# Data Retention Schedule — Harbour Advisory Ltd (Draft) ## 1. Scope, Jurisdictions and Review Status Illustrative consultancy with 45 staff. Scope: client contracts, billing invoices, recruitment applications and support tickets; cloud and paper copies. Jurisdiction, applicable statutes, retention limits, processor terms and approved schedules were not provided. **Status: Draft for legal/privacy and business review; no disposal authorised.** No data-subject records are required for this exercise. ## 2. Record Inventory and Retention Schedule | ID | Class / purpose | Lawful basis status | Trigger | Period & evidence | Location / copy | Owner | Proposed disposition | Status | |---|---|---|---|---|---|---|---|---| | R01 | Client contracts / administer services and evidence terms | To be confirmed by privacy lead | Contract end; confirm amendments/claims | TBC; contract and applicable obligations to verify | Contract platform, shared drive, email, signed paper | Legal/commercial owner | Secure deletion or approved archive only after checks; log disposal | Open | | R02 | Customer invoices / account and reconcile charges | To be confirmed | Financial period close, subject to advice | TBC; finance adviser to verify accounting/tax rules | Finance app, exports, email, backups | Finance lead | Approved electronic deletion or paper shredding with log | Open | | R03 | Unsuccessful applicant files / recruitment decision and correspondence | To be confirmed | Final recruitment decision / appeal closure to verify | TBC; HR and privacy review needed | HR platform, recruiter mailbox, local downloads | HR lead | Configured deletion with confirmation and processor review | Open | | R04 | Support tickets / service delivery and issue analysis | To be confirmed | Ticket closure; reopen rules needed | TBC; contractual and privacy considerations to review | Helpdesk, attachments, exported CSVs | Service lead | Delete or anonymize after tested process; ticket audit log | Open | No retention period is asserted as law. The lawful-basis column is a decision queue, not a conclusion. ## 3. Duration Decision Notes Contracts: obtain contract clauses, claims/dispute guidance, governing jurisdiction and authoritative review. Invoices: obtain finance retention requirements and reporting-period trigger. Recruitment: identify unsuccessful/successful candidate differences, dispute risk and privacy notice. Tickets: differentiate operational incident records from tickets containing sensitive attachments. Cite the precise legal instrument or approved policy version *only after* verification. ## 4. Exceptions, Legal Holds and Access Safeguards Before any disposal run, check the legal hold register, live complaints, investigations, litigation and statutory preservation notices. A named authorized legal/privacy reviewer must release a hold. Access is limited by job role; preserve evidence of holds applied and released. ## 5. Disposal and Verification Controls IT must inventory master systems, email attachments, exports, physical files, third-party replicas and backups. Define per-platform deletion capabilities; where selective backup deletion is infeasible, document restricted access, scheduled overwrite/expiry and purge after restoration. Require signed destruction certificates for paper, system deletion logs for electronic items and exception handling where deletion fails. ## 6. Missing Evidence and Assumptions Register | ID | Gap | Risk | Evidence needed | Owner | Interim safeguard | |---|---|---|---|---|---| | G01 | Jurisdiction and regulatory duties unknown | Incorrect or unlawful period | Country/state, sector, qualified citations | Privacy/legal | No bulk disposal | | G02 | Backups and exports unmapped | Orphaned retained copies | IT inventory, restore/expiry design | IT lead | Restrict exports | | G03 | No formal authority | Premature deletion | Delegation/approval policy | Governance lead | Manual approval gate | | G04 | Processing lawful bases undocumented | Unclear processing rationale | Record of processing/notice | Privacy lead | Review access and minimization | ## 7. Implementation Action Plan | Priority | Action | Owner | Timing | Evidence / completion criterion | |---|---|---|---|---| | High | Verify legal sources and proposed retention triggers by class | Privacy/legal with HR and finance | Before approval | Signed decision note linked to each R-ID | | High | Validate copies, backups, processors and deletion capability | IT | Before system configuration | Inventory and restore/purge test record | | High | Approve legal-hold override workflow | Governance/legal | Before first disposal | Approved hold register and sign-offs | | Medium | Pilot one low-risk category after approval | Record owner / IT | Following sign-off | Disposal log and error review | ## 8. Approval, Communication and Review Checklist Confirm record owners; verify source laws and version; approve one retention trigger and outcome per category; review contracts and vendors; configure safeguards; document legal hold override; publish staff guidance; train owners; set annual and regulatory-change review checkpoints. Record approver, signed date and schedule version before calling this effective. ## 9. Management Summary Four records classes have been mapped but **no binding retention durations have been established**. Highest priorities are confirmation of legal and contractual requirements, complete copy/backup mapping and controlled approval for any disposal. Until then, the table is a planning inventory, not a legal retention schedule. ## 10. Disclaimer This draft provides records-management planning support and does not certify compliance or authorize deletion. A qualified privacy/legal adviser and organizational approvers must verify all applicable periods and safeguards.