This Model Policy is a generic template that can be adapted for any jurisdiction or industry. Caveat: The retention periods listed in the Appendix A Records Retention Schedule are based on BC law and need to be modified in accordance with the ESA and other retention requirements of your particular jurisdiction.

1. PURPOSE

ABC Company management recognizes that HR records contain personal and other legally required information that must be maintained and may be needed under ordinary business circumstances as well as for litigation, audits, investigations, inspections and other legal proceedings and has adopted this Policy to ensure that such records are retained for as long as necessary and securely and properly destroyed or disposed of when they are no longer needed in accordance with employment standards, personal information and data protection and other applicable laws.

1. SCOPE

This Policy applies to all official HR records that ABC Company generates, shares or receives in the course of its operations, including, without limitation:

• Paper documents;
• Email, Web files, text files, PDF files and other electronic records and documents;
• Video or digital images;
• Graphic representations;
• Electronically stored information contained on network servers and management systems; and
• Recorded audio material, e.g., voicemail.

1. POLICY

All HR records are the property of ABC Company, and employees are expected to hold such records in confidence, keep them secure and refrain from disclosing them to others within or outside the Company without proper authorization. Employees must also return any HR records in their possession to the HR director upon termination of their employment

1. HR RECORDS RETENTION

ABC Company will retain HR records for as long as specified for that particular kind of record in the HR Records Retention Schedule attached to this Policy as Appendix A. The HR director and IT director will collaborate to appoint competent records management personnel to ensure implementation of the Retention Schedule. The responsibilities and duties of records management personnel will include, without limitation:

• Development and implementation of records retention processes;
• Monitoring federal and provincial laws affecting HR records retention and modifying the Retention Schedule from time to time as necessary to ensure continuing compliance; and
• Monitoring officers’, managers’ and employees’ compliance with ABC Company records retention and disposal requirements.

1. HR RECORDS STORAGE
   • ORGANIZATION OF HR RECORDS

The ABC Company HR department will, where practicable, take measures to ensure that its official records are organized and stored according to general categories in a manner that best facilitates the efficient implementation of this Policy and that records within each category are organized and stored in chronological order or by time period, e.g., by month or year.

• HR RECORDS

Categories of HR records not listed as being required to be retained on a permanent basis should be maintained by date or conspicuously dated to make such records easily identifiable for destruction at the end of the record retention period specified in the Retention Schedule.

• CONFIDENTIALITY OF HR RECORDS

HR records containing confidential information should be labeled and stored securely and in such a manner as to limit access to individuals with proper authorization to view the records. ABC Company personnel should recognize that all email, regardless of content, may be subject to disclosure in the course of government investigation or litigation involving the Company. While ABC Company understands that employees may use their business email to conduct personal business, email is provided for business use and ABC Company reserves the right to review employees’ email at any time. Employees should therefore have no expectation of privacy with regard to any information or communications contained in work-related email accounts.

• ELECTRONIC STORAGE SYSTEM

Records management personnel is authorized to develop and implement a system for maintaining ABC Company’s HR records via an electronic storage system that images hardcopy records or transfers computerized records to electronic storage media, e.g., hard drives, storage area networks, or optical media, such as CDs and DVDs.

1. HR RECORDS DESTRUCTION

HR records that have been retained for the applicable period listed in the Retention Schedule should be prepared for destruction using the processes established by records management personnel, e.g., shredding of paper documents and deletion of data contained on servers and hard drives, unless destruction is suspended due to litigation or legal proceedings in accordance with Section 7 below.

1. SUSPENSION OF DISPOSAL OF HR RECORDS FOR LITIGATION OR LEGAL PROCEEDINGS

Employees must direct any subpoena, court order or other request for HR records or questions regarding the release of ABC Company HR records they receive to [designated executive officer] before releasing such records or answering such questions. If any employee reasonably anticipates or becomes aware of litigation, governmental investigation or audit or any other legal proceeding involving ABC Company, he/she must notify the HR director or records management personnel. Upon receiving such

notification, disposal or destruction of HR records pertaining to the matter of the proceeding shall be immediately suspended until such time as [designated executive officer] or ABC Company legal counsel determines that destruction may resume.

APPENDIX A: HR RECORDS RETENTION SCHEDULE

This HR Record Retention Schedule sets forth an abbreviated schedule of key record-keeping holding periods based on BC law and is not intended to, and does not provide, either a complete compilation of all federal or provincial law retention periods for HR records or records involving other aspects of ABC Company operations.