is secure? 


The Company may update this policy from time to time by publishing a new version.

This page should be checked occasionally to ensure that the policy remains relevant.

Contact Information

First People Recruitment Ltd                                                    Adele Walker

132 Queens Road                                                                         Email - [email protected]

Brighton,  BN1 3WB                                                                     Telephone – 01273 202453

The Information Commissioner’s Office (ICO) can be contacted at: -

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate) Fax: 01625 524 510

Email: [email protected] 

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