Are You Holding Employee Data Too Long? UK GDPR Says Think Again
Professional services firms often retain employee data longer than necessary. Here’s what UK GDPR requires and how to mitigate risk.
Employee data is a compliance blind spot for many professional services firms. From CVs and appraisal notes to disciplinary records, HR systems often store personal data far beyond its useful life — and well beyond what the UK GDPR permits.
The law is clear: personal data must not be kept “for longer than is necessary.” But what counts as “necessary”? It depends on the purpose — not convenience.
Common risk areas include:
- Old interview records kept ‘just in case’
- Ex-employee documents retained indefinitely
- Emails containing personal data archived without review
What you should be doing:
- Establish clear retention periods for HR records
- Automate deletion or anonymisation where possible
- Regularly audit storage locations (including emails and shared drives)
Heads of compliance and HR teams must collaborate to align data retention policies with legal obligations. Over-retention not only increases the risk of a breach — it also signals poor data governance to regulators and stakeholders alike.
Tip: Document your retention schedules as part of your Record of Processing Activities (ROPA). It’s not just good practice — it’s required under Article 30 of UK GDPR.
