Document Retention Policy
It is Signify Group (“Signify”) policy to maintain complete, accurate and high quality records. It is also our policy to delete all data not covered by exceptions or legal requirements set out in this policy after two years.
Records are to be retained for the period of their immediate use, unless longer retention is required for historical reference, contractual, legal or regulatory requirements or for other purposes as may be set forth below. Records that are no longer required, or have satisfied their required periods of retention, shall be destroyed. No officer, director, employee, contractor or volunteer of Signify shall knowingly destroy a document with the intent to obstruct or influence the investigation or proper administration of any matter within the jurisdiction of any government department or agency or in relation to or contemplation of any such matter or case.
This policy covers all records and documents of Signify. Signify reserves the right to amend, alter and terminate this policy at any time.
Responsibility for Administration
The Chief Data Officer (“CDO”) of Signify shall be responsible for administering this policy.
Statement of Policy
It is the policy of this organisation:
To comply with applicable legal and regulatory duties to retain documents.
To possess all documents needed for our normal business purposes, including administration of our ongoing business relationships.
Therefore, the organisation directs and expect all officers, directors, employees, contractors and volunteers to follow the rules and procedures set forth herein. Please be aware that “documents” includes not only documents in paper form, but e‐mail messages and all other forms of electronically stored information. Also be aware that the rules and procedures apply to all computers and other electronic devices provided to you by the organisation for use in the business of the organisation, regardless of whether those computers or devices are used on the organisation’s premises or elsewhere.
Rules and Procedures
From time to time, the Chief Data Officer may issue a “legal hold,” suspending the destruction of any records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. If and when you are informed of this by the CDO, do not discard any documents relevant to the subject matter of the lawsuit, investigation or proceeding.
You will be informed of the specific types of documents that are relevant and must be retained for these purposes by the Chief Data Officer. Until that point in time, do not discard any document that may be relevant without the written approval of the Chief Data Officer. If in doubt, save the document. In all other circumstances, you must retain the documents listed the schedule below for the periods of time set forth on that schedule. The schedule reflects our legal obligations for document retention.
Please note that the information listed in the schedule below is intended as a guideline and may not contain all the records Signify may be required to keep in the future. Questions regarding the retention of documents not listed in this schedule should be directed to the Chief Data Officer. Please note that failure to follow this policy can result in possible civil and criminal sanctions against Signify and its officers, directors and employees, and possible disciplinary action against responsible individuals, up to and including termination of employment.