# STRUCTURED DILIGENCE ISSUE REGISTER **Input Sufficiency:** Sufficient for preliminary issue structuring. The supplied materials support three distinct documented retention requirements, but do **not** establish that the requirements apply to the same underlying employee-record categories. Accordingly, the findings are kept separate rather than consolidated. --- ### ISSUE 1 **ISSUE:** HR Data Retention Policy specifies a 7-year retention period for employee personnel records. **SOURCE:** Source 1 — HR Data Retention Policy, section addressing employee personnel records — 7-year retention period. **UNDERLYING FACT:** The supplied HR Data Retention Policy states a 7-year retention period for employee personnel records. **AFFECTED DOCUMENT:** HR personnel files. **EVIDENCE STATUS:** SUPPORTED **MISSING INFORMATION:** The specific categories, subcategories, or record types encompassed by the 7-year personnel-record retention period are not identified in the supplied material beyond the reference to employee personnel records. **REVIEWER OBSERVATION:** UNKNOWN **CONFIDENCE / UNCERTAINTY:** The 7-year period is documented in the supplied source. It is unclear whether the records subject to this period overlap with the employee-record categories addressed by the other supplied retention provisions. **FOLLOW-UP REQUIRED:** Confirm the specific employee-record categories covered by the 7-year retention provision and compare them with the categories addressed in Sources 2 and 3. --- ### ISSUE 2 **ISSUE:** Employee Privacy Notice describes employee personal-data retention as limited to the period necessary for the stated purpose or as otherwise required by applicable retention requirements. **SOURCE:** Source 2 — Employee Privacy Notice, section addressing employee personal data retention. **UNDERLYING FACT:** The supplied Employee Privacy Notice states that employee personal data is retained only for the period necessary for the stated purpose or as otherwise required by applicable retention requirements. **AFFECTED DOCUMENT:** Employee privacy documentation. **EVIDENCE STATUS:** SUPPORTED **MISSING INFORMATION:** The supplied material does not identify the specific employee personal-data categories, stated purposes, or external retention requirements to which the provision applies, nor does it establish how this provision corresponds to the 7-year or 3-year periods in Sources 1 and 3. **REVIEWER OBSERVATION:** UNKNOWN **CONFIDENCE / UNCERTAINTY:** The retention language is documented. Its relationship to the specific record-retention periods in the other sources is unclear from the supplied evidence. **FOLLOW-UP REQUIRED:** Identify the employee personal-data categories and applicable retention requirements contemplated by the Privacy Notice and compare their scope with Sources 1 and 3. --- ### ISSUE 3 **ISSUE:** HR Operations Procedure appears to specify a 3-year retention period for certain employee records. **SOURCE:** Source 3 — HR Operations Procedure, section addressing retention of employee records — 3-year period. **UNDERLYING FACT:** The supplied HR Operations Procedure appears to require retention of certain employee records for 3 years. **AFFECTED DOCUMENT:** HR operational records. **EVIDENCE STATUS:** SUPPORTED **MISSING INFORMATION:** The specific employee-record categories subject to the 3-year period are not identified in the supplied material. **REVIEWER OBSERVATION:** The reviewer notes that the 3-year requirement may concern different record categories from those covered by the 7-year requirement, but the current materials do not establish whether the underlying records are the same. **CONFIDENCE / UNCERTAINTY:** The existence of a 3-year retention provision is supported by the supplied source. The scope of the provision and its relationship to the other retention periods remain unclear. **FOLLOW-UP REQUIRED:** Confirm the specific record categories governed by the 3-year provision and determine whether they overlap with the records subject to Sources 1 and 2. --- ### REGISTER-LEVEL NORMALIZATION FINDING The supplied materials indicate **three retention-related requirements**, but they do not provide enough evidence to establish that they govern the same underlying records. The appropriate current classification is therefore **POSSIBLY RELATED — INSUFFICIENT BASIS**, rather than SAME UNDERLYING ISSUE. No legal compliance conclusion or resolution of the apparent retention-period difference is established by the supplied evidence.