Data Retention and Disposal Policy

Last reviewed: November 2026

1. Purpose

Mosaic Group Limited will not retain personal information or business records for longer than is necessary for the purpose for which they are held.

Retention periods will take account of:

  • legal and regulatory requirements;

  • contractual obligations;

  • legitimate business requirements;

  • applicable limitation periods;

  • health and safety requirements; and

  • the rights and interests of individuals.

Information that is no longer required will be securely deleted, anonymised or destroyed.

This policy should be read alongside Mosaic’s Data Protection Policy, Privacy Notice and Information Security policies.

2. General principles

  • Records should normally be retained for the periods set out in this policy.

  • A longer period may be used where there is a documented legal or business justification.

  • Where litigation, an investigation, audit, insurance claim or regulatory enquiry is underway or reasonably anticipated, relevant records must not be destroyed until the matter has concluded.

  • Duplicate and convenience copies should be deleted when no longer required.

  • Retention requirements apply to both electronic and paper records.

  • Special category and criminal offence information should receive additional protection and should not be retained merely because other information in the same file is retained.

  • At the end of the applicable period, information should be securely destroyed or anonymised unless continued retention can be justified.

3. Retention schedule

Record typeStandard retention period
General website or contact enquiries where no business relationship develops12 months after last meaningful contact
General business correspondenceRetain while relevant; up to 6 years where connected with a contractual, financial or material business relationship
Customer and supplier contact recordsDuration of active relationship plus up to 6 years where required for contractual, financial or legal purposes
Contracts and agreements executed as simple contracts6 years following expiry, termination or completion
Contracts executed as deeds12 years following expiry, termination or completion
Customer orders, purchase orders, invoices, receipts, delivery records and debtor/creditor records6 years following the end of the relevant financial/accounting period
Corporation Tax and supporting financial recordsAt least 6 years from the end of the relevant accounting period, or longer where required
PAYE, payroll, pay deductions, benefits in kind and related pay and tax recordsNormally 6 years following the relevant tax year/pay reference period
Employee personnel records, contracts, disciplinary/grievance records and termination recordsEmployment period plus 6 years, unless another statutory period applies
Employee emergency contact detailsDelete promptly once employment ends unless still required for a specific reason
Routine sickness and absence recordsRetain only for as long as required for employment, legal or management purposes; normally no longer than employment plus 6 years
Health surveillance records subject to COSHH or equivalent legislationPeriod required by the relevant regulations; for applicable COSHH health records this may be 40 years
Other occupational health or medical informationRetain only for as long as necessary for the relevant employment, legal or health and safety purpose
Successful recruitment recordsRelevant material transferred to the employee file; unnecessary recruitment material deleted after appointment
Unsuccessful job applications, interview notes and recruitment recordsNormally 12 months after completion of the recruitment exercise
Speculative employment enquiries where no formal application follows12 months after last meaningful contact
DBS certificate or certificate informationNormally no longer than 6 months after the relevant decision
Limited record that a DBS check was undertakenRetain only where necessary, recording appropriate details rather than the certificate itself
Marketing contact recordsWhile the relationship or marketing purpose remains current, subject to periodic review
Marketing suppression/opt-out recordsRetain for as long as necessary to ensure the individual’s preference continues to be respected
Complaints and associated correspondenceNormally up to 6 years after closure where necessary for business or legal purposes
Data protection complaintsNormally up to 6 years after closure, subject to the circumstances and sensitivity of the information
Subject access and other individual-rights requestsNormally 3 years after closure unless a dispute or claim justifies longer retention
Personal data breach recordsNormally up to 6 years after closure, with sensitive supporting information reviewed and minimised where appropriate
Insurance policies and claimsDuration of the policy or claim plus the relevant limitation period; normally at least 6 years after closure where appropriate
Litigation and legal claim filesUntil proceedings and relevant appeal or limitation periods have expired; seek legal advice where necessary
Intellectual property and trade mark recordsDuration of the relevant rights plus any period necessary to establish or defend ownership
Asset registersLife of the asset plus the period required for accounting and tax purposes
Software licences and material IT contractsDuration of licence or contract plus up to 6 years where relevant
Website security and server logsRetain only for as long as necessary for security, troubleshooting, hosting and incident investigation purposes
Cookie preference recordsRetain only for as long as reasonably necessary to remember the user’s cookie/privacy choice

4. Health surveillance records

Health surveillance records must be distinguished from confidential medical records.

Where health surveillance is required by legislation, Mosaic will retain the relevant health record for the period required by the applicable regulations.

Confidential clinical or medical information held by an occupational health professional will remain subject to medical confidentiality and appropriate access controls.

5. DBS information

DBS certificate information must be handled securely and used only for the purpose for which it was obtained.

Certificate information should normally be destroyed as soon as it is no longer required and usually no later than six months after the relevant decision.

Where appropriate, Mosaic may retain a limited record confirming that a check took place without retaining the certificate or detailed disclosure information.

6. Review and disposal

Departments responsible for records must periodically review information under their control and dispose of information that has reached the end of its retention period.

Where a record is not clearly covered by this schedule, the Data Protection Lead should determine an appropriate retention period based on:

  • the purpose for which the information is held;

  • applicable legal requirements;

  • relevant limitation periods;

  • sensitivity of the information; and

  • the risks associated with continued retention.

7. Secure disposal

Paper records containing confidential or personal information must be securely shredded or disposed of through an approved confidential-waste process.

Electronic information must be securely deleted from live systems in accordance with Mosaic’s information-security arrangements.

Information held within backups will be managed in accordance with Mosaic’s backup and system-retention arrangements and must not be restored for ordinary business use once the underlying information should have been deleted.

8. Suspension of destruction

Normal destruction must be suspended where records may be relevant to:

  • actual or anticipated litigation;

  • a regulatory investigation;

  • an insurance claim;

  • an audit;

  • a data protection request or complaint; or

  • another matter requiring preservation of evidence.

Records should be returned to the normal retention cycle once the hold is no longer required.

9. Review

This policy will be reviewed at least annually through the IMS Management Review process and sooner where there is a significant change in:

  • law or regulatory guidance;

  • Mosaic’s systems or processing activities;

  • business requirements; or

  • identified risks.