Retention Policy

Last Modified: 30 Apr 2024

1. About this policy

   1. The information of Pairly, including data subject data, is vital to how it conducts its business and manages employees.

   2. Certain laws require us to retain certain records, usually for a specific amount of time. The accidental or intentional destruction of these records during their specified retention periods could result in the following consequences:

      1. fines and penalties;

      2. loss of rights;

      3. obstruction of justice charges;

      4. contempt of court charges; and/or

      5. serious disadvantages in litigation.

   3. We must retain certain records because they contain information that:

      1. has business value (for example, it provides a record of a business transaction, evidences our rights or obligations, protects our legal interests or ensures operational continuity); or

      2. must be kept to satisfy legal, accounting, or other regulatory requirements.

   4. This policy does not form part of any employee's contract of employment and we may amend it at any time. 

   5. This policy applies to all employees, officers, consultants, contractors, volunteers, interns, casual workers, and agency workers of Pairly Ltd 

   6. This policy explains the differences among records and disposable information.

2. RECORDS

   1. A record is any type of information created, received, or transmitted in the transaction of business, regardless of physical format. Examples of where the various types of information are located include:

      1. appointment books and calendars; 

      2. audio and video recordings;

      3. computer programs and the data input into those programs;

      4. contracts;

      5. electronic files;

      6. emails;

      7. handwritten notes;

      8. invoices;

      9. letters and other correspondence;

      10. memory in mobile phones and other mobile devices;

      11. online postings, such as on Facebook, Twitter, Instagram, and other social media platforms and websites;

      12. performance reviews; and/or

      13. voicemails.

   2. Any records that hold Personal Data (any information which can be used to identify a living individual, e.g. name, address, telephone number, email) are to be considered part of the relevant category listed in the Records Retention Schedule contained in the Appendix to this policy and must be retained for the amount of time indicated in the Records Retention Schedule. 

   3. All records are to be considered and treated as confidential information and should not be disclosed to any third party (including police, courts or other investigatory bodies) without the permission of a Director and/or Privacy Officer.

   4. A record should not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or other situations, e.g. litigation) requires that is retained beyond the set period. If you are unsure whether to retain a certain record, contact the Privacy Officer.

3. Disposable Information

   1. Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a record as defined by this policy. Examples include:

      1. duplicates of originals (that have not been annotated);

      2. preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record;

      3. books, periodicals, manuals, training binders, and other printed materials obtained from sources outside of the company and retained primarily for reference purposes; and/or

      4. spam and junk mail.

4. Guidelines for DESTRUCTION

   1. Each member of staff is responsible for the continuing process of identifying the records that have met their required retention period and supervising their destruction. The destruction of confidential, financial, and personnel-related records must be conducted by shredding if possible our may be outsourced to a reputable third party who provides record destruction services. Non-confidential records may be destroyed by recycling. The destruction of electronic records must be coordinated with the Privacy Officer.

   2. The destruction of records must stop immediately upon notification from the Privacy Officer, a Director or on notice that the company may be involved in a lawsuit or an official investigation.

5. Breach of this policy

   1. Breach of this policy may result in disciplinary action up to and including dismissal. Any member of staff suspected of committing a breach of this policy will be required to co-operate with our investigation, which may involve handing over relevant passwords and login details.

   2. You may be required to remove any social media content that we consider to constitute a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action.

APPENDIX

Record Retention Schedule

Employees should give special consideration to the categories of documents listed in the record retention schedule below. Avoid retaining a record if there is no business reason for doing so, and consult with the Privacy Officer if unsure.