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Data Protection & Retention Policy

[Company registered name] (“the Company”)  ·  ICO registration: [ICO reg. number]  ·  Data protection contact: [name / email]
Version 1.0  ·  Effective: [date]  ·  Next review: [date + 12 months]

1. Purpose & scope

This policy sets out how the Company collects, uses, stores, secures and disposes of personal data in line with the UK GDPR and the Data Protection Act 2018. It applies to all personal data processed through the Mostlane Portal and related systems, covering employees, workers, contractors and customer contacts.

2. Roles

The Company is the data controller. Day-to-day responsibility sits with [name / role]. The Company is not required to appoint a statutory Data Protection Officer but has designated the above person as the point of contact for data protection matters.

3. Data protection principles

The Company processes personal data: lawfully, fairly and transparently; for specified purposes only; limited to what is necessary; kept accurate; retained no longer than necessary; and kept secure.

4. Personal data we hold & lawful basis

CategoryExamplesLawful basis
Staff recordsName, username, email, phone, permissions, pay rateContract; legal obligation
Working timeClock in/out, timesheets, shifts, holidayLegal obligation (Working Time Regs); contract
Employment documentsContracts, letters, policies (in the staff documents area)Contract; legal obligation
Job & site recordsJob notes, photos, signatures, site & customer contactsContract; legitimate interests
Security dataLogin history, IP address, device records, audit logLegitimate interests (system security)

5. Retention periods

Personal data is kept only as long as necessary for the purpose or as required by law, then deleted or anonymised.

RecordRetention periodReason
Payroll, pay & working-time records6 years after the tax yearHMRC / statutory
Holiday & shift history6 yearsWorking Time Regulations
Employment contracts & HR file6 years after leavingLimitation Act / disputes
Job sheets, site photos, signatures6 years after job completionContract / liability
Login history, IP, device records, audit log12 months (auto-pruned)Security; data minimisation
Unsuccessful applicants / leavers’ accessAccess removed immediately on leavingData minimisation

The portal automatically prunes its security audit log and login history at 12 months. Longer-retained records (payroll, HR, job history) are reviewed annually and deleted or anonymised once their period expires.

6. Security measures

7. Your rights

Individuals have the right to be informed, to access their data, to rectification, to erasure, to restrict or object to processing, and to data portability. The portal provides a one-click data export (access/portability) and erasure (anonymise & close) for each person, via My Documents (administrator function). Requests should be sent to [contact email] and will be answered within one month.

8. Personal data breaches

Any suspected breach must be reported immediately to [contact]. Where a breach is likely to result in a risk to individuals, it will be reported to the ICO within 72 hours of becoming aware, and affected individuals informed where the risk is high.

9. Processors & international transfers

The Company uses the following processors, each under a data processing agreement. Where data is transferred outside the UK, an approved safeguard (UK adequacy or the International Data Transfer Agreement) applies.

ProcessorPurpose
CloudflareHosting, database (D1), file storage (R2)
ResendTransactional email (password / welcome)
Google Maps PlatformMapping & geocoding of site addresses
PDFShiftGenerating job-sheet PDFs
[others as applicable]

10. Review

This policy is reviewed at least every 12 months, or sooner if the law or our systems change materially.

Signed: [name]  ·  Position: [role]  ·  Date: [date]