Discover SailGPRetention Policy

SAILGP

Document Retention Strategy & Policy

F50 League LLC ("F50") is committed to protecting and respecting your privacy. F50 is a Delaware Company with its registered office at Corporation Trust Center, Orange Street, Wilmington, Delaware 19802.

In the large majority of circumstances, the data controller is likely to be F50 as a consequence of the centralised data management arrangement operated throughout the F50 Group. Within this policy, references to "SailGP" shall be deemed to mean the F50 Group (whether separately or altogether), F50 and its subsidiaries, as well as any holding company of F50 and its subsidiaries as appropriate. If you have any questions regarding this Policy you should contact F50 in the first instance via enquiries@sailgp.com or to the following address:

The Data Protection Officer
SailGP
191 Wood Lane
London
W12 7FP

Introduction

  1. Information and data is one of SailGP’s key corporate assets. In the course of carrying out its’ various functions, SailGP accumulates information from both individuals and external organisations. SailGP also generates a wide range of data, which is recorded in documents and records. SailGP strives to maintain data in accordance with the Act.

  2. These documents and records are in several different formats, examples of which include, (but are not limited to) communications such as emails, press releases and information relating to the series, events, teams, our commercial partners and sponsors, tickets and broadcasting of the Series.

  3. For the purposes of this Policy, the terms ‘document’, ‘data’ and ‘records’ include information in both hard copy and electronic form.

  4. In certain circumstances, it will be necessary to retain specific documents in order to fulfil statutory or regulatory requirements and also to meet justifiable operational needs. Document retention may also be useful to evidence events or agreements in the case of disputes, and also to preserve information which has historic value. SailGP has developed this Policy with the intention of benefitting SailGP and the data subjects to strike a careful balance between legal obligations, operational efficiency and retention of data for periods which are reasonable and appropriate in the circumstances.

  5. SailGP will retain some data and forms of information for longer than others. In line with principle 5 of the Act, information is not sought to be kept longer than is necessary.

  6. The retention of all documents and records is impractical and appropriate disposal forms an important aspect of this Policy. Disposal will assist SailGP to maintain sufficient electronic and office storage space and will de-clutter office accommodation. SailGP operates a “paper light” approach to hard copy documents with the large majority of records being retained electronically rather than as hard copies where possible.

SailGP’s Policy schedule is a tool used to ensure the retention of business information, personal data and sensitive personal data for as long as it is needed and justified in accordance with our balanced approach referred to in paragraph 4 above. SailGP is keen to be transparent and proactive to proactively provide data subjects with transparency on how data will be retained by SailGP and ultimately destroyed. This Document Retention Strategy should be read in combination with our Privacy Policy https://www.SailGP.com/privacy-policy. It takes account of the context within which SailGP operates, including the legal and regulatory environment, for example compliance with the fifth data protection principle, the expectations of stakeholders and SailGP’s ongoing legal obligations. It is intended primarily as a resource to inform you about how data is held, processed, archived and destroyed to enable disposal activity to be carried out in a consistent and controlled manner.

A table containing the intended retention period is given for each relevant data category. The retention period applies to all records in that category default, and will be adhered to wherever possible, although it is recognised by SailGP that there may be exceptional circumstances which require documents to be kept for either shorter or longer periods. In addition, it should be noted that, in line with the Act and SailGP’s obligation to implement appropriate physical and technical security measures, the data and information held by SailGP electronically is regularly and periodically backed up. These back-up copies are maintained indefinitely and in accordance with SailGP’s Security Policy to ensure the consistency and stable framework upon which SailGP operates its business. On this basis these back-up copies are unaffected by the retention periods for each relevant data category which form part of this Policy. The data set which forms part of each backup copy will be unaffected by the retention periods and action taken in line with the retention periods as referred to below. Retention periods also apply to all formats of records, i.e. paper and electronic, unless specifically stated otherwise.

The primary factors that inform decisions on retention are:
• Business need.
• Services provided to our customers and fans.
• Provision of professional services such as global sports league.
• Our experience of when retention of information and data is likely to be beneficial to the data subject as relevant to the specific services they seek from SailGP, including staying up to date with SailGP’s operations.
• Legislative and regulatory requirements – for example compliance with the fifth data protection principle. Where relevant legislation is listed.
• Informed and express consent of the data subject.

In our experience, data subjects are often keen to consent to SailGP maintain data and information beyond the periods referred to as part of this Policy. The reason and justification for these extended periods of retention, by way of example, can include:
• Provision of extended record keeping services.
• Removing an administrative burden from data subjects.
• Enabling an ease of operation between SailGP and the data subject.
• Maintaining an ongoing business relationship, which may be limited to matters such as a data subject’s ongoing interest in SailGP including attendance at events operated on an annual basis.

It is therefore not unusual for data subjects to provide free and unambiguous consent to SailGP to retain data beyond the periods forming part of this Policy.

Data Retention Schedule - Summary

1. Purpose of this document
A vital part of SailGP’s Data Protection Policy and practice is for personal data to be retained for the appropriate period of time – neither too long nor too short. It is SailGP’s policy to retain all information only for as long as specified in the Data Retention Schedule and, in general, no longer than two years plus the current year. This document is a summary of the Data Retention Schedule, and gives an indication of the categories of personal data held by SailGP and the basis on which SailGP often retains data and information for longer than the two years stipulated in the Policy.

2. Current plus two-year rule
Personal data is not usually held for more than two years after it ceases to be current, unless there is a specific reason for doing so (see below for the specific categories requiring different retention periods). The definition of current will vary according to the personal data: for example, it will mean until a SailGP event has taken place, the completion of a SailGP season, or until a member of staff has ceased being employed by SailGP where it relates to staff.
The ‘current plus two years’ rule is a target period for retention. If there is no need to keep the personal data that long, then it may be disposed of securely before the two years’ time-limit. SailGP will aim to assess and update data held in accordance with this Policy on a quarterly basis which means the two-year plus current rule will ultimately be subject to this quarterly variance.

3. Exceptions to the two-year rule
This section gives a guide to the categories which have legislation determining the length of time for which personal data within that category should be retained. An indication is given to the main section of the Data Retention Schedule dealing with this category.

CategoryExamples & Retention period
Financial records• Tax information, cash book payments etc. Payroll data. Current year plus 6 years
Complaints• Correspondence with complainants, correspondence with a regulatory body such as the Information Commissioner’s Office. Current year plus 6 years
Contractual arrangements• Supplier agreements, Service level agreements. Legal contracts. Tender documentation. Life of contract plus 6 years
Governance papers• Articles, Instruments and company administration records. Agendas and minutes of meetings. Current year plus 6 years
Data Protection requests• Correspondence regarding Data Subject Access requests. Current year plus six years
Personnel records• Wide variety of specific retention limits – please see Schedule below. From 6 months to 75 years
Health and Safety records• Please refer to Health and Safety Officer. Retention Schedule Up to 50 years
Details relating to SailGP teams and its representatives• Financial information, personal data, audit information. Current year plus 6 years

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Given our experience of document and data retention, SailGP operates a Policy where usually data is firstly archived. Archived data can then either become live data on the basis of repeated operation or alternatively can lead to deletion of the data after the periods of retention forming part of this Policy.
Data which is archived is held on the following basis:
1. Once data has been archived this means it will not be actively used by SailGP. Unless the data becomes current and/or the data subject requests such data to become current.
2. Once data becomes current again the two year plus current year rule will be reapplied to such data.
3. Data which has been archived will generally remain archived for two years and then will be destroyed or anonymised.
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Data Retention periods (Detailed)

Data CategoryRecords Held (type of data)Retention Timescale yearsPurpose of RetentionAction Following RetentionLegal Basis/Relevant SailGP Policy
PayrollPayroll RecordsCurrent Tax Year + 6Legal ComplianceDestroyHMRC Policy
Time SheetsCurrent Year + 2Consistent with PolicyDestroyHR Policy
Salary DetailsCurrent Tax Year + 6Legal ComplianceDestroyHRMC Policy
Overtime RecordsDate of Termination + 3Consistent with PolicyDestroyHR Policy
P45Current Tax Year + 5Legal ComplianceDestroyTaxes Management Act 1970
P60 ListsPrevious Year + 2Consistent with PolicyDestroyHR Policy
FinanceAnnual AccountsPrevious Year +2+ ArchiveConsistent with PolicyPermanentFinance Policy
Monthly Financial StatementsCurrent Year + 2Consistent with PolicyDestroyFinance Policy
Internal Audit ReportsCurrent Financial Year + 2Consistent with PolicyDestroyFinance Policy
External Audit ReportsPrevious Year + 2 + ArchiveConsistent with PolicyPermanentFinance Policy
Tax DocumentationCurrent Financial Year + 5Legal ComplianceDestroyValue Added Tax Act 1994
VAT AdministrationCurrent Tax Year + 5Consistent with PolicyDestroyFinance Policy
Cheque ReconciliationsCreation until after Audit then 6Consistent with PolicyDestroyFinance Policy
Travel/Staff Expenses, etc.Current Year + 5Consistent with PolicyDestroyFinance Policy
BACS printsCurrent Financial Year + 3Consistent with PolicyDestroyFinance Policy
Legal CostsCurrent Financial Year + 5Consistent with PolicyDestroyFinance Policy
InvoicesCurrent Year + 5Consistent with PolicyDestroyFinance Policy
OrdersCurrent Year + 5Consistent with PolicyDestroyFinance Policy
Purchase RecordsCurrent Tax Year + 5Consistent with PolicyDestroyFinance Policy
Human ResourcesCurrent Staff DetailsRetain and check currencyLegal ComplianceRetainCIPD Recommendation
Former Staff DetailsDate of Termination + 6Legal ComplianceDestroyCIPD Recommendation
Staff Career Development ReviewsRetain for current staff. Former staff Termination + 2Consistent with PolicyRetain/DestroyHR Policy
Attendance RecordsDate of Termination + 4Consistent with PolicyDestroyHR Policy
Occupational Health ReportsDate of Termination + 4Consistent with PolicyDestroyHR Policy
Employee Counselling ReturnsDate of Termination + 4Consistent with PolicyDestroyHR Policy
Exit Interview FormsDate of Termination + 1Consistent with PolicyDestroyHR Policy
Employment Tribunal RecordsDate of Termination + 1Consistent with PolicyDestroyHR Policy
Personal and Domestic Leave RequestsDate of Termination + 2Consistent with PolicyDestroyHR Policy
Declaration of Outside EmploymentDate of Termination + 4Consistent with PolicyDestroyHR Policy
Holiday/Leave RegistersDate of Termination + 2Consistent with PolicyDestroyHR Policy
Pension DocumentsDate of Termination + 6Consistent with PolicyDestroyHR Policy
ReferencesDate of Termination + 3Consistent with PolicyDestroyHR Policy
Disclosure Certificates (clear)Record Receipt OnlyConsistent with PolicyDestroyHR Policy
Disciplinary RecordsDate of Termination + 1Consistent with PolicyDestroyHR Policy
Grievance RecordsDate of Termination + 1Consistent with PolicyDestroyHR Policy
Agency Worker CVActive + 1Consistent with PolicyDestroyHR Policy
Data held on HR SystemDate of Termination + 6Consistent with PolicyDestroyHR Policy
Maternity Leave RequestsCurrent Tax Year + 3Consistent with PolicyDestroyHR Policy
Flexible Working RequestsDate of Termination + 2Consistent with PolicyDestroyHR Policy
Personnel FilesDate of Termination + 6Consistent with PolicyDestroyHR Policy
Training RecordsDate of Termination + 6Consistent with PolicyDestroyHR Policy
Redundancy DetailsActive + 6Consistent with PolicyDestroyHR Policy
Recruitment Documents6 monthsLegal ComplianceDestroyCIPD Recommendation
Previous Employment Details6 monthsLegal ComplianceDestroyCIPD Recommendation
Successful Post ApplicationsTransfer to staff fileLegal ComplianceTransfer to staff fileCIPD Recommendation
Unsuccessful Post Applications1 YearLegal ComplianceDestroyCIPD Recommendation
Interview Notes1 YearLegal ComplianceDestroyCIPD Recommendation
Bank DetailsCurrent Tax Year + 5Consistent with PolicyDestroyHR Policy
Health and SafetyHealth and Safety ReportsCurrent Year + 5Consistent with PolicyDestroyH&S Policy
Health and Safety Records40 (COSHH)Consistent with PolicyArchiveH&S Policy
Legal DocumentationPermanentConsistent with PolicyArchiveH&S Policy
Risk Assessment ReportsYear of Assessment + 3Legal ComplianceDestroyManagement of Health and Safety at Work Regulations 1992
Accident Book4 years from date of last entryLegal ComplianceArchiveLegislation
Health and Safety CorrespondenceCurrent Year + 5Legal ComplianceDestroyLegislation
Safety Training RecordsCurrent Year + 6Legal ComplianceDestroyLegislation
Fire Safety CertificatesPermanentLegal ComplianceArchiveLegislation
Fire Risk Assessment and Fire PlansActiveLegal ComplianceArchiveLegislation
PPE Maintenance and ExaminationCurrent Financial Year + 5Legal ComplianceArchiveLegislation
LEV MonitoringCurrent Financial Year + 6Legal ComplianceArchiveLegislation
Lifting Operations - ExaminationsActiveLegal ComplianceArchiveLegislation
Fire Occurrence RecordsCurrent Year + 5Consistent with PolicyDestroyH&S Policy
InsuranceInsurance Policies12 yearsLegal ComplianceArchiveLegislation
Employers Liability ClaimsPermanentLegal ComplianceArchiveLegislation
EstatesBuilding PlansPermanentConsistent with PolicyAvailableProperty Policy
Resource ManagementCurrent Financial Year + 2Consistent with PolicyDestroyProperty Policy
Legal DocumentationPermanentConsistent with PolicyArchiveProperty Policy
Waste Transfer NotesCurrent Financial Year + 2Legal ComplianceArchiveLegislation
Waste Consignment NotesCurrent Financial Year + 3Legal ComplianceArchiveLegislation
Business Continuity PlanActiveConsistent with PolicyArchiveProperty Policy
Security InformationCurrent Year + 5 yearsConsistent with PolicyDestroyProperty Policy
Leased Property FilesEnd of lease + 5 yearsConsistent with PolicyDestroyProperty Policy
Property FilesCurrent Financial Year + 5Consistent with PolicyDestroyProperty Policy
Job FilesCurrent Financial Year + 5Consistent with PolicyDestroyProperty Policy
LeasesEnd of lease + 5 yearsConsistent with PolicyDestroyProperty Policy
CCTV recordings28 daysConsistent with PolicyDestroy unless legally requiredCCTV Policy
MarketingPromotional MaterialCurrent Year + ArchiveConsistent with PolicyArchiveMarketing Policy
Public RelationsCurrent Year + ArchiveConsistent with PolicyArchiveMarketing Policy
Community LiaisonCurrent Year + ArchiveConsistent with PolicyArchiveMarketing Policy
Press CuttingsCurrent Year + ArchiveConsistent with PolicyArchiveMarketing Policy
ICTFunctional SpecificationsActive + 2Consistent with PolicyDestroyIT Policy
Current Technical SpecificationsActiveConsistent with PolicyDestroyIT Policy
Operating LogsActive + 1Consistent with PolicyDestroyIT Policy
Security Incident ReportCurrent Year + 5Consistent with PolicyDestroyIT Policy
EmailsActive + 2Consistent with PolicyDestroyIT Policy
Photocopying LogDeleted after three monthsConsistent with PolicyDestroyIT Policy
CorporationAnnual Reporting and AccountsPermanentLegal ComplianceArchiveCorporate Policy
Policy DocumentsActive + 5Legal ComplianceDestroyCorporate Policy
Board Committee PapersCurrent Year + 5Legal ComplianceDestroyCorporate Policy
Board MinutesPermanentLegal ComplianceArchiveCorporate Policy
General CorrespondenceCurrent Year + 5Legal ComplianceDestroyCorporate Policy
SMTSenior Management Team MinutesCurrent Year + 5Legal ComplianceDestroyCorporate Policy
Senior Management Team PapersCurrent Year + 5Legal ComplianceDestroyCorporate Policy
Racing LeagueTicketing InformationCurrent Year + 2Consistent with PolicyArchiveIn line with Ticketing Suppliers Policy
Accreditation InformationCurrent Year + 2Attendees at Events will often follow up and attend in subsequent yearsArchiveN/A
Website SubscriberCurrent Year + 6As data subjects can unsubscribe, not doing so means retention is relevantArchiveN/A
Athlete data, including diametric dataCurrent Year of SailGP Season + 2Relevance to broadcast footageArchiveN/A
Attendee at SailGP HospitalityCurrent Year of SailGP Season + 2Attendees will often follow to attend subsequent yearsDestroy/AnonymisedN/A

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Last updated: 3 October 2018