Procedure for Safeguarding Organizational Records

Details

DateVersionStatusInformation ClassificationDocument Template IDDocument No
06-11-20191.0ApprovedInternalAMS DOCAMS-SP-31

Revision History

DateVersionDescriptionAuthorReviewed byApproved byApproved date
29-10-20191.0Initial VersionShaila, UshaAMFSuresh Kumar06-11-2019

Acronym Used

AcronymExpanded Form

Introduction

Organizational records are vital for the functioning of the business.  This procedure defines process for identifying organizational records and appropriate controls implemented to safeguard them.

Scope

Organizational records are defined as those required primarily for statutory and regulatory requirements. In addition, this procedure is applicable for all accounting records, payroll files and personnel files.

ISO27001 Control Reference

  • A.18.1.3 Protection of records

  • A.18.1.4 Privacy and protection of personally identifiable information

Key Practices & Responsibility

The key practices and responsibilities are as follows:

Srl.Key PracticeResponsibility
Identify Organizational RecordsAsset Owner, Head – Function
Controls for Safeguarding Organizational RecordsAsset Owner, Head – Function

Key Practice Details

Identify Organizational Records

  • The asset owner in consultation with Head - Function will identify and document all the organizational records of the department.  The details to be obtained for each record include:

    • Name of Record

    • Type of Record (Electronic/Paper)

    • Record/Asset Owner

    • Location of Record

  • All Organizational records will be classified as "Confidential" and receive the level of protection defined in the Procedure for Information Classification and Handling.

  • The Inventory of Information Assets will detail the organizational records and the appropriate retention period.

Controls for Safeguarding Organizational Records

  • All organizational records in hard copy format will be locked and the list of users requiring access to the record will be documented.

  • Organizational records that cannot be easily replaced will be stored in fireproof cabinets and a copy will be maintained in an offsite location. 

  • Employee personnel files will be safeguarded from unauthorized access as they contain personal information about the employee. 

  • The electronic records will be shared only on a need basis to identified individual and read-only access will be provided.

  • Wherever, employee records are required to be shared/furnished to an external agency, the same shall be done on the basis of a proper agreement that restricts its use to intended purposes and bound by adequate confidentiality safeguards. This shall not apply to information furnished to government agencies and other professionals organizations that are bound by confidentiality requirements laid down by law or professional bodies.

  • The retention period will be defined for all organizational records and the destruction/disposal of the records will be commensurate with the classification of the record. The table below indicates the sample record types and their retention periods, which are applicable to ASL's information assets:

Record TypeRetention Period
ACCOUNTING AND FINANCE
Accounts Payable ledgers and schedules7 years
Accounts Receivable ledgers and schedules7 years
Annual Audit Reports and Financial StatementsPermanent
Annual Plans and Budgets2 years
Bank Statements and Canceled Checks7 years
General LedgersPermanent
Bills invoices and other transactional records7 years
CONTRACTS
Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supporting documentation)7 years after expiration or termination
CORPORATE RECORDS
Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, bylaws, annual corporate reports)Permanent
Licenses and PermitsPermanent
ELECTRONIC DOCUMENTS
Electronic Mail1 Year
Electronic Documents6 years
Critical Logs(All authentication access logs, Change management, Firewall changes, Network configuration changes like VLAN, Security policy changes i.e. AD group policy)1 Year
Web Page Files: Internet Cookies1 month
INSURANCE RECORDS
Certificates IssuedDuration of the policy and subsequent claim period allowed
Claims Files (including correspondence, medical records, injury documentation, etc.)2 years after final settlement
Group Insurance Plans – Active EmployeesUntil Plan is amended or terminated
Group Insurance Plans – RetireesPermanent or until 6 years after death of last eligible participant
Records of Inspections of records by Statutory agencies3 years
Insurance Policies (including expired policies)Duration of the policy and subsequent claim period allowed
LEGAL FILES AND PAPERS
Legal Memoranda and Opinions7 years after close of matter
Litigation Files1 year after expiration of time allowed for appeals or time for filing appeals
Court OrdersPermanent
Statutory Records(EPF,ESI, Gratuity etc)7 years
PAYROLL DOCUMENTS
Labor Distribution Cost Records7 years
Payroll Registers7 years
PERSONNEL RECORDS
Commissions/Bonuses/Incentives/Awards7 years
Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records)6 years after separation
Employment Records- Correspondence with Employment Agencies and Advertisements for Job Openings3 years from date of hiring decision
TAX RECORDS
Tax-Exemption Documents and Related CorrespondencePermanent
Payroll Tax Records7 years
Tax Bills, Receipts, Statements7 years
Tax Returns Income, Franchise, PropertyPermanent
MISCELLANEOUS
Policy and Procedures Manuals – OriginalCurrent version with revision history
Policy and Procedures Manuals CopiesRetain current version only
Annual ReportsPermanent
Internal Audit Records7 Years
Project RecordsTill project completion

Audits and Training

  • The evidences of Safeguarding Organizational Records like record retention period will be verified by the periodic internal audits.

  • If significant changes are made to the procedure on Safeguarding Organizational Records, the Quality Group along with function heads, in coordination with Training Function, conduct training sessions to train the affected groups or send communications to the affected group based on the criticality of the changes.

References

Srl.Document/Section Name
Procedure for Information Classification and Handling