Data Retention Policy

1. This policy covers all data that we hold or have control over where data subjects are located in the United Kingdom (‘data’). This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings and CCTV recordings. It applies to both personal data and non-personal data.  
2. This policy covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage. It also covers data that belongs to us but is held by employees on personal devices.  
3. This policy explains the differences between our formal or official records, disposable information, confidential information belonging to others, personal data and non-personal data. It also gives guidance on how we classify our data. 
4. This policy applies to all business units and functions of FAITHFULL in the United Kingdom. 

Through this policy, and our data retention practices, we aim to meet the following commitments:

• We comply with legal and regulatory requirements to retain data. 
• We comply with our data protection obligations, in particular to keep personal data no longer than is necessary for the purposes for which it is processed (storage limitation principle). 
• We handle, store and dispose of data responsibly and securely. 
• We create and retain data where we need this to operate our business effectively, but we do not create or retain data without good business reason. 
• We allocate appropriate resources, roles and responsibilities to data retention. 
• We regularly remind employees of their data retention responsibilities. 
• We regularly monitor and audit compliance with this policy and update this policy when required. 

1. Responsibility of all employees. We aim tocomply withthe laws, rules, and regulations that govern our organisation and with recognised compliance good practices. All employees mustcomply with:

• this policy;  
• the Record Retention Schedule; and 
• any communications suspending data disposal and any specific instructions from FAITHFULL. Failure to do so may subject us, our employees, and contractors to serious civil and/or criminal liability. An employee's failure to comply with this policy may result in disciplinary sanctions, including suspension or termination. It is therefore the responsibility of everyone to understand and comply with this policy. 

2. The Records Management Officer is responsible for identifying the data that we must or should retain, and determining, in collaboration with its professional advisers, the proper period of retention. It also arranges for the proper storage and retrieval of data, co-ordinating with outside vendors where appropriate. Additionally, the Records Management Officer handles the destruction of records whose retention period has expired. 

3. We have designated Tiffany Lloyd as the Records Management Officer. The Records Management Officer is responsible for: 

• Administering the data management programme; 
• Helping department heads implement the data management programme and related best practices; 
• Planning, developing, and prescribing data disposal policies, systems, standards, and procedures; and 
• Providing guidance, training, monitoring and updating in relation to this policy. 

4. Data Protection Officer.Our Data Protection Officer (DPO)is responsible foradvising on andmonitoringour compliance with data protection laws which regulate personal data. Our DPO works with ourRecords Management Officeron the retention requirements for personal data and on monitoring compliance with this policy in relation to personal data.

1. Formal or official records. Certain data is more important to us and is therefore listed in the Record Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business. Please see paragraph 6.1 below for more information on retention periods for this type of data.  
2. Disposable information. 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 formal or official record as defined by this policy and the Record Retention Schedule. Examples may 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 FAITHFULL and retained primarily for reference purposes. 
• Spam and junk mail. 
• Please see paragraph 6.2 for more information on how to determine retention periods for this type of data. 

3. Personal data. Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (the principle of storage limitation) (see paragraph 6.3 for more information on this). 

4. Confidential information belonging to others. Any confidential information that an employee may have obtained from a source outside of FAITHFULL, such as a previous employer, must not, so long as such information remains confidential, be disclosed to or used by us. Unsolicited confidential information submitted to us should be refused, returned to the sender where possible, and deleted, if received via the internet.  

4. Data classifications. Some of our data is more confidential than other data. Our obligations with our customers and suppliers governs how each type of data should be marked and protected. If you want to understand more about the confidentiality of certain data, please speak to our Records Management Officer. 

1. Formal or official records. Any data that is part of any of the categories listed in the Record Retention Schedule contained in the Annex to this policy, must be retained for the amount of time indicated in the Record Retention Schedule. A record must not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or notice to preserve documents for contemplated litigation or other special situation) calls for its continued retention. If you are unsure whether to retain a certain record, or if you believe an exception should be made to allow a record to be retained for longer than the amount of time indicated in the Record Retention Schedule, contact the Records Management Officer. 
2. Disposable information. The Record Retention Schedule will not set out retention periods for disposable information. This type of data should only be retained as long as it is needed for business purposes. Once it no longer has any business purpose or value it should be securely disposed of, unless required to be retained pursuant to legal obligations. 
3. Personal data. As explained above, data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). Where data is listed in the Record Retention Schedule, we have taken into account the principle of storage limitation and balanced this against our requirements to retain the data. Where data is disposable information, you must take into account the principle of storage limitation when deciding whether to retain this data.  
4. What to do if data is not listed in the Record Retention Schedule. If data is not listed in the Record Retention Schedule, it is likely that it should be classed as disposable information. However, if you consider that there is an omission in the Record Retention Schedule, or if you are unsure, please contact the Records Management Officer. 

1. Storage. Our data must be stored in a safe, secure, and accessible manner. Any documents and financial files that are essential to our business operations during an emergency must be duplicated and/or backed up at least once per week and maintained off site. 
2. Destruction. Our Records Management Officer is responsible for the continuing process of identifying the data that has met its required retention period and supervising its destruction. The destruction of confidential, financial, and employee-related hard copy data must be conducted by shredding if possible. Non-confidential data may be destroyed by recycling. The destruction of electronic data must be co-ordinated with Records Management Officer. 
3. The destruction of data must stop immediately upon notification from the Records Management Officer that preservation of documents for contemplated litigation is required (sometimes referred to as a litigation hold). This is because we may be involved in a legal claim or an official investigation (see next paragraph). Destruction may begin again once Records Management Officer lifts the requirement for preservation. 

1. Preservation of documents for contemplated litigation and other special situations.We require all employees to comply fully with our Record Retention Schedule and procedures as provided in this policy. All employees should note the following general exception to any stated destruction schedule: 

• If you believe, or Records Management Officer informs you, that certain records are relevant to current litigation or contemplated litigation (that is, a dispute that could result in litigation), government investigation, audit, or other event, you must preserve and not delete, dispose, destroy, or change those records, including emails and other electronic documents, until the Records Management Officer determines those records are no longer needed.  
• Preserving documents includes suspending any requirements in the Record Retention Schedule and preserving the integrity of the electronic files or other format in which the records are kept.    

2. If you believe this exception may apply, or have any questions regarding whether it may apply, please contact the Records Management Officer. 

3. In addition, you may be asked to suspend any routine data disposal procedures in connection with certain other types of events, such as our merger with another organisation or the replacement of our information technology systems. 

1. Questions about the policy.Any questions about retention periods relevant to your functionor this policyshould be raised withthe Records Management Officer.

1. Reporting policy breaches. We are committed to enforcing this policy as it applies to all forms of data. The effectiveness of our efforts, however, depend largely on employees. If you feel that you or someone else may have breached this policy, you should report the incident immediately to your supervisor. If you are not comfortable bringing the matter up with your immediate supervisor, or do not believe the supervisor has dealt with the matter properly, you should raise the matter with the Records Management Officer. If employees do not report inappropriate conduct, we may not become aware of a possible breach of this policy and may not be able to take appropriate corrective action. 
2. No one will be subject to and we do not allow, any form of discipline, reprisal, intimidation, or retaliation for reporting incidents of inappropriate conduct of any kind, pursuing any record destruction claim, or co-operating in related investigations. 
3. Audits. Our Records Management Officer will periodically review this policy and its procedures (including where appropriate by taking outside legal or auditor advice to ensure we are in compliance with relevant new or amended laws, regulations or guidance. Additionally, we will regularly monitor compliance with this policy, including by carrying out audits. 

1. This policy supplements and should be read in conjunction with our other policies and procedures in force from time to time, including without limitation our:

• Data protection policy; and 
• other IT, security and data related policies, which are available on request. 

Contact Data: billing address, delivery address, email address and telephone numbers. 

Data: all data that we hold or have control over where data subjects are located in the UK and therefore to which this policy applies. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings and CCTV recordings. It applies to both personal data and non-personal data. In this policy we refer to this information and these records collectively as "data". 

Data Protection Officer: our Data Protection Officer who is responsible for advising on and monitoring compliance with data protection laws. 

Disposable information: 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 formal or official record as defined by this policy and the Record Retention Schedule. 

Financial Data: bank account and payment card details. 

Formal or official record: certain data is more important to us and is therefore listed in the Record Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business. We refer to this as formal or official records or data. 

Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender. 

Marketing and Communications Data includes customers’ preferences in receiving marketing from us and our third parties and customers’ communication preferences. 

Non-personal data: data which does not identify living individuals, either because it is not about living individuals (for example financial records) or because it has been fully anonymised. 

Personal data: any information identifying a living individual or information relating to a living individual that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. This includes special categories of personal data such as health data and pseudonymised personal data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.  

Profile Data: username and password, purchases or orders made by customers, customers’ interests, preferences, feedback and survey responses.   

Record Retention Schedule: the schedule attached to this policy which sets out retention periods for our formal or official records.  

Storage limitation principle: data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed. This is referred to in the UK GDPR and EU GDPR as the principle of storage limitation. 

Transaction Data: details about payments to and from you and other details of products and services you have purchased from us. 

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.  

Usage Data includes information about how customers interact with and use our website, products and services. 

FAITHFULL establishes retention or destruction schedules or procedures for specific categories of data. This is done to ensure legal compliance (for example with our data protection obligations) and accomplish other objectives, such as protecting intellectual property and controlling costs.  

Employees should comply with the retention periods listed in the record retention schedule below. 

If you hold data not listed below and consider your data should be listed or if you become aware of any changes that may affect the periods listed below or if you have any other questions about this record retention schedule, please contact the Retention Management Officer. 

The below retention schedule timeframes would be subject to extension pursuant to a litigation hold if the data was subject to a dispute.