TargetCW Privacy
Global Privacy & Data Protection Office

Document Retention

Document/Data Retention 

Purpose

The human resources (HR) department retains and destroys personnel records in accordance with TargetCW's corporate policies on business records retention, as well as federal and state laws governing record retention. Below is an outline of the HR department's operating procedures for personnel record retention and destruction of documents when such retention periods have passed. If TargetCW's retention procedure is not of sufficient duration for any state in which the company does business, this procedure will be superseded by state requirements.

The HR department maintains both employee record information and government compliance reports. Both are subject to the following retention requirements and destruction procedures.

This policy is also designed to be in compliance with Article 30 of the GDPR which address the concept of disciplined destruction of personal data no longer in use. In addition this policy covers PIPEDA in Canda; And Argentina Personal Data Protection Act 25,326. TargetCW realizes that the needs of HR organizations are different than those of other types of organizations, and as such our policies will meet the needs of government agencies first; although we may not need the data, government entities may call upon us for such data. 


Maintenance of Employee Records

The following employee information records are maintained in segregated personnel files:

1) Pre-employment testing results and background check information.
2) I-9 forms electronically stored in SN
3) Benefits plan and employee medical records electronically stored in our benefits portal
4) Health and safety records are in the HR file as needed in Tempworks
5) General employee personnel records are in Tempworks

Government compliance reports are maintained in Tempworks as well. 


Destruction of Employee & Applicant Records

All paper personnel records and confidential employee data maintained by the HR department will be destroyed by shredding after retention dates have passed; this procedure pertains to all personnel records, not just those governed by the Fair and Accurate Credit Transactions Act (FACTA).

Employment application materials submitted by applicants who were never employed are also to be shredded.

Hardcopy confidential records may be shredded using a locked shredder on the TargetCW premises. In the case of remote employees, employees are discouraged from printing out or creating hard copies of confidential records where possible. If hard copies must be printed, created or kept, they should be stored in a locked cabinet, drawer or other secure location until they are no longer needed, or until the maximum retention period has ended. Remote employees must then destroy all confidential files by shredding them in a locked shredder on the TargetCW premises, or otherwise rendering the documents unusable or unreadable.

Personnel records include electronic as well as paper records. The HR department will work with the IT department periodically but no less than twice annually to review and ensure that the HR department's electronic records relating to employee information and compliance reports are properly purged.


Litigation Hold

 

When TargetCW is involved in or anticipates that it may be involved in litigation, the General Counsel's office will issue a litigation hold. This means that all documents relating to the litigation matter must be kept in order to preserve any potential evidence. If we fail to do so, TargetCW can be sanctioned by the court for destroying evidence. A court has broad authority to impose these sanctions, which may include anything from unfavorable procedural rulings during a trial to payment of monetary damages.

In the event that the TargetCW General Counsel announces a litigation hold on any or all TargetCW records as a result of pending or anticipated litigation, all records covered by such litigation hold MUST NOT be discarded, deleted or destroyed. Further, the IT department will suspend the automatic deletion of emails for all individuals covered by the litigation hold. Any questions about the litigation should be directed to the General Counsel.


Data Destruction & Anonimization

 

HR along with the IT and Information security department is responsible for destroying data based on the appropriate retention period or if a employee, contractor or worker requests that certain information be deleted. Since laws differ by country and state, TargetCW will generally use the most generous data for general data deletion as permitted by law. 

For international workers employed by a third party vendor, TargetCW will onward employment data and upon satisfactory transmission and employment and completion of assignment; the following will be destroyed or randomized: DOB, Tax ID Number, banking information. This scripted process will occur on a semi-annual basis.  

For US/UK/Canada and new employment entities that employ workers directly through TargetCW. After satisfaction of workers assignment, TargetCW will maintain all records in Tempworks for a period of no more than 7 years, but no less than 3 years depending on the state and type of information. This will occur on an annual basis. Within StaffingNation, after completion of an assignment, SSN, DOB and banking information will deleted or randomized after a 1 year period of time. This will occur on a semi annual basis.

For 1099's or independent contractors, full files will be deleted 4 years after issuance of the 1099 document. 

For applicants where personal information is collected, personal data like SSN and DOB will be deleted 6 after the last active job requisition assignment or the request of the candidate which ever comes sooner. This will happen on a semi-annual basis.