Record Retention Policy
1. Summary
AiFi will retain records and data as needed to satisfy business needs and applicable laws and regulations.
2. Applicability
This Policy applies to AiFi, Inc. (“AiFi”), its subsidiaries, and other entities controlled by AiFi.
3. Policy
Retaining necessary records and data is a routine part of business, enabling AiFi to conduct its business effectively and to respond accurately and in a timely manner to internal and external customer demands. However, retaining unnecessary records and data in any form complicates and delays the retrieval of important information and wastes limited resources such as storage capacity and filing space.
AiFi and its functional departments will ensure that records and data are retained, reviewed, stored, and disposed of systematically, as necessary to satisfy business needs and the requirements of applicable laws and regulations.
AiFi and its functional departments shall implement procedures meeting the requirements of Exhibit 1.
5. Review
This Policy shall be reviewed at least annually and following any major changes to ensure that this Policy continues to meet its organizational goals.
Exhibit 1
1. AiFi, its subsidiaries, and other entities controlled by AiFi, Inc. will ensure that records and data are retained, reviewed, stored, and disposed of systematically and in the regular course of business after considering business needs and the requirements of applicable laws and regulations.
2. "Records and data" mean:
a) Written, recorded, or graphical material of any kind in the possession or control of AiFi or its directors, officers, or employees in the course of their duties;
b) The term includes data in any medium, such as paper, recordings, or electronic files (whether stored on a network server, individual computer hard disk, or separate disk from which information can be obtained by any means)
3. AiFi will adopt procedures addressing the following minimum requirements:
a) Appointing a records and data custodian who has overall responsibility for administering this Policy. Additional custodians may be appointed when needed to respond to document requests involving litigation or investigations;
b) Creating and maintaining an index of types of records and data (“Record Retention Table”) that are in the possession or control of AiFi. This will describe generally the types of records and data to be retained. Records and data will be assigned proper periods for retention, determined in accordance with the laws, regulations, and treaties applicable to the locations where AiFi is operating;
c) Destroying records and data in the regular course of business and in accordance with the requirements of applicable laws and regulations. Destruction of records reasonably related to a matter will be stopped if AiFi knows or has a reasonable basis to believe that litigation, a government investigation, or an audit is pending or imminent.
d) Random and scheduled reviews to ensure that records and data are being disposed of in accordance with the requirements of this Policy. AiFi will review retention procedures and practices as part of its normal audit process, and
e) Providing periodic training to employees in the requirements of this Policy. Training may be provided via disseminating written policies or procedures, computer-based courses, or any combined training methods used by AiFi.
4. Questions on implementing or interpreting this Policy should be directed to the Legal Team to legal@aifi.com.
Record Retention Table
| Category | Record Type | Record Description | Duration |
| Mail | Exchange mailboxes | Items in user, shared, and resource mailboxes: emails, calendar items with an end date, notes, and tasks with an end date. Doesn't apply to items in Microsoft 365 Group mailboxes. | 1 year |
| SharePoint | SharePoint classic and communication sites | Files in classic sites or communication sites or team sites that aren't connected to a Microsoft 365 group, and files in all document libraries (including default ones like Site Assets). | 2 years |
| Accounting and Finance | Annual Financial Reports and Work Papers | | 3 years |
| Accounting and Finance | Billing Records | | 3 years |
| Taxes | Income Tax Returns and Sales Tax Returns | | 3 years |
| Marketing | Customer Contact Details | Email address, phone number, Company | 7 years |
| Marketing | Event Signup | | 1 year |
| Marketing | Demo signup | Name, email address, position, company | 1 year |
| Marketing | Toll-free numbers | Name, address, phone number | 1 year or when data request for deletion is closed. |
| Human Resources | Contact Details | Address, email address, phone number | Permanent and deleted 30 days after termination. |
| Human Resources | Emergency Contacts and Next of Kin | Names, relationship to the employee/contractor, contact numbers | Permanent and deleted 30 days after termination. |
| Human Resources | Employment Information | Job title, department, employee ID, work history | Permanent |
| Human Resources | Personal and Social Circumstances | Marital status, dependents | Permanent |
| Human Resources | Criminal Record Information | Details of criminal convictions and offences | No retention after audit |
| Human Resources | Financial Information | Bank account details, tax information | Permanent |
| Human Resources | National Identification Numbers | Social security number, Passport, national insurance number | Permanent and deleted 30 days after termination. |
| Human Resources | Health Information | Health records, disability information, sick leave records | Permanent |
| Human Resources | Qualifications | Educational records, resumes, certifications, training records | Permanent |
| Human Resources | Applications | Resumes, personal information, qualifications, contact details | 1 year |
