The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the UK GDPR.

In addition to safeguarding the rights of data subjects under the UK GDPR, by ensuring that the Company does not retain excessive amounts of data, this Policy also aims to improve the speed and efficiency of managing data.

This Policy applies to all personal data held by Pioneer Quality Services Limited.

Personal data, as held by Pioneer Quality Services Limited, is stored in the following ways and in the following locations:

1. The Company’s servers, located in Head Office, The Stable, The Cattle Yard, Manston, Kent, CT12 5FQ and located on OneDrive.
2. Computers permanently located in the Company’s premises at The Stable, The Cattle Yard, Manston, Kent, CT12 5FQ.
3. Laptops, computers and other mobile devices provided by the Company to its employees.
4. Physical records stored in the head office lockable filing cabinet.

Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used as set out in Parts 12 and 13 of the Company’s Data Protection Policy, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability, and further rights relating to automated decision-making and profiling as set out in Parts 14 to 18 of the Company’s Data Protection Policy.

The following technical measures are in place within the Company to protect the security of personal data. Please refer to Parts 20 to 24 of the Company’s Data Protection Policy for further details:

1. All emails containing personal data must be encrypted.
2. All emails containing personal data must be marked “confidential”.
3. Personal data may only be transmitted over secure networks.
4. Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative.
5. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted.
6. Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it.
7. Where personal data is to be transferred in hard-copy form, it should be passed directly to the recipient or sent using registered post. All personal data transferred physically should be transferred in a suitable container marked “confidential”.
8. No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Data Protection Manager.
9. All hard copies of personal data, along with any electronic copies stored on physical media should be stored securely.
10. No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation.
11. Personal data must be handled with care at all times and should not be left unattended or on view.
12. Computers used to view personal data must always be locked before being left unattended.
13. No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the Data Protection Manager and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
14. No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the UK GDPR.
15. All personal data stored electronically should be backed up regularly with backups stored offsite. All backups should be encrypted.
16. All electronic copies of personal data should be stored securely using passwords and encryption.
17. All passwords used to protect personal data should be changed regularly and must be secure.
18. Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords.
19. All software should be kept up to date. Security-related updates should be installed as soon as reasonably possible after becoming available.
20. No software may be installed on any Company-owned computer or device without approval.
21. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Data Protection Manager to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the Telephone Preference Service (TPS).

The following organisational measures are in place within the Company to protect the security of personal data. Please refer to Part 25 of the Company’s Data Protection Policy for further details:

1. All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the UK GDPR and under the Company’s Data Protection Policy.
2. Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company.
3. All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so.
4. All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised.
5. All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times.
6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed.
7. The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed.
8. All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the UK GDPR and the Company’s Data Protection Policy.
9. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the UK GDPR and the Company’s Data Protection Policy.
10. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under the UK GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Personal data stored electronically (including any and all backups thereof) shall be deleted securely using appropriate non-recoverable software tools.

Personal data stored in hard-copy form shall be shredded to at least the standard of BS EN 15713:2023 and recycled.

As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

When establishing and/or reviewing retention periods, the following shall be taken into account:

1. The objectives and requirements of the Company.
2. The type of personal data in question.
3. The purpose(s) for which the data in question is collected, held, and processed.
4. The Company’s legal basis for collecting, holding, and processing that data.
5. The category or categories of data subject to whom the data relates.

If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

The Company’s Data Protection Manager is contactable via email: enquiries@pioneerqs.uk.

The Data Protection Manager shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the UK GDPR and other applicable data protection legislation.

The Data Protection Manager shall be directly responsible for ensuring compliance with the above data retention periods throughout the Company. Any questions regarding this Policy, the retention of personal data, or any other aspect of UK GDPR compliance should be referred to the Data Protection Manager.