POLICY REGULATING THE RETENTION OF DOCUMENTATION IN INLINGUA
SCOPE
- This Policy is aimed at regulating the retention, maintenance and disposal of documentation, both personal and other, within Inlingua, as provided for in the Data Protection Legislation and General Data Protection Regulation (EU) 2016/679 (GDPR), and in accordance with the principles of data protection legislation, and other legal provisions in Maltese Law.
BACKGROUND
- The GDPR puts forward the principle that personal data and sensitive personal data should not be retained for periods that are longer than necessary. In this context, Inlingua will be putting forward a retention policy for all data and documentation that it collects and processes, with the purpose of ensuring compliance to the Regulation and to ensure that no resources are utilised in the processing and archiving of data which is no longer of relevance.
OBJECTIVES
- This policy aims to achieve the following objectives:
- Regulate the retention of and disposal of the various types of documentation whether held in manual or automated filing systems within Inlingua while adhering to the Data Protection principle that personal data should not be retained for a longer period than necessary;
- Dispose of unnecessary documentation that is no longer relevant and is taking up useful storage space;
- Promote the digitisation of documentation as may be reasonably possible in order to minimize the use of storage space required to store documentation, as well as to promote a sustainable use of paper and printing consumables.
ADMINISTRATION
- Documentation is held and recorded by Inlingua This Policy is therefore applicable to all such documentation. It will be the responsibility of the Data Controller who is the Head of School at inlingua School of Languages Malta to ensure that all provisions of this Policy are adhered to.
DOCUMENTATION HELD WITHIN INLINGUA
- As part of its operating requirements the Inlingua requests, keeps and maintains a wide range of documentation including personal data. The various types of documentation utilised by Inlingua may be categorised as follows:
- Employment Records
- Employment Application Form and CVs
- Enrolment Records and Enrolment Data
- Attendance Records
- Absence Records
- Yearly Leave Records
- Disciplinary Records and Admonishments
- Sick Leave records and Medical records
- Financial Documentation
- EU Funding applications
SECURITY OF DOCUMENTATION
- Documentation is maintained in an accessible but secure location with adequate access provided to officials who have the clearance level to access the relevant documentation. In the case of documents with sensitive personal data with higher clearance levels, access control protocols are fully adhered to, to ensure that only those that have the required security clearance have access to such documentation.
- In the case of personal data, the GDPR also stipulates that only those required to process personal data should have access to personal records.
- Personnel who are found to be in breach of these security protocols, and thus in breach of the GDPR, will be subject to disciplinary action.
MANUAL VS ELECTRONIC RECORDS
| Category | Manual/Electronic |
| Personal Information | |
| Employees Personal Files | Manual & Electronic |
| Application forms for enlistment, calls, positions etc | Electronic |
| Application Forms for the filling of positions co-financed from EU Funds | Electronic |
| Applications for training opportunities | Electronic |
| Training Courses provided | Manual & Electronic |
| Attendance and Absence Records | |
| Attendance Sheets | Manual & Electronic |
| Vacation Leave Application Forms | Manual & Electronic |
| Yearly Leave balances | Manual & Electronic |
| Disciplinary records | |
| Admonishments | Manual & Electronic |
| Disciplinary Charges | Manual & Electronic |
| Medical Records | |
| Sick Leave Certificates | Manual |
| Sick Leave Records | Manual & Electronic |
| Medical History | Manual |
| Medical Referrals | Manual |
| Financial Documentation | |
| Tax and National Insurance Records | Manual & Electronic |
| Procurement Records | Manual & Electronic |
| Accounting Records | Manual & Electronic |
| Inventory Records | Manual & Electronic |
| Yearly Financial Statements | Manual & Electronic |
| EU Programmes | |
| Documentation relating to projects utilising EU Funding | Manual & Electronic |
| EU Funding applications | Manual & Electronic |
RETENTION PERIOD
- Retention of different categories of documents is governed by different requirements and different legislation and regulations.
The following schedule outlines the retention requirements for the various categories of documentation within Inlingua.
| Category | Retention Period |
| Personal Information | |
| Employees Personal Files | 10 years |
| Application forms for enlistment, calls, positions etc | 10 years |
| Application Forms for the filling of positions co-financed from EU Funds | 10 years |
| Applications for training opportunities | 10 years |
| Training Courses provided | 10 years |
| Attendance and Absence Records | |
| Attendance Sheets | 10 years |
| Vacation Leave Application Forms | 10 years |
| Yearly Leave balances | 10 years |
| Disciplinary records | |
| Admonishments | 10 years |
| Disciplinary Charges | 10 years |
| Medical Records | |
| Sick Leave Certificates | 10 years |
| Sick Leave Records | 10 years |
| Medical History | 10 years |
| Medical Referrals | 10 years |
| Financial Documentation | |
| Tax and National Insurance Records | 10 years |
| Procurement Records | 10 years |
| Accounting Records | 10 years |
| Inventory Records | 10 years |
| Yearly Financial Statements | 10 years |
| EU Programmes | |
| Documentation relating to projects utilising EU Funding | 10 years |
| EU Funding applications | 10 years |
CONCLUSION
This retention policy aims to achieve a good working balance between the retention of useful and meaningful information in line with the provisions of the relevant legislation and the disposal of data which is no longer required and is being archived unnecessarily. Data that needs to be destroyed after the noted timeframes will be disposed of in an efficient manner to ensure that such information will no longer be available within Inlingua. Data Protection Controllers, Heads, and DPOs are aware of the noted retention periods and will instruct all relevant personnel to follow the indicated procedures accordingly.
It is to be noted that anonymised or statistical data do not fall within the parameters of this Retention Policy, since they do not constitute identifying personal data.