Collinge & Co Limited: Data Retention Policy

Introduction

This Policy sets out the obligations of Collinge & Co Limited, a company registered in England and Wales under registration number 01275240, whose registered address is 127 Telegraph Road, Heswall, Wirral CH60 0AF, United Kingdom (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”).

The UK 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 UK 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 UK 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 UK GDPR to protect that data).

In addition, the UK 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:
1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
2. When the data subject withdraws their consent;
3. When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
4. When the personal data is processed unlawfully (i.e. in breach of the UK GDPR and/or the DPA 2018);
5. When the personal data has to be erased to comply with a legal obligation; or
6. Where the personal data is processed for the provision of information to childrens’ protection services and authorities.
This Policy sets out the type(s) of personal data held by the Company for the purposes of operating Collinge & Co hairdressing salons, providing hairdressing training by Collinge & Co Training Limited and for the selling of products and services online, 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.

For further information on other aspects of data protection and compliance with the UK GDPR and the DPA 2018, please refer to the Company’s Data Protection Policy.
Aims and Objectives
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 the Company complies fully with its obligations and the rights of data subjects under the UK GDPR and the DPA 2018.
2. In addition to safeguarding the rights of data subjects under the UK GDPR and the DPA 2018, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.
Scope
1. This Policy applies to all personal data held by Collinge & Co Limited.
2. Personal data, as held by the Company is stored in the following ways and in the following locations:
  1. The Company’s servers, located in the Company’s training offices and head office in the UK;
  2. Third-party servers, operated by:
    1. Zenoti salon booking and POS software located in USA, EU and the UK;
    2. Shopify website hosting collingeandco.com located in the USA and EU;
    3. OneAdvanced, supplying PICS MIS (Management Information Software) for DWP (previously the DfE & ESFA) funding claims and BKSB for diagnostic software, located in the UK & EU;
    4. One File learner e-portfolio located in the UK;
    5. OneFlow contract signature and management software located in the EU;
    6. Microsoft 365 servers located in the UK;
    7. Klaviyo used for marketing campaigns located in the USA and EU;
    8. Google Workspace located in the EU (infrequent storage of Personal Data);
    9. Loop HR employee personal data located in the UK and EU;
    10. Notion employee and apprentice personal data located in the UK, EU and USA.
  3. Computers permanently located in the Company’s salon premises;
  4. Laptop computers provided by the Company to its employees;
  5. Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with the Company’s Remote Access and Mobile Device Policy;
  6. Physical records stored in the Company’s training offices and head office in the UK.
Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the UK GDPR and the DPA 2018, and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy.
1. Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used as set out in the Company’s Data Protection Policy, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).
2. Data subjects are given control over their personal data held by the Company 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 the Company’s use of their personal data, the right to data portability (for example, apprentices transferring to other training providers), and further rights relating to automated decision-making and profiling, as set out in the Company’s Data Protection Policy.
Technical and Organisational Data Security Measures
1. The following technical measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy for further details:
  1. All electronic copies of personal data should be stored securely using passwords and data encryption:
    1. Where data is stored on the company’s on-premise server the data will be encrypted by Windows Server standard encryption;
    2. Where data is stored on hosted or cloud servers we use suppliers that have SSL certificates for an encrypted connection and servers that use 256 bit encryption;
    3. Passwords used to access the company’s server are a minimum of 12 characters, with a mix of Upper-case, Lower-case, Numerals and Special characters;
    4. Users must follow the Strong Password Guidelines when accessing all other software and web apps.
  2. We avoid sending emails containing personal data or attachments including personal data. Internally documents including personal data are stored on an on-premise server and files can be shared by directing colleagues to the file path. If an email has to be sent that contains personal data, the personal data should be within a password protected file;
  3. It is not permitted to send an email that includes Personal Data in the body of the email;
  4. Personal data may only be transmitted over secure networks;
  5. Personal data may not be copied/transferred using USB drives;
  6. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
  7. Personal data may not be transmitted by facsimile transmission;
  8. Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using a Royal Mail Signed For service;
  9. When discussing details regarding Data Subjects with the company’s premises, employees should be sure that only relevant people are party to the Data Subject’s Personal Data and that Personal data is not shared informally to anyone that does not have a reason to hear;
  10. All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
  11. No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
  12. Personal data must be handled with care at all times and should not be left unattended or on view;
  13. Computers used to view personal data must always be locked (Win+L) before being left unattended;
  14. No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such devices belong to the Company or otherwise, without the formal written approval of both the Data Compliance Officer and Managing Director and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary
  15. No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the UK GDPR and the DPA 2018 (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
  16. It is permitted for company employees to access their business email (@collingeandco.com email addresses) from their phones as long as their email account is not used to transfer Personal or Company data.
  17. All personal data stored electronically should be backed up daily with backups stored onsite. All backups should be encrypted with 256 bit encryption;
  18. All electronic copies of personal data should be stored securely using passwords and encryption;
  19. All passwords used to protect personal data should not use words or phrases that can be easily guessed or otherwise compromised. All passwords should contain a combination of uppercase and lowercase letters, numbers, and symbols. Different passwords should be used to access different services and software. It is the company’s policy not to insist on periodically changing passwords but for individuals to use robust passwords that they can remember.
  20. Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
  21. All software should be kept up-to-date. Security-related updates should be installed promptly after becoming available;
  22. No software may be installed on any Company-owned computer or device without approval; and
  23. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Managing Director 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.
2. The following organisational measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy for further details:
  1. All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the UK GDPR and the DPA 2018, and under the Company’s Data Protection Policy;
  2. Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;
  3. All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
  4. All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised;
  5. All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
  6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
  7. The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
  8. All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the UK GDPR and the DPA 2018, and the Company’s Data Protection Policy;
  9. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the UK GDPR and the DPA 2018, and the Company’s Data Protection Policy;
  10. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under the UK GDPR and/or the DPA 2018 and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
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:
1. Personal data stored electronically (including any and all backups thereof) shall be deleted by the server operation system’s deletion function and immediate emptying of the Recycle bin;
2. Sensitive personal data stored electronically (including any and all backups thereof) shall be deleted by the server operation system’s deletion function and immediate emptying of the Recycle bin;
3. Personal data stored in hardcopy form shall be shredded onsite by an external company to BS EN15713:2009 standard and we receive a Certificate of Destruction. Locked offices, with locked Secure Shredding Cabinets store hardcopy data ready for collection.
4. Sensitive personal data stored in hardcopy form shall be shredded onsite by an external company to BS EN15713:2009 standard and we receive a Certificate of Destruction. Locked offices, with locked Secure Shredding Cabinets store hardcopy data ready for collection.
Data Retention
1. As stated above, and as required by law, the Company 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.
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.
3. When establishing and/or reviewing retention periods, the following shall be taken into account:
  1. The objectives and requirements of the Company;
  2. The type of personal data in question;
  3. The purpose(s) for which the data in question is collected, held, and processed;
  4. The Company’s legal basis for collecting, holding, and processing that data;
  5. The category or categories of data subject to whom the data relates;
  6. To meet the Department for Education (DfE) requirements, previously the Education & Skills Funding Agency (ESFA).
4. The data retention periods for different types of documents are stated in the “Document Retention Periods” Table, available to view for Collinge & Co employees only via the company’s online handbook.
5. 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.
6. Notwithstanding the Company’s 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 the Company to do so (whether in response to a request by a data subject or otherwise).
Roles and Responsibilities
Implementation of Policy

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