Retention Policy
Aug 27, 2025 8:36 AM
Educated Recruitment Ltd is a member of the Recruitment and Employment Confederation (REC) and adheres to their Code of Professional Practice.
Retention Policy
1Introduction
1.1This policy sets out how long employment/recruitment-related information will normally be held by us and when that information will be confidentially destroyed.
2Responsibility
2.1Our admin team are responsible for implementing and monitoring compliance with this policy.
2.2They will undertake an annual review of this policy to verify that it is in effective operation.
3Our process
3.1Information (hard copy and electronic) will be retained for the period specified in our Records Retention Schedule.
3.2All information must be reviewed before destruction to determine whether there are special factors that mean destruction should be delayed, such as potential litigation, complaints or grievances.
3.3Hard copy and electronically-held documents and information must be deleted at the end of the retention period, unless there is a requirement to delay deletion (as per paragraph 3.2)
3.4Hard copy documents and information must be disposed of by shredding and removal services.
Records Retention Schedule
This Record Retention Schedule sets out the time periods that different types of records must be retained for business and legal purposes.
The retention periods are based on business needs and legal requirements and should be read in accordance with Educated Recruitment Ltd Privacy policy. If you maintain any types of records that are not listed in this schedule and it is not clear what retention period should apply, please contact our admin team for guidance.
Any deviation from the retention periods in this schedule must be approved in advance by the Office Manager.
The first section of this policy will address employment records and the second section will address work-seeker records.
- Internal employee/applicants for internal roles
Record | Retention Period | Storage Format | Lawful basis and reference |
Rejected job applicant records, including: Contact details CV/Applications References Test results Interview notes | Six months after applicant is notified of rejection. The application forms should give applicants the opportunity to object to their details being retained. | Paper or electronic | Legitimate business interest To ensure that you do not accept multiple applications from the same rejected candidate To consider alternative roles for the candidate To demonstrate fair and non-discriminatory recruitment process Kept in line with the Equality Act 2010 (s.123) |
Application records of successful candidates, including: CV/Applications References Training certificates Correspondence concerning employment Test result Interview notes | Up to 5 years after employment ceases. | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract oKept in line with the Limitation Act 1980 (s.5) To demonstrate compliance with a fair and non-discriminatory recruitment process |
Employment contracts including: Training records Written particulars of employment Changes to terms and conditions | Up to 5 years after employment ceases. | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract oKept in line with the Limitation Act 1980 (s.5) Confirmation of rights and obligations owed and due by employee- employer |
Employee performance and conduct records: Probationary reviews Review and appraisal notes Promotions/demotions | Up to seven years after employment ceases | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract oKept in line with the Limitation Act 1980 (s.5) Confirmation of rights and obligations owed and due by employee- employer |
Other employment records Redundancy records Annual leave records Parental leave records Sickness records Return to work meetings | Up to 5 years after employment ceases | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract oKept in line with the Limitation Act 1980 (s.5) Confirmation of rights and obligations owed and due by employee- employer |
Directors’ service contracts and any variations | Up to 5 years after employment ceases | Paper or electronic | Legitimate business interest To protect the business against any legal claims for breach of contract Confirmation of rights and obligations owed and due by employee- employer Legal obligation Retained for one year from the date of termination or expiry Kept in line with Companies Act 2006 (s.228) |
Copies of identification documents/right to work | Kept for two years from date of termination of employment | Paper or electronic | Legal obligation Kept in line with the Immigration (Restrictions on Employment) Order (Art 6(1)(b)) |
Records relating to/demonstrating compliance with Working Time Regulations 1998: Registration of work and rest periods Working time opt-out forms | Kept for two years from the date on which the record was made | Paper or electronic | Legal obligation Kept in line with the Working Time Regulations 1998 (Regulation 9) |
Criminal records information Information forms DBS check forms DBS certificates | Kept for up to 6 months following the end of employment. | Paper or electronic | Legitimate business interest To demonstrate that safeguarding processes were followed In line with legislation of Keeping Children Safe in Education |
Gender pay gap reporting information | Kept available for a period of at least three years beginning with the date of publication | Paper or electronic | Legal obligation Kept in line with Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (Regulation 15) |
- Work-seeker records
Record | Retention Period | Storage Format | Lawful basis and reference |
Work-seeker records Name/address and if under 22, date of birth Any terms between recruitment business and the work-seeker and any variations Details of the work-seeker’s training, experience, qualifications and any authorisation to undertake particular work Names of hirers to whom the work-seeker is introduced or supplied Details of any resulting engagement and date from which it takes effect Details of any enquiries made under Regulations 19, 20 and 22 about the work-seeker and the position concerned | Kept for up to 5 years once employment has ceased, unless otherwise requested by the work seeker | Paper or electronic | Legal obligation Kept in line with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Reg 29) Legitimate business interest To protect the business against any legal claims for breach of contract oKept in line with the Limitation Act 1980 (s.5) To keep records to demonstrate that safeguarding processes are adhered to and followed To contact the candidate for any further work-finding services To protect your business against any legal claims |
Records relating to/demonstrating compliance with Working Time Regulations 1998: Registration of work and rest periods Working time opt-out forms | Kept for two years from the date on which the record was made | Paper or electronic | Legal obligation Kept in line with the Working Time Regulations 1998 (Reg 9) |
Copies of identification documents/right to work | Kept for two years from date of termination of employment | Paper or electronic | Legal obligation Kept in line with the Immigration (Restrictions on Employment) Order (Art 6(1)(b)) |
Criminal records information Information forms DBS check forms DBS certificates | Kept for one year after you last provided your work-finding service (unless safeguarding issues or other similar extenuating circumstances are raised) | Paper or electronic | Legal obligation Kept in line with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Reg 29) Legitimate business interest To demonstrate that safeguarding processes were followed |
Gender pay gap reporting information | Kept available for a period of at least three years beginning with the date of publication | Paper or electronic | Legal obligation Kept in line with Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (Regulation 15) |
- Payroll and salary records
Please find below People Group Services Data Retention Policy – as our payroll agency, we follow the below guidelines for Payroll & Salary Records in line with People Group Services.
Data Retention Policy
Data Subject = Employee/Worker
Where you have been paid through People PAYE we must hold this personal data for six full tax years following the end of the last tax year in which you were paid, in order to comply with HMRC and pension record keeping requirements.
Personal Data we are likely to hold:
- Name, DOB, NI number, address, telephone numbers, email address, next of kin
- Banking details
- Right to work and identity documents such as copy passports, visa, etc
- Qualification documents such as DBS checks, academic certificates, driving licence
- Payroll details such as amounts paid, tax and NI, pension and student loan deductions
- Telephone conversations and notes made from those
From 25th May 2018 onwards we will follow the data retention rules set out below:
- A)If we receive personal data from a third party to whom the Data Subject provided it (e.g. a recruitment agency) but we have not processed a placement or payments for the Data Subject and the Data Subject has not accepted our privacy notice, we will retain this personal data for a period of one month, at the end of which period it will be automatically deleted from our systems.
- B)If a Data Subject has personally provided us with their personal data, but they have not accepted our privacy notice and we have not processed a placement or payment for them, we will retain their personal data for a period of six months, at the end of which period it will automatically be deleted from our systems. Data Subjects can request deletion of all of their data at an earlier stage.
- C)If a Data Subject has provided us with their personal data and have accepted our privacy notice, but we have not processed a placement or payment(s) for the Data Subject, we will retain their personal data for a period of 12 months, at the end of which period it will be automatically deleted from our systems. Data Subjects can request deletion of all of their data at an earlier stage.
- D)If we have processed a placement or payment(s) for a Data Subject we will retain their personal data for a period of six complete tax years following the end of the tax year in which the last payment was made, at the end of this period it will be automatically deleted from our systems.
- E)All recorded telephone conversations will be automatically deleted after 2 years.
Data Subjects of People Group Services can request the earlier removal of their data by sending an email to:
Data Subjects of People Group Services can request the correction of any of their data by sending an email to:
Data Subjects of People Group Services can request a copy of their data by sending an email to:
For any contact regarding the Data Retention of Educated Recruitment Ltd candidates, please contact our admin team:
admin@educatedrecruitment.co.uk
01626 201 481
Policies
- Website Terms & Conditions
- Recruitment, Selection & Vetting Policy
- Equal Opportunities & Diversity Policy
- Recruitment of Ex-Offenders Policy
- Whistleblowing Policy
- Retention Policy
- Complaints Policy & Procedure
- Compliance Statement
- Customer Service Policy
- Safeguarding Child Protection Policy
- Privacy Notice Policy
- Modern Slavery Policy