This policy includes:

• Introduction
• Aims and Objectives
• Scope
• Data Subject Rights and Data Integrity
• Technical and Organisational Data Security Measures
• Data Disposal
• Data Retention
• Roles and Responsibilities
• Implementation of Policy

Introduction

This Policy sets out the obligations Hanco has regarding retention of personal data collected, held, and processed by Hanco in accordance with current UK legislation and EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

a) Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);

b) When the data subject withdraws their consent;

c) When the data subject objects to the processing of their personal data and Hanco has no overriding legitimate interest;

d) When the personal data is processed unlawfully (i. in breach of the GDPR);

e) When the personal data must be erased to comply with a legal obligation; or

f) Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by Hanco for the purpose employment opportunities which are tailored to your circumstances and your interests AND client data to allow us to fulfill the most suited candidates for their requirements, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.

Aims and Objectives

2.1 The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that Hanco complies fully with its obligations and the rights of data subjects under the GDPR.

2.2 In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by Hanco, this Policy also aims to improve the speed and efficiency of managing data.

Scope

3.1 This Policy applies to all personal data held by Hanco, on Hanco servers, and contracted service providers;

3.2 Personal data, as held by Hanco stored in the following ways and in the following locations:

a) Hanco’s servers, located in Milton Keynes;

b) Third-party servers, operated by Microsoft, DigitalOcean and others located in the UK and the EU;

d) Mobile devices provided by Hanco to its employees

e) Physical records stored in a Secured location at Hanco Global Solutions head office based in Milton Keynes

Data Subject Rights and Data Integrity

All personal data held by Hanco is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in Hanco’s Data Protection Policy.

4.1 Data subjects are given control over their personal data held by Hanco including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict Hanco’s use of their personal data, the right to data portability, and further rights relating profiling, as set out in Parts 14 to 20 of Hanco’s Data Protection Policy.

Technical and Organisational Data Security Measures

5.1 The following technical measures are in place within Hanco to protect the security of personal data. Please refer to Parts 21 to 26 of Hanco’s Data Protection Policy for further details:

a) Personal data may only be transmitted over secure networks;

b) Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

j) Personal data must be handled with care at all times and should not be left unattended or on view;

k) Computers used to view personal data must always be locked before being left unattended;

n) All personal data stored electronically should be backed up daily with backups stored onsite and offsit All backups should be encrypted;

p) All passwords used to protect personal data should be changed regularly and should must be secure;

q) Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable m IT staff do not have access to passwords;

r) All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;

s) No software may be installed on any Hanco-owned computer or device without approval; and

t) Where personal data held by Hanco is used for marketing purposes, it shall be the responsibility of <> to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

5.2 The following organisational measures are in place within Hanco to protect the security of personal data. Please refer to Part 27 of Hanco’s Data Protection Policy for further details:

a) All employees and other parties working on behalf of Hanco shall be made fully aware of both their individual responsibilities and Hanco’s responsibilities under the GDPR and under Hanco’s Data Protection Policy;

b) Only employees and other parties working on behalf of Hanco that need access to, and use of, personal data in order to perform their work shall have access to personal data held by Hanco;

c) All employees and other parties working on behalf of Hanco handling personal data will be appropriately trained to do so;

d) All employees and other parties working on behalf of Hanco handling personal data will be appropriately supervised;

e) All employees and other parties working on behalf of Hanco handling personal data should exercise care and caution when discussing any work relating to personal data at all times;

f) Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

g) The performance of those employees and other parties working on behalf of Hanco handling personal data shall be regularly evaluated and reviewed;

h) All employees and other parties working on behalf of Hanco handling personal data will be bound by contract to comply with the GDPR and Hanco’s Data Protection Policy;

i) All agents, contractors, or other parties working on behalf of Hanco handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of Hanco arising out of the GDPR and Hanco’s Data Protection Policy;

j) Where any agent, contractor or other party working on behalf of Hanco handling personal data fails in their obligations under the GDPR and/or Hanco’s Data Protection Policy, that party shall indemnify and hold harmless Hanco against any costs, liability, damages, loss, claims or proceedings which may arise out of that fail

Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

6.1 Personal data stored electronically (including any and all backups thereof) shall be deleted securely using

6.2 Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely

6.3 Personal data stored in hardcopy form shall be shredded

6.4 Special category personal data stored in hardcopy form shall be cross shredded

Data Retention

7.1 As stated above, and as required by law, Hanco shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

7.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

7.3 When establishing and/or reviewing retention periods, the following shall be taken into account:

a) The objectives and requirements of Hanco;

b) The type of personal data in question;

c) The purpose(s) for which the data in question is collected, held, and processed;

d) Hanco’s legal basis for collecting, holding, and processing that data;

e) The category or categories of data subject to whom the data relates;

7.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

7.5 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within Hanco to do so (whether in response to a request by a data subject or otherwise).

7.6 In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.

 

Data Ref.	Type of Data	Purpose of Data	Review Period	Retention Period or Criteria	Comments
Candidate	Name Address Phone number Email CV	To contact, to evaluate skills, publish summaries and reports to potential employers, and to place in suitable job role	Reviewed 3 months before end of retention period or when candidate is put forward for an interview or contacted about new roles	72 Months	Personal data will be updated if the data subject is a suitable candidate for available roles and would like to be put forward for the role, we will confirm that the data we hold on them is up to date before they are put forward to the role. AND whichever comes sooner 3 months before the end of the retention period, we will contact the data subject to inform them that we still have their personal data and for them to confirm that the data we hold is still up to date.
Candidate Placed	Signed Contract Copy of Utility Bill Copy of Passport Working Visa (if required) Ltd Company Certificate Company Bank details Reviews	to confirm limited company status, proof of residency or has the correct visa to work in the country	On each new placement	72 months from start of employment	When any candidate is placed in permanent or contract role, prove is required that the candidate has the right to work in the country and we have their limited company details and company account information to allow our finance department to make required payments.
Client	Company Name Contact Name Job Role Phone Number Email Address	to fulfill placement opportunities within the business	Reviewed on each contact to client or with information found on the public domain	Indefinitely
Client PSL	Company Name Contact Name Job Role Phone Number Email Address Contracts	When a Preferred Supplier List (PSL) is agreed, contracts are signed and agreed, and contracts are saved securely on our internal servers	Reviewed as and when required	Indefinitely

Hanco also uses systems to purge support tickets and client records from the server within the specified timeframes outlined above.

Roles and Responsibilities

8.1 Hanco’s Data Protection Officer is Neil Westerby, at 151 Silbury Blvd., Milton Keynes MK9 1LH.

8.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, Hanco’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.

8.3 The Data Protection Officer and Directors, shall be directly responsible for ensuring compliance with the above data retention periods

8.4 Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Officer.

Implementation of Policy

This Policy shall be deemed effective as of 1 March 2020. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.