We will keep Personal Data only for as long as the retention of such Personal Data is deemed necessary for the purposes for which that Personal Data are Processed and in accordance with our Records Management Policy.
HBFI is required to keep records for prescribed periods of time, ranging up to 7 years following the conclusion of the business relationship (and in certain cases, permanently), for example:
- For the purposes of handling potential claims and for record-keeping purposes:
- Personal data contained within expressions of interest (which do not progress to application stage) and unsuccessful loan applications are retained for up to two years
- Where an individual makes a complaint, we will hold records regarding the complaint for 3 years after the complaint is closed.
- Where an individual makes a Loan Appeal, such records will be retained for 7 years
- Information relating to third parties (e.g. customers, service providers) is kept for up to 7 years following the conclusion of the business relationship, e.g. Loan applications.
- Personal data in relation to unsuccessful candidates and unsuccessful tenders is anonymised or deleted after 12 months.
- Final audit reports are retained permanently
- Board and Committee minutes are retained permanently
- In line with Government guidance and best practice, records relating to FOI requests, AIE requests and general queries are kept for 7 years after the complaint is closed (with records relating to general queries being anonymised thereafter), while responses to parliamentary queries are kept permanently.
- Records of calls are kept for up to 2 years for record-keeping and complaint management purposes.