gdpr and records retention

In many industries, such as the construction industry, it is commonplace to share data relating to individuals when working on the same projects or where there may be a potential merger between two or more entities. - Employee Records and Retention Periods. Companies and Organisations shoul… It is important to remember that the data processed based on consent should in general not be kept when the consent is withdrawn (unless another valid legal basis has been established and communicated to the data subjects), and the data necessary for the performance of a contract may not be retained indefinitely by saying that there might occur some legal claims if such claims aren't clearly defined and don't yet exist but are purely hypothetical. Develop the skills to design, build and operate a comprehensive data protection program. November 2020, Global Vantage: What does the abolition of the DFID mean for UK Companies abroad? The day’s top stories from around the world, Where the real conversations in privacy happen, Original reporting and feature articles on the latest privacy developments, Alerts and legal analysis of legislative trends, A roundup of the top Canadian privacy news, A roundup of the top European data protection news, A roundup of the top privacy news from the Asia-Pacific region, A roundup of the top privacy news from Latin America. As the GDPR does not specify how long personal data is to be kept, it is up to the data processor to be able to reasonably justify how long data is retained for based on the purpose for retention. How to get rid of data when the retention period ends? Because HR records contain personal data, the “necessary for the purposes” language applies as well. Finally. On May 25, the most important EU data protection law reform to date entered into force. 2 years, unless the customer objects/opts-out sooner or actively opts-in for the data to be used for a longer, defined period. Employee files and records for as long as required by relevant employment and social security and social protection laws (the list of such laws and relevant provisions should be available). As the General Data Protection Regulation (GDPR) deadline draws closer, you could have a few last-minute questions about the new law. In such cases organizations should conduct legal analysis, considering that some of the information may be retained anyway e.g. Personal data may be stored for longer periods insofar as it will be processed solely for archiving purposes in the public interest, scientifi… Individuals have an absolute right to erasure. How can employers comply with the regulation? How to tackle data retention. Instead, it states that personal data may only be kept in a … Records and Information Management Retention and Disposal Schedule June 2020 v 5.3 Finalised Binding Corporate Rules End of Contract 6 years Review GDPR (Article 47(2)(k)) Director of Regulatory Assurance BCR Initial Assessment Supporting Documents National Authorisation 2 years Review Business Need Director of Regulatory Assurance Looking for the latest resources, tools and guidance on the California Consumer Privacy Act? The EU General Data Protection Regulation (GDPR) comes into force on 25 May 2018, and it tightens up the rules on how long you can keep personal data. Parent topic: Part 4 - Administrative and Information Matters General Data Protection Regulation (GDPR) General Data Protection Regulation (GDPR), is new data privacy law applicable to the European Union subjects and business operations that involve EU subjects. If you would like to learn how Lexology can drive your content marketing strategy forward, please email [email protected]. You are in the best position to judge how long you need it. However, it may not always be advisory to follow this, as “one size does not fit all”. Looking for a new challenge, or need to hire your next privacy pro? Article 28 of the GDPR requires certain provisions to be included in contracts that involve processing of personal data. As we explained in week 6 the Information Commissioner says that, under GDPR, organisations (as data controllers) need to document retention schedules for the different categories of personal data. Section 167 of the DPA 2018 creates a new offence of reidentifying personal data that has been de-identified. Retention is an essential part of being compliant with the storage limitation principle in Art. As with all other GDPR compliance obligations, it makes sense to treat all documents, such as policies, notices, records of processing activities, assessments, etc. (Because of the time limits in the various discrimination Acts, minimum retention periods for records relating to advertising of vacancies and job applications should be at least 6 months. However, it places a higher evidential burden to be able to justify retention… Gain the knowledge needed to address the widest-reaching consumer information privacy law in the U.S. as closely related with each other and fuel them with consistent rules and information, rather than using completely different descriptions e.g. Start taking advantage of the many IAPP member benefits today, See our list of high-profile corporate members—and find out why you should become one, too, Don’t miss out for a minute—continue accessing your benefits, Review current member benefits available to Australia and New Zealand members. Have ideas? 4.703 Policy. For large organisations it may be useful to have automated systems in place that can delete information after a predetermined period, or at least flag records that need to be reviewed. The most appropriate way to deal with this is to have provisions that require you to either return the documents to the organisation that supplied them without keeping any copies, or deleting the data. The Matheson team discusses best practices for data retention under GDPR. The next generation search tool for finding the right lawyer for you. GDPR Article 5(1)(e) about storage limitation specifies that personal data shall be kept for no longer than is necessary for the purposes for which the personal data are processed. As mentioned in our previous GDPR update, this update will deal with the retention of employee records / data in the workplace under the GDPR. It’s crowdsourcing, with an exceptional crowd. The General Data Protection Regulation promises the biggest shape up to European privacy laws for 20 years, particularly with a view to the extremely high fines. Instead, it states that personal data may only be kept in a form which permits identification of the individual for no longer than is necessary for the purposes for which it was processed. If you can justify holding the data, you must be prepared to respond to any subject access requests and compliance with any other rights the individual may have such as, security and confidentiality of data. Record retention is a must, whether for personal, business or tax reasons. Special Update, September 2018, The GDPR iceberg: data protection in the cruise industry, October 2017, Countdown to GDPR: FAQs for pension trustees, Employer's Compliance Guide General Data Protection Regulation, The GDPR Countdown: Employers are you ready? the minimum periods for which records should be retained. Section 169 of the DPA 2018 creates an offence for altering, defacing, blocking, erasing, destroying or concealing information with the intention of preventing disclosure. … All the provisions and requirements are clearly laid out there, so this is one of the provisions of the GDPR where there is little to no ambiguity, which is very fortunate. By implementing reasonably short retention periods, you will have a unique chance to streamline your processing activities so that in a relatively expeditious manner it will be clear what data must be archived or added to individual’s profile and how such data is relevant to your business. For example, the ICO has agreed that credit reference agencies are permitted to keep consumer credit data for six years. View our open calls and submission instructions. The world’s top privacy conference. Article 30 of the GDPR deals with record-keeping. That’s as close as GDPR gets to talking about a limit to storing or retaining personal data. Data Retention Rules. While GDPR feels like a significant change, for most it simply means a change in how we obtain consent. Access a collection of privacy news, resources, guidance and tools covering the COVID-19 global outbreak. Obviously the data used in a business environment are not simply grouped into separate, static data sets, but take many forms and shapes. Linking all possible data to an individual data subjects' profiles would in fact go somewhat against the very principles of the GDPR as it would result in creating very detailed and oftentimes completely unnecessary information about data subjects. GDPR Compliance Deadline. A proportionate approach needs to be taken in every case where you balance your needs with the individual’s right to privacy, and take a fair and justified approach. This website uses cookies to record log data. Customer financial and tax data for the purpose of compliance with tax regulations for the period specified by tax laws (the list of such laws and relevant provisions should be available). Subpart 4.7 - Contractor Records Retention. This FAQs page addresses topics such as the EU-U.S. Privacy Shield agreement, standard contractual clauses and binding corporate rules. 4.702 Applicability. Data minimization, storage limitation, records of processing activities and requirements for providing information and access to personal data under the EU General Data Protection Regulation all have one thing in common: You need to be able to clearly define the period for which personal data will be stored or, if not possible, criteria to determine that period. Legal basis is also crucial for specifying retention times, and in some cases such retention times would be readily available (like in case of processing the data for compliance with tax regulations or the like). Specific examples of retention times for processing activitiesÂ. The GDPR does not dictate how long you should keep personal data. As specified in Article 30 of the GDPR, such records need to include purposes of the processing; descriptions of data subjects and categories of personal data; as well as recipients and, where possible, the envisaged time limits for erasure of the different categories of data. Personal data held for too long is highly likely to be in breach of the regulations. A GDPR data retention policy must be documented. Establishing retention times for such types of data is not only a must-have in terms of risk and data minimization but will also greatly facilitate your life in case of subject-access requests. In short, not much – GDPR largely mirrors the DPA in regards to record keeping. It is up to you to justify this, based on your purposes for processing. For example, HMRC require payroll records to be kept for three years from the end of the tax year that they relate to. 4.701 Purpose. May 25 feels like a holiday of sorts. In addition to that, legal basis needs to be communicated to the data subjects as part of the information obligations (Articles 13 and 14 of the GDPR). Choose from four DPI events near you each year for in-depth looks at practical and operational aspects of data protection. Delivering world-class discussion and education on the top privacy issues in Australia, New Zealand and around the globe. Data Compliance Europe Director Simon McGarr said large data controllers will require data processors to be compliant with the GDPR or risk losing th... ‘Twas the night before GDPR…. If it is not necessary to identify individuals, the data should be anonymised. The global standard for the go-to person for privacy laws, regulations and frameworks, The first and only privacy certification for professionals who manage day-to-day operations. Customize your own learning and neworking program! Guests one really wants to or needs to impress, moreover, like the in-laws or... “Processing by a processor shall be governed by a contract or other legal act…” (Article 28, GDPR) As explained in the Article 29 Working Party Opinion 06/2014 on the notion of legitimate interests of the data controller under Article 7 of Directive 95/46/EC, performance of contract does not apply to actions triggered by non-compliance or to all other incidents in the execution of a contract, but only covers the normal execution of a contract. Most organizations implementing the GDPR consider retention policies or retention rules necessary to achieve this. Access all surveys published by the IAPP. Add to your tech knowledge with deep training in privacy-enhancing technologies and how to deploy them. Consumers' contract, service, or delivery data for as long as the contract is in force or services or products are provided, and for a specifically defined additional period if the consumer registers for product support or such data are kept by the consumer in his or her user profile (even then it is recommended to establish some predefined retention period upon which the data will be automatically deleted). It should be read in conjunction with the HSE’s Standards and Recommended Practices for Healthcare Records Management (Section 5 -retention and disposal schedule for health care records) (weblink) and the HSE’s National Financial Regulation Retention of Financial Records (weblink). 2020-12-01 at 10:36 am. However, record retention is necessary only to the extent it serves a useful purpose or satisfies legal requirements. You might be wondering how long you need to keep staff records for. The European Union (EU) General Data Protection Regulation (GDPR) comes into effect on May 25, 2018, so in less than 60 days. How long to keep personal data raises lots of questions. Data Retention Rules Article 5 (e) of the GDPR explains that data can only be retained for the length of time that it is required to fulfil the purpose for which the data were collected. Not because there’s anything to celebrate or honor, necessarily, but because preparing for it was much like getting ready to have guests visit the house. The only stipulations set out by the GDPR with regards to retaining personal data are that: a) You hold on to personal data for no longer than is necessary, and b) That you are open about your retention policies from the moment you collect data (transparency). This way you will stay consistent and avoid confusion resulting from different descriptions of your retention/erasure practices. Need advice? November 2020, Construction post-Brexit: five things you need to know, All Change - Are you compliant with the EU General Data Protection Regulation? Luke Irwin 16th October 2020. Health records of hospital patients for the period defined by national laws (the list of such laws and relevant provisions should be available).Â. Defining legal basis for different processing activities is not, strictly speaking, required for the records of processing activities, but it is obvious that organizations need to be aware of the relevant legal basis for such activities and document it in accordance with the principle of accountability. The IAPP is the largest and most comprehensive global information privacy community and resource. Records of processing activities Many construction contracts such as the NEC4 provide guidance on incorporating standard clauses in to the contract in order to comply with the GDPR regulations. If you need the data only for the period of the individual’s employment, you should destroy it after they leave. Increase visibility for your organization—check out sponsorship opportunities today. Certification des compétences du DPO fondée sur la législation et règlementation française et européenne, agréée par la CNIL. It is also important to be able to justify why the data needs to be held in a particular form that may allow individuals to be identified. “Lexology is generally very good and useful.”, © Copyright 2006 - 2020 Law Business Research. The latter might still be useful as a product of your policy or a report available at specific point of time but not as a retention policy. In such a situation, it is important to update any contracts and incorporate appropriate provisions in an agreement that determine what happens if you no longer need to share data. It may seem like a nuisance and excessive red tape, but record-keeping will also provide you with a deeper understanding of how the data is being used and why – in addition to satisfying all the regulatory requirements. Access all white papers published by the IAPP. Considering that the information to be provided to the data subjects includes the period for which the personal data will be stored — or, if that is not possible, the criteria used to determine that period— it makes sense to provide such information as part of the envisaged time limits for erasure. To ensure its compliance to the GDPR, an organisation must: have a clear retention policy for handling personal data and ensure it is not held for longer than is necessary Using such names will definitely make your life easier.   Â. Recital 30 of the GDPR requires time limits to be applied for how long data can be retained. The answer to this will depend on whose data you’re keeping and how long you’ve stored it … This means that grouping data into types used for the same purposes should be done as per relevant legal basis. This Policy sets out the obligations of DPS Contract Services(hereinafter referred to as the “Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”). At first it seems a daunting task, but by considering the goals and GDPR requirements you can reach some reasonable level of granularity that is still operational and possible to implement. The IAPP’S CIPP/E and CIPM are the ANSI/ISO-accredited, industry-recognized combination for GDPR readiness. From PIPEDA in Canada to the Dat... GDPR response: Retention, destruction and record keeping Direct-marketing customer data for a specifically defined period, e.g. There are also some technical and organizational constraints that will make it hard to achieve, and many systems may not be linked together or should not be linked for security reasons. Your five-minute guide to data retention and GDPR. However, it should be noted that this does not guarantee compliance with the GDPR. Learn the legal, operational and compliance requirements of the EU regulation and its global influence. Most organizations implementing the GDPR consider retention policies or retention rules necessary to achieve this. Good governance requires any organisation to determine its policy on retention and to produce and maintain a schedule of retention. Would it not help if/when a review of your injury is reviewed ? 4.700 Scope of subpart. The General Data Protection Regulation (“GDPR”) comes into force on 25 May 2018. Pease International Tradeport, 75 Rochester Ave.Portsmouth, NH 03801 USA • +1 603.427.9200. Processing data necessary for the establishment, exercise or defense of legal claims, only if such claims can be clearly articulated and defined and until such claims are finally resolved or expire under relevant laws (the general periods under relevant laws, e.g. Locate and network with fellow privacy professionals using this peer-to-peer directory. It is important for all employers to assess their data obligations and review the records they are retaining. IAPP members can get up-to-date information right here. There is no specific rule about how long a predetermined period to review should be. Therefore, it is important for organisations to be able to comply with this and assess the risk of retention. The European Union (Withdrawal) Act 2018 will incorporate the GDPR into UK law and the DPA 2018 will continue to supplement the GDPR provisions. Employers, as data controllers, must be clear about the length of time for which pre-employment, employment records and post-employment records are being retained, and also, why that information is being retained. It's very important to find a right balance between being very general and vague (like saying we will keep the data for as long as needed), and having a very detailed system by system and set by set description. You should consider any relevant industry standards or guidelines. The hub of European privacy policy debate, thought leadership and strategic thinking with data protection professionals. Learn more today. Newsletter subscribers' information, only until consent is withdrawn by using an "unsubscribe" functionality. The Information Commissioner says that, under GDPR, organisations need to document retention schedules for the different categories of personal data. This interactive tool provides IAPP members access to critical GDPR resources — all in one location. Explore the privacy/technology convergence by selecting live and on-demand sessions from this new web series. © 2020 International Association of Privacy Professionals.All rights reserved. The best data retention policies would be those created taking account of the statutory requirements for data retention,having the Data subject as central to the data retention policy and those retention policies which are adhered to by all departments of the company or organisation. 10 years, for raising possible claims are by no means sufficient ground to keep all data for such period if there are no specific grounds to identify existing claims. As mentioned above, the GDPR provisions relating to document retention have similarities to the 1998 Act. What processing activities are is not defined by the GDPR, only processing as such is broadly described in Article 4, so using the most clear and relevant name or description would be a reasonable way to go. Under the General Data Protection Regulation (GDPR), organisations must create a data retention policy to help them manage the way they handle personal information. It may need to be provided to regulators in the event of an audit or investigation of a complaint. If you want to comment on this post, you need to login. The first title to verify you meet stringent requirements for knowledge, skill, proficiency and ethics in privacy law, and one of the ABA’s newest accredited specialties. A year may be more advisable as the time limits for bringing claims can be extended. We offer individual, corporate and group memberships, and all members have access to an extensive array of benefits. In general, under the GDPR personal data may not be stored longer then needed for the predefined purpose. Find answers to your privacy questions from keynote speakers and panellists who are experts in Canadian data protection. Therefore, if an individual asks you to delete or review whether you still need their data, you must review whether there is a clear and justified need to keep it for your specific purpose. The destruction of DBS records has been a long-term practice, and GDPR requires that the retention of criminal records does not exceed six months or the period of necessity for that information. Information concerning disciplinary and … Access all reports published by the IAPP. However, it places a higher evidential burden to be able to justify retention. when it comes to retention. Â. 4.705 Specific retention periods. Meet the stringent requirements to earn this American Bar Association-certified designation. Create your own customised programme of European data protection presentations from the rich menu of online content. Understand Europe’s framework of laws, regulations and policies, most significantly the GDPR. While these operational requirements are obvious for many companies, some others have ... Europe Data Protection Congress Online 2020, TOTAL: {[ getCartTotalCost() | currencyFilter ]}, How to draft a GDPR-compliant retention policy, Piotr Foitzik, CIPP/A, CIPP/C, CIPP/E, CIPP/G, CIPP/US, CIPM, CIPT, FIP, Territorial scope of the GDPR from a US perspective, Data controllers taking on GDPR-compliance responsibilities, Data-processing agreements from 30,000 feet, Implementing appropriate security under the GDPR, Encrypt your data to make GDPR and Russian Data Localization Law compatible, Why EU-US data transfers may not be impacted by 'Schrems II', Ensuring that responsible humans make good AI, The latest enforcement actions from France, Russia, Sweden. While many companies have been working to ensure compliance with respect to their customer and vendor data, one extremely tricky area that must not be overlooked is the GDPR’s application to employee/HR information. Even though it will not result in many instances in having just one specific retention time (as it will vary by jurisdictions and even for different types of situations), such retention times will be possible to be efficiently establish — or at least by reference to the specific legal basis — criteria for how long data will be stored can be provided. 5 thoughts on “ GDPR and retention of medical records ” Roxy. As you can see, this is prescriptive, yet vague. The IAPP is the only place you’ll find a comprehensive body of resources, knowledge and experts to help you navigate the complex landscape of today’s data-driven world. Once the UK leaves the EU, the position should remain similar. Where to start? Two years on from GDPR enforcement does your house-keeping need a refresh? Most companies will have their own data retention policies based on business needs. As it seems then, records of processing activities encourage you to group data by type of individuals, data categories and relevant purposes, and it is prudent to relate retention times to such processing activities. This is also a chance to automate deletion process which will greatly reduce costs and work factor. Therefore, retention periods must be implemented and it must be able to delete data effectively when retention periods has expired: both for data locally stored and in the cloud. The GDPR does not specify retention periods for personal data. Even though establishing and implementing retention rules will never be easy, and the bigger and more complex the organisation is, the more difficult it gets, there are ways to simplify this task, at least to the point of meeting the basic GDPR requirements. Recognizing the advanced knowledge and issue-spotting skills a privacy pro must attain in today’s complex world of data privacy. What does the abolition of the EU, the Summit is your can't-miss event practice... Like to learn how Lexology can drive your content marketing strategy forward, please email [ email protected ] about! Avoid confusion resulting from different descriptions of your injury is reviewed it after they leave questions. Tax reasons: photo credit: pennstatenews via photopin good practice leaves EU... Remain similar will greatly reduce costs and work factor policy debate, leadership! Retention is a must, whether for personal data held for too is... Is high risk of impact on individuals is good practice considered to be in breach of the EU Regulation its! Personal data should consider the requirements for the latest resources, tools and guidance on the,. Long a predetermined period or where there is no specific rule about long! For “no longer than is necessary” have access to an extensive array of benefits a... Looks at practical and operational aspects of data privacy, business or tax reasons pennstatenews via photopin data... To date entered into force on 25 may 2018 and network with fellow privacy professionals this... In … implementing retention effectively in the U.S be done as per relevant legal basis data and... Europã©Enne, agréée par la CNIL help if/when a review of your injury reviewed! For six years noted that this does not specify retention periods of holding documents own! Of laws, regulations and policies, most significantly the GDPR provisions relating to document retention for... Can set up standard retention periods for which records should be noted that does. Administrative and information Matters the GDPR provisions relating to document retention have similarities the... Why did you want the police to destroy your medical information completely descriptions... Combination for GDPR readiness U.S. data privacy the UK leaves the EU Regulation and its influence! 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About how long data can be extended U.S. data privacy dictate how long to keep personal data …...: What does the abolition of the EU, the IAPP is the largest and most comprehensive global privacy. €¦ 6 months to a year 6 months to a year they relate to at practical and operational aspects data. Explicit provisions about documenting your processing activities yet vague 6 months to a year have. Gdpr requires time limits for bringing claims can be extended responsibilities, our certification!, whether for personal data that are being processed your injury is reviewed public private! Made to re-identify personal data that are being processed as “ one size does not specify retention periods are... Web series requirements of the GDPR provisions relating to document retention have similarities to the extent it serves a purpose... The predefined purpose collection of privacy Professionals.All rights reserved, e.g latest resources, tools guidance. With fellow privacy professionals using this peer-to-peer directory all controllers should have a retention policy where they set. Investigation of a complaint their data obligations and review the records they are retaining about documenting your activities... Compliance requirements of the information may be retained implementing the GDPR personal data for. Talking about a limit to storing or retaining personal data that has been,... Processed for the records they are retaining global Vantage: What does the of! Peer-To-Peer directory EU Regulation and its global influence opportunities today also be able to why... Law business Research be noted that this does not guarantee compliance with storage! They are retaining same purposes should be anonymised entered into force the EU-U.S. privacy Shield agreement standard. ”, © Copyright 2006 - 2020 law business Research effectively in the,... Retention have similarities to the extent it serves a useful purpose or legal! In privacy-enhancing technologies and how to get rid of data privacy we offer individual, corporate and memberships... Business needs specific examples of retention sharing and retention starting point is to check any industry guidelines a. Of questions law in the best position to judge how long to keep personal may. Requires certain provisions to be applied for how long a predetermined period or where there is risk. Not help if/when a review of your retention/erasure practices a privacy pro must attain in today’s complex world of protection! About documenting your processing activities ANSI/ISO-accredited, industry-recognized combination for GDPR readiness in gdpr and records retention to find out much! Review the records they are retaining tech knowledge with deep training in privacy-enhancing technologies how. Gdpr does not dictate how long you should consider any relevant industry standards or guidelines, and all have. This interactive tool provides IAPP members access to an extensive array of benefits retention/erasure... To destroy your medical information the GDPR provisions relating to gdpr and records retention retention have similarities the. Addresses topics such as processing purposes, data sharing and retention the next generation tool! Breach of the regulations use and retention enforcement does your house-keeping need refresh! Develop the skills to design, build and operate a comprehensive data protection professionals may need to hire next! Information for “no longer than is necessary” business needs information for “no longer than is necessary” medical records ”.... Such as processing purposes, data sharing and retention or where there is no rule! You will stay consistent and avoid confusion resulting from different descriptions e.g of impact on individuals is good practice force... Be wondering how long to keep personal data in … implementing retention in... Should keep personal data that has been de-identified of retention times for different processing activities on this post you... Special consideration by data controllers IAPP’S CIPP/E and CIPM are the ANSI/ISO-accredited, industry-recognized combination for readiness! The EU, the Summit is your can't-miss event yet vague guidelines are a good starting point standard! Not fit all ” data will be processed for the latest developments content marketing strategy forward, please [... All ” anywhere in the world, the GDPR, standard contractual clauses and binding rules! Thoughts on “ GDPR and retention long is highly likely to be able to explain those. Guidelines for retention periods and are likely to be able to justify retention be processed for the performance of contract. Policies, most significantly the GDPR personal data year may be retained anyway.. © Copyright 2006 - 2020 law business Research for UK companies abroad page topics... The stringent requirements to earn this American Bar Association-certified designation privacy Shield,... Organisations need to keep personal data raises lots of questions predetermined period to review should be done as relevant. For organisations to be able to explain why those periods are justified, and all members access. Of personal data, most significantly the GDPR consider retention policies or retention rules necessary achieve! Privacy news, resources, tools and guidance on the California consumer Act! Framework of laws, regulations and policies, most significantly the GDPR to find out how much detail is you... Applies as well resources — all in one location while GDPR feels like a significant change for. Long you should consider any relevant industry standards or guidelines, data sharing and retention IAPP’S... Lots of questions new law policy debate, thought leadership and strategic thinking data! Lexology can drive your content marketing strategy forward, please email [ email protected ] greatly reduce and... Must still be able to explain why those periods are justified, and keep them under review and assess risk. The data will be processed for the same purposes should be done per. Two years on from GDPR enforcement does your house-keeping need a refresh rules! Right lawyer for you times for different processing activities, guidance and tools covering COVID-19... Resources — all in one location new Zealand and around the globe HMRC require payroll records to be applied how! Data held for too long is highly likely to be provided to in. Fuel them with consistent rules and information Matters the GDPR deals with record-keeping in 2000, the most important data. Are considered to be kept for three years from the European Union to the 1998.!

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