Data Retention Policy

This policy and schedule has been put in place to ensure that personal data is only retained for as long as is necessary for the purpose for which it was given to the organisation.  The policy ensures respect for the data privacy of employees, contractors, suppliers, customers both current and past, and any other individuals who do not come under these groups but do, or have in the past, had dealings with the company.  The policy lessens the risk of a data breach and aims to prevent loss of personal data.

Employees are obliged to have a clear awareness of the data retention policy and, where they are responsible for relevant data, to implement the retention periods set out below.

Category of Personal Data

Elements of Personal Data

Retention Period

Recruitment related data

This may include; contact details, date of birth, curriculum vitae, work and educational history, referee names, interview notes, medical cert (fit for work, no medical data), related documentation

Freefoam Plastics retain documentation of an individual who has attended for interview for 18 months from the date the position is filled to allow for any complaints to come through the Workplace Relations Commission.

Terms and Conditions of Employment

This may include personal data contained in contracts of employment and all related documentation.

Freefoam Plastics retain all contractual and related documentation for the duration of employment and 8 years from the end of the year in with the termination or expiration of the contract took place.

Working Time Records

This will include details regarding weekly working hours, annual leave and public holidays, rest breaks, PPS numbers, statement of duties, name and address of each employee, copy of employment contract, copy of any notices about starting, finishing or break times given to an employee and notice of additional working hours.

The Organisation of Working Time Act 1997 and related Regulations (Ireland) provide that working time records must be retained for a minimum of 3 years.

 

Freefoam Plastics will retain this information as part of the personal data for 8 years from the termination or expiration of the contract.

Payslips, payroll and tax records

This will include earnings information, tax bands and tax information, PRSI, USC bands and other transactions carried out in payroll.  Also, retention of name, address, PPS number, Date of Birth and any pension information.

To comply with Revenue, HMRC and other tax requirements across all jurisdictions, all employee payroll and tax records will be retained for 8 years from the end of the financial year following termination, or to the end of any enquiry by the Revenue Commissioners or equivalent.

Employment Permit Records

These will include duration of employment, remuneration details, employment permit details, passport information.

These must be retained for a minimum of 5 years and so will be retained for 8 years following the end of the year in which the termination or expiration of the contract occurred.

Parental Leave Records, Force Majeure Records, Paternity Leave Records and Carers Leave Records

These may include details regarding commencement of leave, duration of leave, manner in which leave was taken, notices, employee signatures and other documentation relating to children such as birth certificates or passport required as proof of age or other information. 

The relevant legislation provides that these must be retained for 8 years. 

Records of employees under 18 years of age

This may include copies of birth certificates, written permissions from parent/guardian, name, date of birth, starting and finishing times or work, pay details.

Freefoam Plastics will retain this data for three years in compliance with The Protection of Young Persons (Employment) Act 1996 (Ireland).

Medical Records

These may include sick leave certificates, occupational health assessment and other records relating to sick leave

Freefoam Plastics will retain these records for 8 years following the termination or expiration of employment.  These will continue to be treated with utmost security and confidentiality.

Email and Internet Usage

This may include emails stored in an employee’s email inbox or email folders, and data relating to an employee’s browsing history.

This data is held indefinitely in the event that it is required by the company.  However, the access to this is extremely restricted and is only at the highest levels of the organisation. 

Supplier Information

This may include names, addresses and contact information, emails exchanged, credit record with the company, record of contact with Freefoam, bank account details and accounts documentation (invoices, statements, Purchase Order info, delivery notes, credit notes, etc.)

This data is held indefinitely while the business relationship is ongoing, and retained in the event that it is required by the company.  However, this is stored in our secure ERP system where access is restricted.

Customer Information

This may include names, addresses and contact information, emails exchanged, credit record with the company, record of contact with Freefoam, bank account details and accounts documentation (invoices, statements, Purchase Order info, delivery notes, credit notes, etc.)

This data is held indefinitely while the business relationship is ongoing and retained in the event that it is required by the company.  However, this is stored in our secure ERP system and our secure exchange system, where access is restricted.

Prospective Customer Information

This includes email addresses for those who sign up for product updates via our website, or request samples using our online request form.

This data is held indefinitely but only used for the purpose for which it was provided, i.e. to provide updates on products or to follow up with email and/or phone call to provide samples requested.

 

All retention periods set out above are subject to the data protection principles applicable to the personal data contained in the records.

Extension of Retention Periods

The retention periods set out above may be extended in exceptional circumstances including where records are required by the organisation to defend any legal claims taken against it or on receipt of appropriate advice.

Security of Data

Freefoam Plastics will take all reasonable steps to ensure that appropriate security measures are in place to protect the confidentiality of data being destroyed in line with this retention policy. 

All paper-based data is shredded on site prior to being disposed of.

All data based in computer files is deleted only by someone who has appropriate access levels and it is ensured that it is completely deleted, and no information can be accessed again.

All data based in our systems – HR Management System, ERP system and Payroll Systems is deleted within the system by a person with the appropriate access levels.  Once it is deleted it cannot be replaced.

Review of Policy

The Retention Policy will be reviewed from time to time to take into account changes in the law, and the experience of the policy in practice.  The first review of the retention policy will take place after two years of operation, unless circumstances occur in the interim that indicate a review is required sooner.

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