Last Modified: 23 Aug 2023
About this policy
The information of Pairly, including data subject data, is vital to how it conducts its business and manages employees.
Certain laws require us to retain certain records, usually for a specific amount of time. The accidental or intentional destruction of these records during their specified retention periods could result in the following consequences:
fines and penalties;
loss of rights;
obstruction of justice charges;
contempt of court charges; and/or
serious disadvantages in litigation.
We must retain certain records because they contain information that:
has business value (for example, it provides a record of a business transaction, evidences our rights or obligations, protects our legal interests or ensures operational continuity); or
must be kept to satisfy legal, accounting, or other regulatory requirements.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
This policy applies to all employees, officers, consultants, contractors, volunteers, interns, casual workers, and agency workers of Pairly Ltd
This policy explains the differences among records and disposable information.
A record is any type of information created, received, or transmitted in the transaction of business, regardless of physical format. Examples of where the various types of information are located include:
appointment books and calendars;
audio and video recordings;
computer programs and the data input into those programs;
letters and other correspondence;
memory in mobile phones and other mobile devices;
online postings, such as on Facebook, Twitter, Instagram, and other social media platforms and websites;
performance reviews; and/or
Any records that hold Personal Data (any information which can be used to identify a living individual, e.g. name, address, telephone number, email) are to be considered part of the relevant category listed in the Records Retention Schedule contained in the Appendix to this policy and must be retained for the amount of time indicated in the Records Retention Schedule.
All records are to be considered and treated as confidential information and should not be disclosed to any third party (including police, courts or other investigatory bodies) without the permission of a Director and/or Privacy Officer.
A record should not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or other situations, e.g. litigation) requires that is retained beyond the set period. If you are unsure whether to retain a certain record, contact the Privacy Officer.
Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a record as defined by this policy. Examples include:
duplicates of originals (that have not been annotated);
preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record;
books, periodicals, manuals, training binders, and other printed materials obtained from sources outside of the company and retained primarily for reference purposes; and/or
spam and junk mail.
Guidelines for DESTRUCTION
Each member of staff is responsible for the continuing process of identifying the records that have met their required retention period and supervising their destruction. The destruction of confidential, financial, and personnel-related records must be conducted by shredding if possible our may be outsourced to a reputable third party who provides record destruction services. Non-confidential records may be destroyed by recycling. The destruction of electronic records must be coordinated with the Privacy Officer.
The destruction of records must stop immediately upon notification from the Privacy Officer, a Director or on notice that the company may be involved in a lawsuit or an official investigation.
Breach of this policy
Breach of this policy may result in disciplinary action up to and including dismissal. Any member of staff suspected of committing a breach of this policy will be required to co-operate with our investigation, which may involve handing over relevant passwords and login details.
You may be required to remove any social media content that we consider to constitute a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action.
Record Retention Schedule
Employees should give special consideration to the categories of documents listed in the record retention schedule below. Avoid retaining a record if there is no business reason for doing so, and consult with the Privacy Officer if unsure.
|Benefits descriptions per employee||7 years|
|Employee applications and resumes||1 year|
|Employee offer letters (and other documentation regarding hiring, promotion, demotion, transfer, lay-off, termination or selection for training)||1 year from date of making record or action involved, whichever is later, or 1 year from date of involuntary termination|
|Records relating to background checks on employees||5 years from when the background check is conducted|
|Employment contracts; employment and termination agreements||7 years from the date of termination|
|Employee records with information on expenses and non-salaried pay||5 years|
|Hazardous material exposures||Indefinitely|
|Supplemental record for each occupational injury or illness||Indefinitely|
|Job descriptions, performance goals and reviews; garnishment records||7 years from the date of termination|
|Employee tax records||7 years from the date tax is due or paid|
|Medical exams||30 years from the termination of employment|
|Pension plan and retirement records||Indefinitely|
|Consumer Profiles||Until 10 months following cancellation or termination of our contract with you.|
|Provider Profiles||Until 10 months following cancellation or termination of our contract with you.|
|Consumer account details (limited to username, name and password allocation)||6 years|
|Provider account details (limited to username, name and password allocation)||6 years|
|Payroll registers (gross and net)||Indefinitely|
|Articles of Incorporation, Bylaws, Corporate Seal||Indefinitely|
|Annual corporate filings and reports to secretary of state and attorney general||Indefinitely|
|Board policies, resolutions, meeting minutes, and committee meeting minutes||Indefinitely|
|Contracts||14 years from the date of termination|
|Emails (business related)||14 years|
|Fixed Asset Records||Indefinitely|
|Sales and purchase records||Indefinitely|
|Accounting and Finance|
|Accounts Payable and Receivables ledgers and schedules||7 years|
|Annual audit reports and financial statements||Permanent|
|Annual plans and budgets||2 years|
|Bank statements, cancelled checks, deposit slips||7 years|
|Business expense records||7 years|
|Electronic fund transfer documents||7 years|
|Employee expense reports||7 years|
|Journal entries||7 years|
|Petty cash vouchers||3 years|
|Legal and Insurance Records|
|Insurance claims/ applications||Indefinitely|
|Insurance contracts and policies||Indefinitely|
|Leases||7 years after termination|
|Patents, patent applications, supporting documents||Indefinitely|
|Real estate documents (including loan and mortgage contracts, deeds)||Indefinitely|
|Stock and bond records||Indefinitely|
|Trade mark registrations, evidence of use documents||Indefinitely|
|Warranties||Duration of warranty + 7 years|