Records Retention Policy

1. SCOPE
1.1 All Enigma Legals' records, whether physical or digital, are subject to the retention requirements of this procedure.

2. RESPONSIBILITIES
2.1 The Finance Director is responsible for retention of financial (accounting, tax)and related records. Furthermore, the Finance Director is responsible for all other statutory and regulatory records.
2.2 The Executive assistant is responsible for retention of all HR records.
2.3 The Executive assistant is responsible for the storage of hard copy records and for ensuring they are managed in line with this Policy.
2.4 The Executive assistant is responsible for ensuring that electronically stored records are managed in line with this Policy and that they are included in business continuity and disaster recovery plans.

3. PROCEDURE
3.1 Enigma Legal has consulted its insurance broker, in determining what the correct retention period is for the vast majority of work types which do not require special retention periods. Having considered the various limitation dates generally within theLimitation Act 1980, Section 14B of the Act states that limitation can be extended up to a maximum long stop date of 15 years. Given the obvious difficulties in having multiple limitation dates across a significant number of matters, it makes perfect commercial sense in having one, generic, long stop date which, of course derives from statute. The firm also has a duty to insurers to keep files for that period of time in the event any claim were to arise.
3.2 Enigma Legals' data is classified into 3 groups, Clients, Employees\Applicants andSuppliers. Within these groups data falls into work types. Each classification will include Personal Data and is listed below.
3.3 Information about clients:
(a) Personal details including name and contact information
(b) Family and lifestyle details
(c) Device details
(d) User activity details and user preferences
(e) Browser history details Records Retention Policy – 2019
(f) Location details
(g) Electronic identification data including IP address and information collected through cookies
(h) Contractual details including the services provided
3.4 Information about employees and job applicants:
(a) Personal details including name and contact information
(b) Date of birth
(c) Gender
(d) Marital status
(e)Beneficiary and emergency contact information
(f) Government identification numbers
(g) Education and training details
(h) Bank account details and payroll information
(i) Wage and benefit information
(j) Performance information
(k) Employment details
(l) Special categories of personal data, including information that relates to: (i) racial or ethnic origin (ii) political opinions (iii) religious or philosophical beliefs (iv)trade-union membership (v) genetics or health (vi) sex life or sexual orientation
3.5 Information about suppliers
(a) Name and contact information
(b) Financial and payment details
 3.6 The  required retention periods, by record type, are below for Clients and  Suppliers: 

Record Type
Default (Client)
Commercial, Employment

Retention Period
15 Years
7 Years

Storage Media
Electronic / Physical
Electronic / Physical