The Corporate Retention Policy serves as a crucial governance document that ensures organizations maintain their records in compliance with Hong Kong's legal and regulatory requirements. This policy becomes necessary when organizations need to systematically manage their records, protect sensitive information, and ensure compliance with various ordinances including the Personal Data (Privacy) Ordinance (Cap. 486), Companies Ordinance (Cap. 622), and other relevant legislation. The Corporate Retention Policy establishes clear guidelines for retention periods, storage methods, and destruction procedures for different types of corporate records, while considering both physical and electronic formats. It helps organizations minimize legal risks, optimize storage costs, and maintain efficient access to important documents.
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1. Purpose and Scope: Outlines the objectives of the policy and its application across the organization, including all types of records covered
2. Definitions: Defines key terms used throughout the policy including types of records, retention period, destruction, archiving, and legal hold
3. Legal and Regulatory Framework: References to Hong Kong laws and regulations that govern record retention requirements
4. Roles and Responsibilities: Defines responsibilities of different stakeholders (management, employees, IT, legal department) in implementing the policy
5. Record Classification: Categories of records and their business importance (vital, important, useful, non-essential)
6. Retention Periods: General principles for retention periods and reference to detailed retention schedule
7. Storage and Protection: Requirements for secure storage of both physical and electronic records
8. Legal Hold Procedures: Process for implementing and managing legal holds on records
9. Disposal and Destruction: Procedures for secure disposal of records after retention period expires
10. Policy Compliance: Monitoring and enforcement of the policy, including audit procedures
11. Review and Updates: Process for periodic review and updating of the policy
1. Electronic Records Management: Detailed section specifically for electronic records management systems and digital preservation - include if organization heavily relies on electronic records
2. Cross-Border Data Transfers: Section dealing with retention requirements for international data transfers - include if organization operates internationally
3. Industry-Specific Requirements: Additional requirements for regulated industries - include if organization is in financial services, healthcare, or other regulated sectors
4. Disaster Recovery: Procedures for protecting and recovering records in case of disasters - include if organization handles critical records
5. Third-Party Service Providers: Requirements for records held by third-party vendors - include if organization outsources record storage or processing
1. Schedule A - Retention Periods by Record Type: Detailed matrix of record types and their specific retention periods
2. Schedule B - Record Classification Guide: Detailed guide for classifying different types of records
3. Schedule C - Destruction Certificate Template: Template for documenting authorized destruction of records
4. Schedule D - Legal Hold Notice Template: Standard template for implementing legal holds
5. Appendix 1 - Records Inventory Form: Template for conducting records inventory
6. Appendix 2 - Compliance Checklist: Checklist for periodic compliance review of retention practices
7. Appendix 3 - Key Contacts: List of key personnel responsible for records management
8. Appendix 4 - Regulatory Requirements Summary: Summary of relevant Hong Kong regulatory requirements and retention periods
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