Background
In the course of its business as a firm of patent attorneys Secerna creates and stores a limited range of recorded personal information relating to various individuals. Certain records need to be retained to enable Secerna to successfully function as a business.
The purpose of this policy is to set out Secerna’s approved document retention periods which will assist Secerna in:
- meeting its obligations to employees, clients and suppliers;
- complying with the provisions of the General Data Protection Regulation 2018 (GDPR) by ensuring that data is retained only for as long as is justifiably necessary; and
- reducing burdens on space and storage.
A copy of this policy is available on our website and will be periodically reviewed and updated as necessary.
Charlotte Watkins is the partner responsible for ensuring that his policy is adhered to by all employees of Secerna responsible for processing data.
Approved Data Retention Periods
Secerna’s data retention periods (as approved by the Partners of Secerna) are set out below:
Data Source: Non-successful job applicants
Type of Data Held
CVs and covering letters (including name, address, telephone number, e-mail address, education details, job history), interview notes and answers to interview questions (including reference details), all correspondence passing between Secerna and applicant or recruitment agent
Retention Period
1 calendar year from the 31 December of the year the application was received
Reason for Retention
- To avoid responding to duplicate applications.
- In case of appeals against recruitment process.
- Needs of business change and need to recruit further for the same position.
- In a competitive job market candidates apply before they are able to start employment. Often we need to be able to revert back to applicants closer to their available start date.
Data Source: Employees (current and former)
Type of Data Held
All personal information and financial information required for employment and payroll purposes
Retention Period
Length of employment + 7 years
Reason for Retention
- In case of financial requests from HMRC.
- In case of any future financial disputes (PAYE/NI etc).
- In case of any employment issues such as dismissal/redundancy etc.
- In case of future reference requests.
- To meet subject access request requirements.
Data Source: Clients
Type of Data Held
Name, address, e-mail address, telephone number, bank details
Retention Period
7 calendar years from the 1 June of the year the last invoice issued by Secerna
Reason for Retention
- In case of a dispute over professional standards.
- Length of patent/design terms.
- In case of dispute over payment.
Data Source: Inventors
Type of Data Held
Name, address, job title, telephone number, e-mail address, nationality
Retention Period
3 years from expiry of the last associated patent/design family
Reason for Retention
- In case of patent/design litigation.
- Commercial reasons due to length of patent/design terms.
Data Source: Suppliers and consultants
Type of Data Held
Name, address, e-mail address, telephone number, bank details
Retention Period
7 calendar years from the 1 June of the year the last invoice issued to Secerna
Reason for Retention
- In case of dispute over professional service.
- In case of dispute over payment.
Monitoring and Execution
All dates will be entered in a secure online diary system to appear on an annual basis with a weekly reminder starting 1 month prior to the relevant date. All relevant matters will be checked and data permanently deleted in line with the above dates.
If data has been sent to a third party, we will contact them to request permanent deletion of all relevant data and seek written confirmation that this has been done in line with our request.
Charlotte Watkins will sign off each 6-month period once satisfied that all data has successfully and permanently been deleted.
Format of Documents
Secerna processes documents in the following formats:
Physical documents i.e. hard copies of documents stored in filing cabinets.
Electronic documents i.e. word processed documents and digital documents stored electronically.
Examples of the types of documents we store physically and electronically are as follows:
- Client files;
- Financial accounts;
- Company brochures;
- Invoices (Secerna and third party);
- Photographs for marketing purposes;
- Contact list (including name, address, e-mail address and telephone number of all contacts);
- Employee records.
Disposal
Upon expiration of the above dates (unless in the case of an undisputed right to be forgotten request where data will be immediately destroyed), all manual personal information relating to individuals will be confidentially shredded and electronic records will be securely deleted.