Data Retention Erasure Policy

This Policy is written with the intent to make sure that all required information, documents, and records of VIP Pleasure Girls are appropriately maintained and protected under pertaining laws and regulations. Secondly, to ensure that all records of no value, as well as those that are not needed anymore are disposed of in the proper manner and time. Thirdly, to help VIP Pleasure Girls employees comprehend their duties in regards the retainment of e-documents, including PD Files, audio-visual files, web files, instant messages, emails, and all Microsoft Office or other formatted files. All private information will be maintained only for as long as absolutely necessary and no more than that. VIP Pleasure Girls will produce a Data Retention & Erasure Schedule to showcase a generic retention period according to the guidelines pertaining to data retention and the purpose of the information. If maintaining personal information is no longer required for the operations of VIP Pleasure Girls, that information will be deleted. In this case, all copies will also be properly destroyed according to the schedule that has been defined.

Record Retention Schedule

This section includes the Record Retention Schedule which is the primary schedule for data maintenance, disposal, and retention for all records in possession of VIP Pleasure Girls. To make sure that the Schedule abides by the Data Retention & Erasure Policy guidelines, it will be regularly reviewed.

Suspension of the Policy

In specific instances, data has to be preserved for a longer period of time than those established in the Policy, which means that the policy associated with a specific document or customer should be suspended. Such circumstances include: (1) the detection of a crime (or when a crime is suspected), (2) when the owning unite considers the data of having potential historical significance, (3) when the data is related to an organisation in receivership, liquidation or where the company has outstanding debt, (4) when investigations like a regulatory or legal proceedings, or obligation to provide data are suspected to be likely, actual or threatened.

In instances of actual or possible crimes/investigations/legal proceedings occurring, the type of data that must be retained correlates with any information which will harm or help the organisation or the other side of the case, amount or liability involved. Upon doubt over whether a crime/investigation/legal proceeding could take place or what data material is related in such instances, the company will take all necessary measures to let all employees of any suspension know of all information necessary regarding the disposal of documents.

Record Retention Schedule

Function

Record Type

Retention Period

Accounting

Financial information

Permanent

 

Annual accounts

Permanent

 

Cancelled cheques

7 years

 

Bank statements

7 years

 

Interim financial statements

7 years

Contracts

Contracts, including relevant and supportive documentation of any proposal that has led to the contract

7 years after termination/expiration

Corporate Records

Permits & licenses

Permanent

 

Articles of incorporation/record of incorporation

Permanent

 

Annual corporate reports

Permanent

Insurance Records

Certificates

Permanent

 

Insurance policies & expired policies

Permanent

 

Claims files (including medical records, correspondence, etc.)

Permanent

Legal Papers & Files

Litigation files

12 months after the expiration of appeals

 

Legal opinions & memoranda (AND all subject matter files)

7 years after matter closes

 

Court orders

Permanent

 

Member registry

Permanent

 

Directors meetings’ minutes

10 years

 

Requests for leaving from Records Retention Plan

10 years

Personal Records

Job descriptions

3 years after replaced

 

Individual employment contracts

7 years after separation

 

Job applications of unsuccessful candidates (including interviews)

Less than 6 months - longer if with explicit consent

 

Employment records with ads for job openings and employment agencies & relevant correspondence

3 years from the hire decision

 

Staff personnel records (including test results, annual leave, training & qualifications records, individual attendance records, status or job change records, application forms, performance evaluations, garnishments, withholding information, and termination papers)

6 years after separation

 

Employee bank details

As long as absolutely necessary only

 

Forms of working time opt-outs

2 years

Tax Records

Statements/receipts/tax bills

7 years

 

PAYE records

Min. 3 years from the end of the related tax year

 

Tax returns

Permanent

 

Maternity records

3 years after the commencement of the tax year in which the pay period (maternity pay) ends

 

Yearly information returns

Permanent

 

Use of tax records & sales

7 years

 

Wage or payroll records for sole proprietorships, family trusts, and partnerships

5 years after the last day of January following the assessment year.

Miscallaneous

Policy/processes manuals (original)

Retain current version & revision history

 

Policy/processes manuals (copies)

Retain only current version

 

Publications, pictures of other material of historical value

Permanent

Data Retention Schedule Notes

1. Accounting & Finance – All records containing customer’s bank details should be locked in a secure place (a filing cabinet or a desk drawer) when not used by staff. If documents that include credit card information must be retained for more than 3 months, then the identifying details should be removed from the documents (cut out).

2. Tax records – All organisations are obliged to maintain records and books of account as are sufficient to establish credits/deductions/gross income or other matters needed to be displayed or communicated in any such return. These records and documents will be maintained for as long as is required (their contents are material in tax laws administration).

3. Electronic mail – Emails will be retained based on the subject matter. All emails from external sources along with client emails should be deleted after one year regardless of content unless necessary for the business’ operations. All emails that associate with an unsuccessful applicant shall be deleted within 3 months after the review of the application. Staff members should under no circumstances send proprietary or confidential information to outside sources.

4. Electronic documents – Includes instant messaging, spreadsheet, PDF files, word processing and all other file sources. The retention of such information is reliant on the subject matter. For instant messaging, it varies on the content. The messages from instant messaging that are primarily used from prospective applicants during a hiring procedure for the transfer of media (and the media contained in these messages) are deleted upon the termination of the application process. Other messages and media associated with other individuals might be retained for up to 24 months. All staff members should abide by the guidelines of this Policy. Electronic files (emails and documents) are not automatically deleted beyond the dates that this Policy specifies. In specific circumstances, a document can be retained in electronic AND paper form. In such instances, the electronic document is regarded as the official document.

Retaining Personal Information

The purpose of this section is to highlight the established data retention procedures and policies, which have been set out to help ensure full compliance with pertaining laws and all legal duties in relation to the deletion and retention of personal data.

Any personal data processed for any purpose(s) will not be retained for more than absolutely necessary for the specific purpose(s). VIP Pleasure Girls usually deletes personal information belonging in the following categories at the maximum of the retention period indicated in the below table and list:

Information about a Computer (including the use of and visits to this website)

IP address

24 months after the submission of information

Browser version/type

24 months after the submission of information

Website navigation paths

24 months after the submission of information

Page views

24 months after the submission of information

Length of visit

24 months after the submission of information

Referral source

24 months after the submission of information

Operating system

24 months after the submission of information

Geographical location

24 months after the submission of information

  • As a Member of the VIP Pleasure Girls Gallery – Any information provided upon the completion of a recruitment profile of our website, either by social media, instant messaging, phone, email or other means will be retained for 2 years after our last interaction or after the closure of the account. Such information includes a name, age, gender, nationality, professional experience, and services offered.
  • As a Client – Any information provided upon contact with the VIP Pleasure Girls company via social media, instant messaging, mobile, email, contact page, website booking form, website or other means shall be retained for 1 month after the submission of the information (including sensitive personal data).
  • Information Associated with Enquiries Made- Such data, which also includes an email address, address, name, phone number, and payment details will be retained for up to 2 years after the information was submitted.
  • Information sent to our website for publication online – This also includes any media submitted to us. That information will be retained for up to 2 years following the submission of the information.
  • Information contained in communications delivered via the website – This also includes any data related to any such communications. Besides the content of the communication, the associated metadata also fall under this category and will be retained for up to 2 years after contact.

All other chosen-to-be-sent personal information not included in the aforementioned categories will be retained for 2 years after contact.

In spite of the other provisions of this section, VIP Pleasure Girls shall retain electronic and other documents that contain personal data as follows:

  • For the time period absolutely necessary and as required by law.
  • To defend, exercise or establish our legal rights. This includes providing data to others to reduce credit risk and prevent fraud.
  • If the information is believed to be related to any prospective or ongoing legal proceedings.

Information Backup

All electronic information contained on our server will be properly saved and safeguarded. We shall run database backups of all the information associated with all current users, alongside any data that remains on our servers for any reason highlighted in this Data Retention Policy. This database backup is a defence mechanism to help retrieve lost data within a 12-month retrieval period if the users of the system experience any issues.

Internal Messaging & Correspondence

The majority of internal communication and correspondence must be retained for the same period of time as the document these communications relate to. For example, a letter concerning a particular contract should be retained for 7 years after the expiration of the contract, which is the retaining period for the contract as specified in this Policy. The same applies to all records pertaining to a project – they should be retained for as long as the particular project file needs to be retained. All other communication or correspondence that does not relate to documents whose retaining period has been clarified in this Policy should be disposed of sooner and usually fall into three general categories:

(1) Correspondence having important lasting consequences – It should be permanently retained in general.

(2) Correspondence related to non-routine matters – It should be permanently retained.

(3) Correspondence related to routine matters with no lasting effects of particular significance – It should be disposed of within 24 months.

Some examples of category nr.3 include: (1) general replies and enquiries, (2) chronological written communication files, (3) letters that close correspondence with no need for further reference, (4) letters of insignificant subject matter, (5) complaints or letters requesting name change or other specific action which will have no value after the requested action is taken or the changes are made.

It should be noted that any copies necessary for project traceability should be retained. In any other case, they should be read and disposed of using an appropriate data destruction method.


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