Healthbridge Direct Limited

Data Retention Policy

1st June 2026

 

 

  1. Introduction

This Policy sets out the obligations of Healthbridge Direct Limited, a company registered in England under number 09116741, whose registered office is at The Vintry, Redbridge Lane East, Ilford, Essex IG4 5EY (“the Federation”) regarding retention of personal data collected, held, and processed by the Federation in accordance with the Data Protection Legislation. “Data Protection Legislation” means all legislation and regulations in force from time to time regulating the use of personal data and the privacy of electronic communications including, but not limited to, the Data Protection Act 2018, the UK GDPR, the Privacy and Electronic Communications Regulations 2003 as amended, the Data Use and Access Act 2025 and any successor legislation.

The Data Protection Legislation defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The Data Protection Legislation also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

Under the Data Protection Legislation, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the Data Protection Legislation to protect that data).

In addition, the Data Protection Legislation includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

  1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
  2. When the data subject withdraws their consent;
  3. When the data subject objects to the processing of their personal data and the Federation has no overriding legitimate interest;
  4. When the personal data is processed unlawfully (i.e. in breach of the Data Protection Legislation);
  5. When the personal data has to be erased to comply with a legal obligation; or
  6. Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Federation, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.

For further information on other aspects of data protection and compliance with the Data Protection Legislation, please refer to the Federation’s Data Protection Policy.

 

  1. Aims and Objectives
    • 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 Federation complies fully with its obligations and the rights of data subjects under the Data Protection Legislation.
    • In addition to safeguarding the rights of data subjects under the Data Protection Legislation, by ensuring that excessive amounts of data are not retained by the Federation, this Policy also aims to improve the speed and efficiency of managing data.

 

  1. Scope
    • This Policy applies to all personal data held by the Federation.
    • Personal data, as held by the Federation is stored in the following ways and in the following locations:
      1. The Federation’s IT systems using Microsoft Office and NHS systems;
      2. Laptop computers and other mobile devices provided by the Federation to its employees;
      3. Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with the Federation’s Bring Your Own Device (“BYOD”) Policy;
      4. Physical records stored at the Federation’s office and by any director, manager, employee whether permanent or temporary, contractor or agent working on behalf of the Federation at their home address.

 

  1. Data Disposal

Upon the expiry of the data retention periods set out below in this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

  • Personal data stored electronically (including any and all backups thereof) shall be deleted;
  • Special category personal data stored electronically (including any and all backups thereof) shall be deleted;
  • Personal data stored in hardcopy form shall be shredded to at least level 3;
  • Special category personal data stored in hardcopy form shall be shredded to at least level 3.

 

  1. Data Retention
    • As stated above, and as required by law, the Federation 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 Federation;
      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 Federation’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 Federation to do so (whether in response to a request by a data subject or otherwise).
    • In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the Data Protection Legislation.

 

Type of Data Purpose of Data Retention Period or Criteria
GP Medical Records To fulfil obligations of the Federation 10 years after the death or after the patient has permanently left the country, unless the patient remains in the European Union.  In the case of a child, if the illness or death could have potential relevance to adult conditions or have genetic implications for the family of the deceased, the advice of the clinicians will be sought as to whether to retain the records for a longer period.  Current legislation states that electronic patient records (EPRs) are not destroyed or deleted.
Employee Records To fulfil purposes of Federation as an employer 6 years after an employee has left the organisation
Recruitment information To fulfil purposes of Federation as an employer 12 months
Financial records To meet obligations of tax law 7 years
Contact information of providers, contractors and suppliers Processing is based on the performance of a contract and the organisation’s legitimate interests in operating its business effectively 7 years

 

  1. Roles and Responsibilities
    • The Federation’s Data Protection Officer is Judith Andrews, judith.andrews8@nhs.net.
    • The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Federation’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the Data Protection Legislation.
    • All Directors and Managers shall be directly responsible for ensuring compliance with the above data retention periods.
    • Any questions regarding this Policy, the retention of personal data, or any other aspect of Data Protection Legislation compliance should be referred to the Data Protection Officer.

 

  1. Implementation of Policy

This Policy shall be deemed effective as of 1st June 2023. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name:
Position:
Date: 1st June 2023
Due for Review by: June 2027