Stroud Valleys Credit Union Data Retention Policy

Membership Records

Required by

Retention Period

Register of Members Industrial & Provident Society Act (IPSA) Permanently

 

Rules and Amendments (as registered with the Financial Services Authority)

 

Industrial & Provident Society Act (IPSA) Permanently

 

Receipts for any securities held, securities register and register of contracts of guarantee.

 

Industrial & Provident Society Act (IPSA) Permanently

 

Minutes of annual and special general meetings and the meetings of the Board of Directors.

 

Industrial & Provident Society Act (IPSA) Permanently

 

Members’ Share and Loan Register Industrial & Provident Society Act (IPSA) Permanently

 

Copies of Annual Returns Regulator Permanently

 

Register of bad debts written off Regulator Permanently

 

Complaints Regulator (FCA – DISP 1.9.1)

Legal evidence

Complaint resolution + 3 years

Retaining these for 6 years would cover the limitation for legal action.

Financial Promotions Regulator (FCA – COBS 4.11 (3))

Legal evidence

3 Years after the end of promotion for promotions not involving pensions or life policies.

End of promotion + 6 years

Call recordings Regulator (FCA – COBS 11.8.10) 6 months

Anti Money Laundering

   
Evidence of identity, member transactions, reports of suspicious transactions (internal and external), and training provision Anti Money Laundering 5 years after member leaves
     

Accounting Records

   
All record appertaining to the accounts of the credit union including:

 

  • Receipts and invoices.
  • Ledgers and cash books (whether manual or electronic)
  • Payroll Information
  • VAT books and copies of returns
  • Corporation tax records

 

HMRC 6 Years after the date to which they refer
Loan Applications Recommended

Limitations Act 1980 (E & W)

Prescription & Limitation (Scotland) Act 1973

6 years after loan is repaid

5 years in Scotland

 

Financial implications of making a subordinated loan (to another credit union) Regulator (PRA – credit union rulebook 3.15) 5 years
Investment decisions Regulator (PRA – credit union rulebook 6.6) 5 years

Personnel

Senior Management Arrangements Systems and Controls Regulators 6 years after the Senior Manager has been superceded
Employer’s Liability Certificate HSW 40 years
Application forms/interview notes for unsuccessful candidates Guideline retention period in case of discrimination challenge

www.acas.org.uk

1 year
Disciplinary, working time and training, redundancy details Recommended

www.businesslink.gov.uk

6 years after employment ceases
Information pertinent to Regulatory References (see guide here under ‘records’) Regulators (PRA – Fitness and Propriety 5.5) 6 years except in cases of serious misconduct (indefinite)
Employee details and records Recommended

Limitations Act 1980 (E & W)

Prescription & Limitation (Scotland) Act 1973

6 years after employment ceases
Trade union agreements Recommended

www.businesslink.gov.uk

10 years after agreement ceases
Volunteer records No clear guidelines but the credit union should follow data protection requirement that data should not be kept longer than for the purpose for which it was taken.  
     

Health & Safety

   
Accident Reports HSW Act Three years after date of last entry. There are specific rules on recording incidents involving hazardous substances.
Health & Safety Consultations HSW Act Permanently

Records that may be routinely destroyed

   
Notices and acknowledgements of meetings and events.

Messages on post it notes and paper, message slips, duplicate documents such as CC and FYI copies, unaltered drafts, working papers not required to retain together with final official document, reference materials no longer required, superseded address lists or contribution lists.

   

11 May 2018