Hi Madi,

Agreed. We are rethinking that at the moment, and your input may help me with this too. So thank you.

Neil.

From: Madeleine McAllister [mailto:[log in to unmask]]
Sent: 04 January 2017 16:45
To: Gow Neil <[log in to unmask]>; [log in to unmask]
Subject: RE: HR Systems and Data Protection

Hi Neil

Just to add confusion – I wouldn’t link pensions records to HR records i.e. you should still be destroying the HR records whether or not the person is in your pension scheme, as they should have an entirely separate pensions record.

However, they should be linked to safeguarding – you can keep certain HR records for date of termination to age of retirement under certain conditions linked to safeguarding, particularly social worker records.

Regards

Madi

Madi McAllister

Information Governance & Records Management Officer

London Borough of Merton

Tel: x 4180

From: The Information and Records Management Society mailing list [mailto:[log in to unmask]] On Behalf Of Neil Gow
Sent: 04 January 2017 16:39
To: [log in to unmask]
Subject: Re: HR Systems and Data Protection

Hi David,

Pages 22-24 of the Iron Mountain/Bristows Document Retention Guide United Kingdom October 2014 edition give you good reason to apply the six years rule, as it quotes recommendations of the Information Commissioner. I have this URL for the document: http://www.ironmountain.co.uk/Knowledge-Center/Reference-Library/View-by-Document-Type/Best-Practices/D/Document-Retention-Guide-United-Kingdom-2015.aspx?TempAuth=True – although I wasn’t able to access it at this location just now and not sure if it’s a local configuration problem or the link is broken.

We apply the six years rule here (but adjusted for those in final salary pensions schemes) and in theory at least it is applied equally to paper and electronic records.

Neil.

Neil Gow

Head of Records Management, UK Ireland and Germany

Global Site Facilities

UCB

208 Bath Road, Slough

SL1 3WE, U.K

Tel. +44 1753 447867

Mobile: +44 7841 959041

From: The Information and Records Management Society mailing list [mailto:[log in to unmask]] On Behalf Of David Reeve
Sent: 04 January 2017 16:03
To: [log in to unmask]
Subject: HR Systems and Data Protection

Hi all

I am part of a team procuring a new HR System for our company and I am surprised (actually I am not surprised) that few of the products (that we are looking at) have an easy means of deleting records such as leaver records etc. In fact I have been challenged to why we would want to delete personal sensitive data about our former employees. I was interested to gauge your views and interested (desperate?) to hear from any of you that have been involved in HR systems and have retention processes in place. In the days of paper and paper stores it was relatively easy to hold leaver files for 6 years and then delete.

To me the Data Protection Act is clear:

Principle 7: retain personal data no longer than is necessary for the specified purpose

Principle 5: Keep personal data accurate and up to date (difficult to justify keeping personal data locked up in HR systems indefinitely?)

It would be good to get some views.

Thanks

David

Dr David Reeve

Head of Information Strategy

One Castlepark, Tower Hill, Bristol BS2 0JA

Mobile: 07776858434

Email: [log in to unmask]

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