This policy should be read together with the Stamford International University privacy policy
PURPOSE
The purpose of this Policy is to ensure that Stamford International University documents and records are properly maintained and not held for any longer than needed to meet the principle of data limitation.
Stamford International University recognize that the efficient management of its records is necessary to comply with its legal and regulatory obligations and to contribute to the effective overall management of Stamford International University.
This document provides the policy framework through which this effective management can be achieved and audited.
BENEFITS
The benefits of effective document and records management include:
- protecting Stamford International University business critical records;
- ensuring that, whenever necessary, information can be retrieved quickly and efficiently;
- demonstrating compliance with legal and regulatory requirements; and
- reducing the risk of investigations and litigation.
SCOPE OF THE POLICY
This Policy applies to all documents and records, whether held in electronic form or otherwise.
This Policy also applies to records which third parties manage on behalf of Stamford International University.
RETENTION SCHEDULE
The Retention Schedule included within this Policy sets out the periods for which Stamford International University’s key documents and records should be held. These take account of mandatory requirements as well as generally accepted best practice.
The list of document and record types in the Retention Schedule is not exhaustive. If a particular document or record is not shown, guidance on the retention period should be sought from the DPO (Data Protection Officer).
STAFF RESPONSIBILITIES
Stamford International University expects all members of staff and any third parties which are contracted to provide services to Stamford International University to:
- apply the retention periods stated in the Retention Schedule to any documents and records for which they are responsible; and
- protect confidential/privileged documents and records and those which are vital to Stamford International University’s continued operations.
DESTRUCTION OF RECORDS
Care should be taken when selecting the method of disposal. Only documents and records which contain non-sensitive information may be placed into waste-paper bins. Any personal or confidential information should be cross-cut shredded.
Destruction of electronic records should render them non-recoverable. Steps should be taken to ensure that all backups and copies are included in the destruction process.
SUSPENSION OF DESTRUCTION
If Stamford International University becomes the subject of litigation, or an investigation by a governmental or regulatory body, no documents or records of any nature should be destroyed, even if the Document Retention Schedule states otherwise.
The DPO will be responsible for communicating the implementation of an instruction which suspends the destruction of documents or records in these circumstances.
BREACH REPORTING
Any breaches of this Policy, or practices which are considered not to be compatible with it, should be brought to the attention of the DPO and IT Director.
RETENTION SCHEDULE
| Type of document/record | Category | Retention period Mandatory | Stamford International University Retention Period | Citation |
| University and Financial | ||||
| Stamford International University registration documents | University Records | Until the dissolution of the University | Section 1116 of the Civil and Commercial Code B.E. 2468 (1992), and as amended (“CCC”) | |
| Board of directors meeting minutes and resolutions | University Records | Until the dissolution of the University | Until the dissolution of the University | Section 1207 of the CCC |
| Annual Reports | University Records | 10 Years | Section 1198 of the CCC | |
| Accounting: | ||||
| Accounting records (private University) Balance Sheet, Profit & Loss account, cash flow statement – (explaining the University’s transactions, financial position of the University) | Accounting Records | 5 years From the annual closing date (statutory) 12 months of accounting period (statutory) 150 days from the last day of an accounting period 10 years from when the tax return is due (recommend) | Section 14 of the Accounting Act B.E. 2543 (2000) (‘the Accounting Act’) Sections 18, 23, 65, 68bis, and 69 of the Revenue Code B.E. 2481 (2004) (‘the Revenue Code’) and Section 193/31 of the CCC | |
| Official record of inspection of companies’ accounts (containing detailed support for decision regarding planning and performing the audit, evidence obtained, and conclusions reached) | Accounting Records Audits | 10 years from when the tax return is due | Sections 18, 23, 65, 68bis, 69, and 3septies of the Revenue Code and Section 193/31 of the CCC (See also Announcement of the Director-General of Section 3 September of the Revenue (12 March 2001) (‘the Announcement of the Director-General’) | |
| General taxes Information relevant to the University’s tax position including all books, records, and data carriers | General taxes Information relevant to the University’s tax position including all books, records, and data carriers | 10 years from when the tax return is due | Sections 18 and 23 of the Revenue Code and Section 193/31 of the CCC | |
| VAT records Records of delivery of goods or services, exports and imports, VAT invoices, etc. | Tax Records | 5 years (statutory) 10 years (recommended) | Section 87/3 of the Revenue Code Sections 18 and 23 of the Revenue Code and Section 193/31 of the CCC | |
| Corporate income tax | Tax Records | 10 years from when the tax return is due | Sections 18, 23, and 66 of the Revenue Code and Section 193/31 of the CCC | |
| Records relating to tax returns A University which may be required to deliver a university tax return for any period must keep and preserve such records | Tax Records | 10 years from when the tax return is due | Sections 18 and 23 of the Revenue Code and Section 193/31 of the CCC | |
| Human Resources | ||||
| Recruitment Unsuccessful Applicants Including Special Category Data, background checks | Unsuccessful applicants’ information | 1 year from the date of rejection of application | Section 448 of the Civil and Commercial Code B.E. 2468 (1992) (‘CCC’) | |
| Recruitment Successful applicants’ information | Hiring Documents | For the entire duration of the employment relationship (recommended) 10 years (recommended) Plus, an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 578 of the CCC Section 193/30 of the CCC Section 193/32 of the CCC | |
| Successful Applicants Information | Special category data or other data collected for diversity monitoring if permitted in your jurisdiction | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Successful Applicants Information | Background check data which may include / criminal conviction check data | Section 119 of the Labour Protection Act B.E. 2541 (1998) (‘LPA’) Section 193/30 of the CCC Section 193/32 of the CCC | ||
| Formal ID Records | Employment Records | 2 years (statutory) 10 years (recommended) From the termination of employment relationship From the commencement of legal proceedings | Sections 113 and 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Social security number or other national identity numbers | Employment Records | No Statutory recommended for the duration of the employment relationship. | N/A | |
| Bank details | Employment Records | 2 years (statutory) 10 years (recommended) Plus, an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the date of payment From the termination of employment relationship From the commencement of legal proceedings | Sections 113 and 115 of the LPA Sections 114 and 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Information relating to the right to work | Employment Records | 2 years (statutory) 10 years (recommended) From the termination of employment relationship From the commencement of legal proceedings | Sections 113 and 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Address and other personal contact details | Employment Records | 2 years (statutory) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the date of payment From the termination of employment relationship From the commencement of legal proceedings | Sections 113 and 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Work contact details (including work location) | Employment Records | For the entire duration of the employment relationship (recommend) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the date of payment From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Next of kin and emergency contact details | Employment Records | For the entire duration of the employment relationship (recommended) 10 years (recommended) From the date of payment From the termination of employment relationship From the commencement of legal proceedings | N/A | |
| Records of Promotion | Performance Records, Employment Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the date of payment From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Grievances | Performance Records, Employment Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Disciplinary Records | Performance Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Performance management | Performance Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Bonus awards | Performance Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Logs: Incident reports | Employment Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Logs: Attendance records | Employment Records | 2 years (statutory) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the date of payment From the termination of employment relationship From the commencement of legal proceedings | Sections 114 and 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Logs: Records of Annual leave | Employment Records | 2 years (statutory) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the date of payment From the termination of employment relationship From the commencement of legal proceedings | Sections 114 and 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Logs: Location Access Records | Employment Records | For the entire duration of the employment relationship (recommended) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | ||
| Medical Records: Doctors’ notes including fit notes or similar | Medical Records | 2 years (statutory) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the termination of employment relationship From the commencement of legal proceedings | Clause 7 of Ministerial Regulations on The Criteria and Procedure for Medical Examination of Employees and Submission of Examination Results to Labour Official B.E.2547 (2004) (‘the Medical Examination Ministerial Regulations’) Section 193/30 of the CCC | |
| Medical Reports | Medical Records | 2 years (statutory) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the termination of employment relationship From the commencement of legal proceedings | Clause 7 of the Medical Examination Ministerial Regulations[ST5] Section 193/30 of the CCC Section 193/32 of the CCC | |
| Records of adjustments or accommodations at work | Medical Records | For the entire duration of the employment relationship (recommend) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Payslips | Payroll and tax records | 2 years (statutory) 2 years (recommended) 10 years (recommended) From the date of payment From when the incident occurred From when the tax return is due | Sections 114 and 115 of the LPA Section 193/34 of the CCC Sections 18, 23, 65, 68bis, and 69 of the Revenue Code B.E. 2481 (2004) (‘the Revenue Code’) and Section 193/31 of the CCC | |
| Records of gross and net salary | Payroll and tax records | 2 years (statutory) 2 years (recommended) 10 years (recommended) From the date of payment From when the incident occurred From when the tax return is due | Sections 114 and 115 of the LPA Section 193/34 of the CCC Sections 18, 23, 65, 68bis, and 69 of the Revenue Code and Section 193/31 of the CCC | |
| Records of deductions from salary | Payroll and Tax records | 2 years (statutory) 2 years (recommended) 10 years (recommended) From the date of payment From when the incident occurred From when the tax return is due | Sections 114 and 115 of the LPA Section 193/34 of the CCC Sections 18, 23, 65, 68bis, and 69 of the Revenue Code and Section 193/31 of the CCC | |
| Records of statutory (or tax) allowances | Payroll and tax records | 2 years (statutory) 10 years (recommended) From the date of payment From when the incident occurred From when the tax return is due | Sections 114 and 115 of the LPA Section 193/34 of the CCC Sections 18, 23, 65, 68bis, and 69 of the Revenue Code and Section 193/31 of the CCC | |
| Tax and national insurance or social security contributions | Payroll and tax records | 2 years (statutory) 2 years (recommended) 10 years (recommended) From the date of payment From when the incident occurred From when the tax return is due | Sections 114 and 115 of the LPA Section 193/34 of the CCC Sections 18, 23, 65, 68bis, and 69 of the Revenue Code and Section 193/31 of the CCC | |
| Payslips and payroll cards | Pension records | 2 years (statutory) 10 years (recommended) From the date of payment From when the incident occurred From when the tax return is due | Sections 114 and 115 of the LPA Section 193/34 of the CCC Sections 18, 23, 65, 68bis, and 69 of the Revenue Code and Section 193/31 of the CCC | |
| Post termination elections: Elections to transfer or move pension funds, etc. | Pension Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Dependants and beneficiaries’ data: Full name, addresses, bank details, etc. | Pension Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Records of elections | Pension Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Records of changes to contribution levels | Pension Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Records of employer matching or other contributions | Pension Records | 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Health and Safety | ||||
| Standard/routine employee health documentation | Health and Safety records | 2 years (recommended) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended)occupational health questionnaire completed by employee, personal and occupational health histories. From the termination of employment relationship From the termination of employment relationship From the commencement of legal proceedings | Section 115 [ST7] of the Labour Protection Act B.E. 2541 (1998) (‘LPA’) Section 193/30 of the Civil and Commercial Code B.E. 2468 (1992) (‘CCC’) Section 193/32 of the CCC | |
| Drug/alcohol tests: Tests of employees for drugs/alcohol | Health and Safety records | 2 years (recommended) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the termination of employment relationship From the commencement of legal proceedings | Section 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Records relating to work arrangements based on employees’ health. Individual reintegration plans, individual treatment agreements, degree of incapacity for work, required workplace adaptations, etc. | Health and Safety records | 2 years (recommended) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From the termination of employment relationship From the termination of employment relationship From the commencement of legal proceedings | Section 115 of the LPA Section 193/30 of the CCC Section 193/32 of the CCC | |
| Health and safety policies: Policies, systems, procedures, standards, guidance | Health and Safety Records | Until the dissolution of the University | N/A | |
| Audit reports. Assessment of a business’s system and processes, in which it is measured against regulated criteria to make sure health and safety standards are being upheld | Health and Safety Records | Until the dissolution of the University | N/A | |
| Incident notifications. Notification of health and safety incidents arising from/during the conduct of business (e.g., death, serious injury or illness of a person /dangerous incident) | Health and Safety Records | Until the dissolution of the University (recommended) 10 years (recommended) Plus an additional 10 years if legal proceedings have been initiated (recommended) From when the incident occurred From the commencement of legal proceedings | Section 193/30 of the CCC Section 193/32 of the CCC | |
| Investigation reports: Investigation reports containing information on accidents/incidents occurred | Health and Safety Records | Until the dissolution of the University | N/A | |
| Risk assessments carried out in compliance with the law. Legally required assessment of the risks to the health and safety of employees to which they are exposed whilst they are at work/the risks to the health and safety of persons not in the employer’s employment arising out of or in connection with the conduct by him of his undertaking. | Health and Safety Records | Until the dissolution of the University | N/A | |
| Records and minutes of consultations with safety representatives and committees. These could include reports, problems, statistics, recommendations made, who made the recommendations and actions taken, the introduction of any measure which may substantially affect their health and safety at work, the planning of health and safety training, etc. | Health and Safety Records | Until the dissolution of the University | N/A | |
| Information Technology | ||||
| Computer traffic data | IT Securities | 90 days (statutory) 2 years (recommended) from the date that data entered to the computer system. | Section 12 (1) and (2) of the Notification of Ministry of Digital Economy and Society Re: Criteria on Storing Computer Traffic Data of Service Providers B.E. 2564 (2021) | |
| Records of online meeting of the board of directors or shareholders | IT Securities | 90 days (statutory) | Until the dissolution of the University | Emergency Decree on Electronic Meetings, B.E.2563 (2020) Clause 7 of the Notification of Ministry of Digital Economy and Society RE: Standards for Maintaining Security of Meetings via Electronic Means B.E. 2563 (2020) |