Record retention and information handling

Do not use one deletion date for everything

Appendix D generally requires worker records throughout sponsorship and afterwards until the earlier of one year after sponsorship ends or a compliance officer’s examination and approval. Other legal purposes may require longer retention. Licence-application records are generally kept while licensed.

• Identify separately the sponsorship, right-to-work, payroll, employment and legal-hold purposes.
• Record the applicable rule and trigger for each document class.
• Check ongoing disputes or legal holds before authorising deletion.

Operate a restrained evidence register

Recommended practice: keep documents in controlled storage and use the public planning tools with case references only.

• Give access according to role and remove it when staff leave.
• Record evidence transfers and keep secure backups with a tested recovery route.
• Review retention rules when guidance or the underlying purpose changes.

Suggested retention decision record

Create a schedule by document class and purpose, then link each case to the relevant trigger. Include the rule or policy reviewed, the responsible decision maker and the date the decision should be revisited. An employment end date, sponsorship end date and dispute closure date may belong to different records; preserve those distinctions rather than selecting one convenient date for the whole folder.

Place proposed disposals into a review queue. Before approving deletion, check for unresolved enquiries, complaints, investigations or preservation instructions and record the outcome.

• Identify authoritative records, working copies and backup copies separately.
• Record who can approve disposal and how completion is evidenced.
• Revisit the schedule after a source change or a new information purpose.

Suggested access and recovery test

Choose a small set of sensitive records and inspect who can access them in practice. Shared mailboxes, exported spreadsheets and old staff accounts can broaden access beyond the intended team. Record unnecessary access and give an owner the task of removing it through the organisation's approved process.

Test recovery of a sample record from the agreed backup arrangement without exposing it to unnecessary recipients. Keep the recovery result and any limitation. A backup that exists but cannot be restored is weak evidence of continuity. Deletion planning should also account for how the organisation handles retained backup copies.

Fictional practice scenario

A fictional employer's automated storage rule proposes deleting a former worker's folder. The reviewer finds an open employment dispute and a separate right-to-work record purpose. The proposed deletion is paused while the appropriate owners establish what should remain and why.

The exercise produces a documented retention decision and a later review date. It does not prescribe a new legal retention period or imply that keeping every document indefinitely is justified.