PML (PROGRAMME MANAGEMENT) LTD DATA RETENTION POLICY 2019

Data Retention Policy

The Company = PML Group and its subsidiaries (together PML Group)

1. Purpose
The purpose of this Policy is to ensure that necessary records and documents of The Company are adequately protected and maintained and to ensure that records that are no longer needed by The Company or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of The Company in understanding their obligations in retaining electronic documents – including e-mail, Web files, text files, sound and video files, PDF documents, and all Microsoft Office or other formatted files.
2. Policy
This Policy represents The Company’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.
3. Administration
The Company maintains a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of The Company and the retention and disposal of electronic documents. We will make modifications to the Record Retention Schedule from time to time to ensure that it follows National legislation and includes the appropriate document and record categories for The Company; monitor legislation affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.
In addition, any retained information can only be used for the purpose for which it is stored. This is compliant with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)
4. Suspension of Record Disposal In Event of Legal Proceedings or Claims
There are certain occasions when information needs to be preserved beyond any limits set out in the Policy. The Policy must be SUSPENDED relating to a specific customer or document and the information retained beyond the period specified in The Company’s Data Retention Schedule in the following circumstances:

Legal proceedings or a regulatory or similar investigation or obligation to produce information are known to be likely, threatened or actual.

A crime is suspected or detected.

Information is relevant to a company in liquidation or receivership, where a debt is due to The Company.

Information is considered by the owning unit to be of potential historical importance and this has been confirmed by the Administrator.

In the case of possible or actual legal proceedings, investigations or crimes occurring, the type of information that needs to be retained relates to any that will help or harm The Company or the other side’s case or liability or amount involved.

If there is any doubt over whether legal proceedings, an investigation or a crime could occur, or what information is relevant or material in these circumstances, the Administrator should be contacted and legal advice sought.

The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

5. Security of personal information
The Company will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
The Company will store all personal information on our secure (password- and firewall-protected) servers.
The Client should acknowledge that the transmission of information over the internet is inherently insecure, and that The Company cannot guarantee the security of data sent over the internet.
The Client will be responsible for keeping their Username and Password used for accessing The Company’s website confidential; The Company will not ask for password other than when needed to log in to our website.
6. Amendments
The Company may update this policy from time to time by publishing a new version.
This page should be checked occasionally to ensure that the policy remains relevant.
7. Applicability
This Policy applies to all physical records generated during The Company’s operation, including both original documents and reproductions. It also applies to the electronic documents described above.

This Policy was approved by the Board of Directors of The Company on 5th January 2018.

Signed by: Kim Newman, Managing Director of PML Group

(Original signed document held on file – This is available on request. A version of this statement is also available on the company K:Drive)