Data Retention Policy

Data Retention Policy (for clients). Lily Head Dental Practice Sales (LHDPS) is committed to protecting and respecting your privacy. LHDPS is registered under the Data Protection Act 1998 Number: ZA166759. For further information please visit the Information Commissioners Website at www.ico.org.uk. If you have any questions regarding this Policy you should contact LHDPS in the first instance via team@lilyhead.co.uk or to the following address: The Data Protection Manager Lily Head Dental Practice Sales The Old Post Office High Street Harbury CV33 9HW Introduction

Information and data is one of our key corporate assets. In the course of carrying out our various functions, LHDPS accumulates information from both individuals and external organisations. LHDPS also generates a wide range of data, which is recorded in documents and records. LHDPS strives to maintain data in accordance with the Data Protection Act.
These documents and records are in several different formats, examples of which include, (but are not limited to) letters, emails, attendance notes; financial information including invoices, statements and reports; legal documents such as contracts, leases and deeds; and information relating to landlords, vendors, purchasers and other individuals taking an interest in dental practices.
For the purposes of this Policy, the terms ‘document, data and records’ include information in both hard copy and electronic form.
In certain circumstances, it will be necessary to retain specific documents in order to fulfil statutory or regulatory requirements and to meet justifiable operational needs. Document retention may also be useful to evidence events or agreements in the case of disputes, and to preserve information which has historic value. LHDPS has developed this Policy with the intention of benefitting LHDPS and the data subjects to strike a careful balance between legal obligations, operational efficiency and retention of data for periods which are reasonable and appropriate in the circumstances.
LHDPS will retain some data and forms of information for longer than others. In line with principle 5 of the Act, information is not sought to be kept longer than is necessary.
The retention of all documents and records is impractical and appropriate disposal forms an important aspect of this Policy. Disposal will assist LHDPS to maintain electronic and office storage space and will de-clutter office accommodation. LHDPS operates a “paper light” approach to hard copy documents with most records being retained electronically rather than as hard copies.

LHDPS’s Retention Policy schedule is a tool used to ensure the retention of business information, personal data and sensitive personal data for as long as it is needed and justified in accordance with our balanced approach referred to in paragraph 4 above. LHDPS is keen to be transparent and proactive and provide data subjects with transparency on how data will be retained by LHDPS and ultimately destroyed. This Document Retention Policy should be read in combination with our Privacy Policy https://www.dentalpracticesales.co.uk/privacy-policy/. It takes account of the context within which LHDPS operates, including the legal and regulatory environment, for example compliance with the fifth data protection principle, the expectations of stakeholders and LHDPS’s ongoing legal obligations. It is intended primarily as a resource to inform you about how data is held, processed, archived and destroyed to enable disposal activity to be carried out in a consistent and controlled manner. A table containing the intended retention period is given for each relevant data category. The retention period applies to all records in that category default, and will be adhered to wherever possible, although it is recognised by LHDPS that there may be exceptional circumstances which require documents to be kept for either shorter or longer periods. In addition, it should be noted that, in line with the Act and LHDPS’s obligation to implement appropriate physical and technical security measures, the data and information held by LHDPS electronically is backed up at least daily. These back up copies are maintained indefinitely and in accordance with LHDPS’s Security Policy to ensure the consistency and stable framework upon which LHDPS operates its business. On this basis these back up copies are unaffected by the retention periods for each relevant data category which form part of this Policy. The data set which forms part of each backup copy will be unaffected by the retention periods and action taken in line with the retention periods as referred to below. Retention periods also apply to all formats of records, i.e. paper and electronic, unless specifically stated otherwise. The primary factors that inform decisions on retention are:

Business need.
Services provided to our customers.
Provision of professional business agency and associated activities.
Our experience of when retention of information and data is likely to be beneficial to the data subject as relevant to the specific services they seek from LHDPS, including business agency services.
Legislative and regulatory requirements – for example compliance with the fifth data protection principle. Where relevant legislation is listed.
Informed and express consent of the data subject.

In our experience, data subjects are often keen to consent to LHDPS maintaining data and information beyond the periods referred to as part of this Policy. The reason and justification for these extended periods of retention, by way of example, can include:

Provision of extended record keeping services.
Removing an administrative burden from data subjects.
Enabling an ease of operation between LHDPS and the data subject.
Maintaining an ongoing business relationship, which may be limited to matters such as a data subject’s ongoing interest in the dental business market, beyond the periods maintained as part of the Policy.

It is therefore not unusual for data subjects to provide free and unambiguous consent to LHDPS to retain data beyond the periods forming part of this Policy. Data Retention Schedule – (Summary)

Data Category	Records Held	Retention Timescales	Purpose of Retention	Action following Retention
Dental Practice Sales	Prospective Purchaser	Indefinetely	May take several years before they purchase	Archive
Dental Practice Sales	Prospective Vendor	Indefinetely	May take several years before they purchase	Archive
Dental Practice Sales	Active Vendor	Until completion / termination	Property Sales can take time	Archive
Dental Practice Sales	Archived Prospective Purchaser	4 years	Not a meaningful buyer	Destroy / Anonymised
Dental Practice Sales	Archived Vendor	4 years	No longer a business relationship	Destroy / Anonymised
Dental Practice Sales	Offer Details	Current +6	Legal Compliance	Destroy / Anonymised
Dental Practice Sales	Referencing Details	Current +6	Legal Compliance	Destroy / Anonymised
Dental Practice Sales	Deposit Scheme Information	Current +6	Legal Compliance	Destroy / Anonymised
Financial Records	Tax information, accounts	Current +6	Legal Compliance	Destroy / Anonymised
Client & money laundering information	Copies of passports, GDC # & Proof of Address	5 years from the end of the business relationship	Legal Compliance	Destroy / Anonymised
Dental broker relevant information	Offer Details, deposit information, Memorandum of Sales	Current year +6	Legal Compliance	Destroy / Anonymised