This Retention Policy applies to Cotton Parish Council (CPC) and covers all records and documentation, whether analogue or digital and are subject to the retention requirements of this Policy.
For the purpose of this Policy, the terms ‘document’ and ‘records’ include information in both hard copy and electronic form and have the same meaning whether referred to as Documents or Documentation.

This Policy will also aid paper records and electronic data storage issues identified and will eliminate the need to retain paper and electronic records unnecessarily. BPC will ensure that information is not kept longer than is necessary and will retain the minimum amount of information that it is required to hold to meet its statutory functions and the provision of its services.

Any such system or policies relating to record management will include a review of council documentation on an annual basis.
Anything that is no longer of use or value can be destroyed but if the council is in any doubt it will seek advice from Suffolk Association of Local Councils (SALC) and retain that document until that advice has been received.

Documents of historical importance, if not retained by the council, will be offered first to the county record office.

Retention of Documents

2.1 Attached is an Annex which indicates the appropriate retention period and the reasons for retention.

2.2 In respect of the retention of documents in case of a legal dispute, Council's policy is set out under Section 3.

2.3 Other documents not mentioned in the Annex will be treated as follows:

Planning Papers

  • Where planning permission is granted, the planning application, any plans and the decision letter will be retained until the development has been completed, so that, if necessary, the Clerk can check that the development proceeds in accordance with the terms and conditions of the permission.
  • Where planning permission is granted on appeal, a copy of the appeal decision will also be retained likewise
  • Where planning permission is refused, the papers will be retained until the period within which an appeal can be made has expired. If an appeal is made, and dismissed, the decision letter will be retained against further applications relating to that site.
  • Copies of Structure Plans, Local Plans and similar documents will be retained as long as they are in force.

Insurance Policies

  • Insurance policies and significant correspondence will be kept for as long as it is possible to make a claim under the policy.
  • Article 4 of the Employers Liability (Compulsory Insurance) Regulations 1998 (SI 2753) requires that local councils, as employers, retain certificates of insurance against liability for injury or disease to their employees arising out of their employment for a period of 40 years from the date on which the insurance is commenced or renewed.


  • If related to audit matters, correspondence will be kept for the appropriate period specified to the Annex thereto.
  • In planning matters correspondence will be retained for the same period as suggested for other planning papers.
  • All other correspondence will be kept for as long as the matter contained therein is still of interest or use to the council and or the parish.

Personnel matters

  • Article 5 of GDPR provides “personal data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed”. This Policy will ensure that necessary records, documents and electronic data of BPC are adequately protected, archived and disposed of at the correct retention period, and to provide all staff with clear instructions regarding the appropriate retention and disposal of such Documentation.

3. Retention of Documents for Legal Purposes

3.1 Most legal proceedings are governed by 'the Limitation Acts' which state that legal claims may not be commenced after a specified period. The specified period varies, depending on the type of claim in question.

3.2 The table below sets out the limitation periods for the different categories of claim.


Claims under category

Limitation period


6 years


1 year


6 years


12 years

Sums recoverable by statute

6 years

Personal injury

3 years

To recover land

12 years


6 years

Breach of Trust


3.3 If a type of legal proceeding falls into two or more categories, the documentation will be kept for the longer of the limitation period.

3.4 As there is no limitation period in respect of trust, the council will retain all trust deeds and schemes and other similar documentation.

  1. Retention of Encrypted Data

For any information retained under this Policy that is in an encrypted format, consideration must be taken for the secure storage of any encryption keys. Encryption keys must be retained for as long as the data that the keys decrypt is retained.

  1. Disposal of Documents or Documentation

Disposal can be achieved by a range of processes:

    • Any record containing confidential information must either be disposed of in a confidential waste bin or shredded using a cross-cut shredder.
    • Disposal of documents that do not contain confidential information may be disposed of in the normal way or recycled.
    • Deletion – where computer files are concerned
    • Transfer of document to external body - this method of disposal will be relevant

where documents or records are of historic interest and/or have intrinsic value. Such a third party could be the County Archivist or a local Museum.

  1. Disposal of Electrical Hardware

6.1 IT equipment and devices that have the ability and capability to store personal data include:

    • PC’s
    • Laptops
    • Mobile Phones
    • Multi-Functional Devices – printers / scanners
    • Servers
    • USB Memory Sticks and external hard drives.

6.2 IT equipment disposal must be managed by the Chairman in conjunction with the Proper Officer.

6.3 All computer equipment, recycling or refurbishing must be disposed of in accordance with the Waste Electric and Electronic Equipment Regulations 2013.

  1. Documenting Disposal

BPC will keep a record detailing the document disposed of, the date, and the officer who authorised disposal. In particular, the record should be able to demonstrate that the disposal was in accordance with this policy or set out the reasons for departing from it.

The table at Appendix 1 – Retention of Records Schedule sets out the limitation periods for the different categories of claim.

The table at Appendix 2 – Retention of Digital Records – provides the required retention periods for all digital Documents


APPENDIX 1 - Retention of Documents Required for the Audit of Parish Councils

DOCUMENT                              MINIMUM RETENTION PERIOD    REASON


Approved minutes                      Indefinite                                     Archive

Draft/rough/notes of minutes   Until minutes are approved           Management


Receipts and Payment Accounts   Indefinite                                 Archive      

Paid Invoices                               6 years                                      VAT

VAT Records                                6 years                                      VAT

Bank Statements                        Last completed audit year          Audit

Cheque book stubs                    Last completed audit year          Audit

Paying in books                          Last completed audit year          Audit

Scales of fees and charges       5 years                                        Audit


Permissions                                6 years                                     Compliance

Permissions on appeal Indefinite   Indefinite                              recedent

Permissions Commercial                 Indefinite                       Future Compliance

Refusals                                             2 years                         Appeals


Insurance Policies                            2 years                                                         Management

Certificates of Employers’               40 years                        Limitation period

Liability Insurance                                                                                  


Routine correspondence,

papers and email                          Until minutes are confirmed Retain as useful  

Quotations and tenders                  12 years/indefinite       Statute of limitations

Title deeds, leases, agreements    Indefinite                       Audit/management

and contracts,

APPENDIX 2 - Retention of Documents Required Relating to Information Technology In all cases identify the documents that need to be retained in accordance with the

Retention of records Schedule (attached at Appendix 1).





2 years

To satisfy customer complaints

Electronic Back Up Tapes

12 months

T o protect records from loss, destruction or falsification

Electronic files

3 years from date last used

T o protect records from loss, destruction or falsification

All portable / removeable storage media

At end of work cycle / project

Data shall be copied or stored on removable media only by authorized users in the performance of official duties

Cryptographic keys - access limited to user/role

Encryption keys must be retained for as long as the data that the keys decrypt is retained.