NEOFIN ADVISORY Data Retention Policy

1. Introduction

NEOFIN ADVISORY is legally required to manage its customer records to ensure it meets the requirements of the Data Protection Act (DPA) 2018.

The DPA states that personal data must be retained for as long there is a business need for it and:

• it must be adequate and not excessive
• it must be accurate and up to date
• it must not be kept longer than is necessary
• it must be secure

Customer records are defined as any piece of information that relates to our claimants or customers regardless of its content and format. Compliance with these instructions is the responsibility of all staff.

2. Retention of customer records

2.1 Classification of records

NEOFIN ADVISORY has two classifications of customer records: ‘supporting’ or ‘non-supporting/ephemeral’. The definitions are:

• supporting records: documents or data that support a benefit or child maintenance outcome decision and contains information on which that decision is based. It is generally information that would be supplied in the event of an appeal or fraud investigation, or that affects the amount of benefit paid or maintenance assessment. See Section 3 for general guidance on retention of customer documents.
• non-supporting/ephemeral records: documents or data that do not fit into the definition of supporting documents. These are of a general nature and do not affect the customer in any way. For example, general enquiries, internal templates, front cover sheets.

2.2 How long do I keep records?

Telephone call recording

As Neofin operates as an advisory/consulting body, all telephone calls are treated as confidential records and as such are not recorded. Exceptions can apply to this if circumstances will justify such measures – i.e., due to legal requirements.

Non-telephone records

The following retention policy is applied to all non-telephone records in NEOFIN ADVISORY:

• supporting records: generally, records classified as supporting are retained for 14 months after NEOFIN ADVISORY’s live interest in the claim has ended. As with telephone records, exceptions can apply to this and will be treated on a case-by-case basis.
• non-supporting or ephemeral records: These should be retained locally for 4 weeks and then paper records must be destroyed via confidential waste.

Users must:

• only retain information required to support the customer by applying the principles of what is ‘supporting’ and what is ‘ephemeral’
• apply retention periods to all claim documents
• destroy all paper documents that are scanned into electronic systems within 4 weeks of being scanned
• save customer information in the right place for the right length of time

Users must not:

• retain customer records ‘just in case’ they may be needed at some point in the future

Updated: 30/09/2024.