Scope and principles
All Shift Learning’s records and data, whether digital or analogue, are subject to the retention requirements of this procedure.
In this policy document we aim to operate in a way that is legal, in accordance with the DPA2018, the GDPR, the guidelines of the MRS and ESOMAR and the quality standard for market research ISO 20252. Where there are conflicts between these policies we have used our judgement, prioritising what is legal and ethical. In alignment with the GDPR, it has the ambition that data is not held for longer than is necessary but that the storage of data for longer periods than necessary is allowable where the data is being processed for archiving purposes in the public interest and/or scientific purposes.
2. Responsibilities
2.2 The Director is responsible for the retention of financial, HR, Health & Safety, statutory and regulatory records and data in line with these procedures.
3. Procedures
3.1 The required retention periods by record type are recorded below.
3.2 Sensitive data may require a certificate of destruction. This should be raised on project start with the Director.
4. Exceptions
4.1 Exceptions should be made to general deletion principles if there is litigation occurring or pending.
4.2 Exception can be put into place if individuals are exercising their right to be forgotten.
5. Policy review
5.1 This policy is to be reviewed by the company directors at least annually.
| Record type | Retention Period | Retention Period to start from | Retention justification | Medium and storage location | Disposal Method | Person with responsibility to dispose |
| Accounts info | 5 years | End of that financial year accounting period | Legal reasons, in case of investigation | Paper and electronic | Shredding & Deletion | Director |
| Staff and freelance associates personal details | 5 years | End of that financial year accounting period | Legal reasons, in case of investigation | Paper and electronic | Shredding & Deletion | Director |
| Client and potential client data | Retained unless unsubscribed or bounced back. Request annual update. | n/a | Use for mailings | Electronic | Deletion | Director |
| Respondent opt-in surveys | Must be entered into Panel mailing system within 30 days then deleted | Survey close | Need it until this point | Electronic – within panel mailing host | Deletion | Project manager Director |
| Respondent contact data from opt ins esurvey | Retained unless unsubscribed or bounced back. Request annual update. | n/a | Opt-in data with full permission required for future projects. | Electronic – within panel mailing host | Deleted | Project manager Director |
| 3rd party lists sent by clients | Deleted from FTP when downloaded onto One Drive. Version deleted within one week payment of the final client invoice | n/a | Should be retained in case additional services are required up until this point. All files of this type to be password protected with passwords held in the Directors private drive. | Electronic file | Deletion | Director to delete FTP; Project Manager to delete from the shared drive |
| 3rd party lists obtained from suppliers | Single use – deleted on payment of the final client invoice Multiple use – kept on Jack’s private drive and deleted only when uses are used up | n/a | Should be retained in case additional services are required up until this point. All files of this type to be password protected with passwords held in the Directors private drive. | Electronic file | Deletion | Director to delete FTP; Project manager to delete from the shared drive |
| Other data from clients e.g. data on enrolments, market share data | Deleted on payment of the final client invoice | n/a | Should be retained in case additional services are required up until this point | Electronic file | Deletion | Director |
| Focus group and interview opt-ins | Must be entered into panel mailing system within 30 days then destroyed | Date of focus group | Need it until this point | Electronic file | Deletion | Director |
| Interview and focus group recordings (video & audio) | Deleted on payment of the final client invoice | n/a | Should be retained in case additional services are required up until this point | Video & audio files | Deletion | Project Manager/ Director |
| Interview and focus group transcripts (with identifying information) | Deleted when anonymised | n/a | Should be retained in case additional services are required up until this point | Electronic | Deletion | Project Manager/ Director |
| Interview and focus group transcripts (pseudonymised) | 1 year | Final client invoice | In case of client audit | Word files | Deletion | Project Manager/ Director |
| Interview & focus group schedule with participant names | Deleted on payment of the final client invoice | Final client invoice | In case of client audit | Excel files | Deletion | Project Manager/ Director |
| Project print outs, presentations, etc. | Deleted on payment of the final client invoice | Final client invoice | In case of client audit | Word files | Deletion | Project Director |
| Interview and focus group participants incentive information | All banking and account information, address and contact detail – delete when all successfully paid: Names & amounts and method of payment, agreements and date and project to be kept password protected on the Director’s private drive. | Final payments of respondents | In case of problems with payment | Spreadsheets | Deletion | Project Manager/ Director |
| eSurvey results (with identifying information) | To be deleted, once prize draw winners have been drawn and accepted their prize and the opt-ins have been transferred to panel mailing system. | n/a | No requirement for it after this point | Electronic file | Deletion | Project Manager/ Director |
| eSurvey results (anonymised) | To be retained for 8 years | n/a | Contain no personal data, therefore not a concern. Retained in case of requirement for longitudinal work. | Survey data saved in Excel with no personal data | n/a | n/a |
| eSurvey prize winners bank details | To be deleted, once prize draw winners have been drawn and accepted their prize | n/a | No requirement for them after this time | Electronic file | Deletion | Project Manager/ Director |
| Work emails | Emails to be archived after 7 years UNLESS they contain other sorts of data covered in this policy e.g. 3rd party data, financial | n/a | May be needed in the case of litigation or dispute. | Electronic file | Deletion | Individual staff members |
| Research tools, proposals, reports | Final versions to be kept in the file. Whole project files to be deleted after 8 years. | Final project invoice | Contain no personal data, therefore not a concern – may be useful for future projects | Electronic file | Deletion | Project Director to delete all but final versions |