CKB Ltd Data Retention Policy November 2024

1. Introduction

This Policy sets out the obligations of CKB Ltd ® and its group brands including Lanyards Tomorrow ®, Gifts Tomorrow ™ and Bar Amigos ® (“the Company”), a Company registered in England under 07123102 (VAT number 991324508), whose registered address is St. Christopher's House, Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England and whose main trading address is Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS, regarding retention of personal data collected, held, and processed by the Company in accordance with the UK Data Protection Act 2018 and UK-GDPR (General Data Protection Regulation). The UK GDPR is the retained EU law version of the EU GDPR (2016/679) as it forms part of the law of England and Wales, Scotland and NI by virtue of Section 3 of the EU (withdrawal) Act 2018.

The UK GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person which is in the possession of, or is likely to come into the possession of the data controller (the Company in this context).

The UK GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation. The Company does not handle such data in respect of customers but does for employees.

Under the UK GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the UK GDPR to protect that data).

In addition, data protection legislation includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

a) Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
b) When the data subject withdraws their consent;
c) When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
d) When the personal data is processed unlawfully (i.e. in breach of the UK GDPR);
e) When the personal data has to be erased to comply with a legal obligation; or
f) Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company and third party organisations it uses, the period(s) for which that personal data is to be retained before it is deleted or otherwise disposed of and the criteria for establishing and reviewing such retention period(s) if applicable.
For further information on other aspects of data protection and compliance with the UK GDPR, please refer to the Company’s Data Protection Policy/ Employee Data Protection Policy (as applicable).

2. Aims and Objectives
2.1 The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under data protection legislation. This policy applies to both employee and non-employee data subjects. Employee data subjects may be required to provide their details to third party firms (e.g. suppliers) for the purpose of undertaking their role and, as such, the Appendix to this document may not list every interaction which is covered separately under an employee data consent form.
2.2 In addition to safeguarding the rights of data subjects under data protection legislation, by ensuring that excessive amounts of data are not retained by the Company without adequate justification, this Policy also aims to improve the speed and efficiency of managing data.

3. Scope
3.1 This Policy applies to all personal data held by the Company. Please note that any third-party data processors processing personal data on the Company’s behalf will have their own data privacy and data retention policies. The Company has sought to check third party compliance with the UK GDPR/ data protection legislation and an overview of third party involvement is contained in the Appendices to this policy. Please note, however, that whilst supporting transparency, the Company also needs to be mindful of its requirement to protect its business knowledge and security. Should a data subject wish to enquire further about details of third parties the Company works with, etc., please contact the Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS. Please also note that this policy does not cover third party operated marketplace sites which the Company may sell goods on such as Amazon which non-employee data subjects may purchase from.
3.2 Personal data, as held by the Company is/ may be stored in the following ways and in the following locations:
a) Computers permanently located in the Company’s UK premises and laptop devices;
b) Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with the Company’s Bring Your Own Device (“BYOD”) Policy;
c) Physical records stored in the Company’s UK premises; and
d) Third party companies processing personal data such as review companies are contained in the Appendix to this policy. The Company also makes use of a third-party server located in the UK (back up files for disaster recovery purposes may be securely stored in the EU meeting data protection requirements) and a third party electronic file share and storage system is data protection (including GDPR) compliant if stored outside the EU. Please refer to the Appendix.

4. Data Subject Rights and Data Integrity
All personal data held by the Company is held in accordance with the requirements of the UK GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy/ Employee Data Protection Policy.
4.1 Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).
4.2 Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability if possible, and further rights relating to automated decision-making and profiling.

5. Technical and Organisational Data Security Measures
5.1 The following technical measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy/ Employee Data Protection Policy for further details:
a) All emails containing personal data must be encrypted;
b) Personal data may only be transmitted over secure networks;
c) Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
d) Personal data contained in the body of an email, whether sent or received, should be stored securely;
e) Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
f) Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using a secure method of delivery;
g) All personal data transferred physically should be transferred in a suitable container marked “confidential”;
h) No personal data may be shared informally and, if access is required to any personal data, such access should be formally requested from the Company Director;
i) All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
j) No personal data may be transferred to any employees or other parties, whether such parties are working on behalf of the Company or not, without senior authorisation;
k) Personal data must be handled with care at all times and should not be left unattended or on view;
l) Computers used to view personal data must always be locked before being left unattended;
m) No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the Company Director and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary. Please refer to the Company BYOD Policy;
n) All personal data stored electronically should be backed up regularly with backups stored offsite. All backups should be encrypted;
o) All electronic copies of personal data should be stored securely using passwords and encryption;
p) All passwords used to protect personal data should be changed in line with the Company Information Security Policy and should be secure;
q) Under no circumstances should any passwords be written down or shared between any employees or other parties working on behalf of the Company, irrespective of seniority or department;
r) All software should be kept up-to-date. Security-related updates should be installed in line with the Company Information Security Policy; and
s) No new software may be installed on any Company-owned computer or device without approval.
Please refer to the Company Information Security Policy.

5.2 The following organisational measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy/ Employee Data Protection Policy for further details:
a) All employees or relevant other parties working on behalf of the Company can view both their individual responsibilities and the Company’s responsibilities under data protection legislation in the Company’s Data Protection Policy;
b) Only employees or other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;
c) All employees handling personal data will be appropriately trained to do so;
d) All employees handling personal data will be appropriately supervised;
e) All employees and other parties working on behalf of the Company handling personal data shall be expected and encouraged to exercise care and caution when discussing any work relating to personal data at all times;
f) Methods of collecting, holding, and processing personal data shall be regularly reviewed;
g) The performance of those working on behalf of the Company handling personal data shall be subject to review;
h) All employees or relevant other parties working on behalf of the Company handling personal data will be expected to do so in accordance with the principles of data protection legislation and the Company’s Data Protection Policy;
i) All parties working on behalf of the Company handling personal data must ensure that any and all of their employees are held to the same conditions arising out of data protection legislation and as contained in the Company’s Data Protection Policy;
j) Where any party working on behalf of the Company handling personal data fails in their obligations under data protection legislation and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

6. Data Disposal
Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:
6.1 Personal data stored electronically (including any and all backups thereof) shall be deleted securely;
6.2 Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely;
6.3 Personal data stored in hardcopy form shall be shredded securely; and
6.4 Special category personal data stored in hardcopy form shall be shredded securely.

7. Data Retention
7.1 As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
7.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods, as set out below.
7.3 When establishing and/or reviewing retention periods, the following shall be taken into account:
a) The objectives and requirements of the Company;
b) The type of personal data in question;
c) The purpose(s) for which the data in question is collected, held, and processed;
d) The Company’s legal basis for collecting, holding, and processing that data; and
e) The category or categories of data subject to whom the data relates
7.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
7.5 Notwithstanding the defined retention periods in the Appendix, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

8. Roles and Responsibilities
8.1 The Company’s Data Protection Officer is the position holder of Company Secretary at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS.
8.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy and Employee Data Protection Policy), and with the UK GDPR and other applicable data protection legislation.
8.3 The Data Protection Officer and relevant colleagues, including the Company Business Development Manager for technical areas, shall be responsible for ensuring compliance with the above data retention periods.
8.4 Any questions regarding this Policy, the retention of personal data, or any other aspect of UK GDPR compliance should be referred to the Data Protection Officer.
8.5 If you are in the European Union, you may address privacy-related inquiries to our EU Representative pursuant to Article 27 EU GDPR:

EU-REP.Global GmbH
www.eu-rep.global
Attn: CKB Ltd.
Hopfenstr. 1d, 24114 Kiel, Germany
[email protected]

9. Implementation of Policy
This Policy shall be deemed effective as of 1st November 2024. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

V16 CKB Ltd Data Retention policy – effective date 1st November 2024

APPENDIX

Description	Data Ref	Personal/ Non Personal Data	Data Subject Category	Type of Data	Purpose of Data Category	Purpose of Data Detail	Retention Period or Criteria
Third party customer order management system	CKB-DR-01	Personal Information	Non employee data subject	Personal data including name, address, contact details, order details and IP address	Customer Order Management	Required to process and despatch order	Indefinitely - to allow follow up of any product faults in future (one marketplace orders retained for 6 months in line with their policy)
Third party shopping cart provider	CKB-DR-02	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Customer Order Management	Required to process order and store account	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party server (customer order management)	CKB-DR-03	Personal Information	Non employee data subject	Personal data including name, address, contact details, order details and IP address	Customer Order Management	Required to store orders	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Google Analytics	CKB-DR-04	Non Personal Information	Non employee data subject	Anonymised data	Digital Marketing & Analytics	Required to inform product research, marketing and advertising spend, etc	26 months
Online Advertising	CKB-DR-05	Non Personal Information	Non employee data subject	Anonymised data	Digital Marketing & Analytics	Required to inform product research, marketing and advertising spend (conversion tracking), etc	Indefinitely - anonymised data
Online Advertising	CKB-DR-06	Non Personal Information	Non employee data subject	Anonymised data	Digital Marketing & Analytics	Required to inform product research, marketing and advertising spend (conversion tracking), etc	Indefinitely - anonymised data
Third party customer service management tool	CKB-DR-07	Personal Information	Non employee data subject	Personal data including name, address, contact details, order details and IP address	CRM Customer Service	Required to communicate with customers concerning orders and answer questions concerning orders and products	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Facebook	CKB-DR-08	Personal Information	Non employee data subject	Personal data including name if user interacts with posts	Social Media	Business promotion	Indefinitely - allowing for follow up of any product faults in future in the case of a comment made or competition win, for example
Twitter	CKB-DR-09	Personal Information	Non employee data subject	Personal data including name if user interacts with posts	Social Media	Business promotion	Indefinitely - allowing for follow up of any product faults in future in the case of a comment made
Instagram	CKB-DR-10	Personal Information	Non employee data subject	Personal data including name if user interacts with posts	Social Media	Business promotion	Indefinitely - allowing for follow up of any product faults in future in the case of a comment made
Pinterest	CKB-DR-11	Personal Information	Non employee data subject	Personal data including name if user interacts with posts	Social Media	Business promotion	Indefinitely - allowing for follow up of any product faults in future in the case of a comment made
Linkedin	CKB-DR-12	Personal Information	Non employee data subject	Personal data including name if user interacts with posts	Social Media	Business promotion	Indefinitely - allowing for follow up of any product faults in future in the case of a comment made
Facebook Ads	CKB-DR-13	Non Personal Information	Non employee data subject	Anonymised data	Digital Marketing & Analytics	Required to inform product research, marketing and advertising spend (conversion tracking), etc	Indefinitely - anonymised data
Twitter Ads	CKB-DR-14	Non Personal Information	Non employee data subject	Anonymised data	Digital Marketing & Analytics	Required to inform product research, marketing and advertising spend (conversion tracking), etc	Indefinitely - anonymised data
Pinterest Ads	CKB-DR-15	Non Personal Information	Non employee data subject	Anonymised data	Digital Marketing & Analytics	Required to inform product research, marketing and advertising spend (conversion tracking), etc	30 Days
Third party software facilitator	CKB-DR-16	Personal Information	Employee data subject	Personal data including name, contact details and IP address	Business Operation	Business Operation	Retain data in line with statutory obligations.
Third party payment facilitator	CKB-DR-17	Personal Information	Non employee data subject	Personal data including name and total order detail	Payment Gateway	To facilitate payment being made	36 Months
Third party payment facilitator	CKB-DR-18	Personal Information	Non employee data subject	Personal data including name and total order detail	Payment Gateway	To facilitate payment being made	12 Months
Website extension tool	CKB-DR-19	Non Personal Information	Non employee data subject	Anonymised data	Website search bar history	Tool to provide insight into search history on Our Site to inform business purchasing and advertising decisions	24 Months
Third party software for location tracking for currency conversion	CKB-DR-20	Personal Information	Non employee data subject	Personal data including IP address	Currency conversion	Enhanced website functionality for better user experience	On during a users time on the website only
Third party address located based on postcode	CKB-DR-21	Personal Information	Non employee data subject	Personal data including address and IP address	Checkout Address Verification	Enhanced website functionality for better user experience	On during a users time at checkout only
Third party review company	CKB-DR-22	Personal Information	Non employee data subject	Personal data including name, transaction ID, contact details, order details and IP address	Customer Feedback & Product Reviews	Business promotion and product review/ customer service tool	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party review company	CKB-DR-23	Personal Information	Non employee data subject	Personal data including name, transaction ID, contact details, order details and IP address	Customer Feedback & Product Reviews	Business promotion and product review/ customer service tool	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party accountancy firm	CKB-DR-24	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address as well as employee salary information, etc	Business Operation	Staff payroll and pensions administration plus registered office. Past periods accounting firm	In line with financial accounting requirements, currently 6 years
Third party electronic file share and storage system	CKB-DR-25	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address as well as employee contract information	Business Operation	Business Operation	Reviewed in line with relevant data categories
Third party anti-virus software	CKB-DR-26	Personal Information	Employee data subject	Personal data including IP address	Business Protection	Business protection and security	Review at annual renewal time
Third party bank	CKB-DR-27	Personal Information	Non employee data subject and employee data subject	Personal data including name and IP address as well as transactional data where relevant	Business Operation	Business banking	In line with financial accounting requirements
Third party bank	CKB-DR-28	Personal Information	Non employee data subject and employee data subject	Personal data including name and IP address as well as transactional data where relevant	Business Operation	Business banking	In line with financial accounting requirements
Third party security company	CKB-DR-29	Personal Information	Employee data subject	Personal data including name and contact details	Business Protection	Business protection and security	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party security company	CKB-DR-30	Personal Information	Employee data subject	Personal data including name and contact details for out of hours contact	Business Protection	Business protection and security	Review if a change in employee personnel/ an employee asks to be removed from contact list
Third party security technology company	CKB-DR-31	Personal Information	Employee data subject	Personal data including name, address, contact details and IP address	Business Protection	Business protection and security	Retained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party mailing company	CKB-DR-32	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Business Operation	Order delivery	Retained for as long as it needs it to carry out a particular purpose or meet a particular obligation.
Third party delivery company	CKB-DR-33	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Business Operation	Order delivery	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Whats App	CKB-DR-34	Personal Information	Employee data subject	Personal data including name and contact details for out of hours contact	Business Operation	Communications	Review if a change in employee personnel/ an employee asks to be removed from contact list
Third party IT firm	CKB-DR-35	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Business Operation	IT support	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party e-mail/ domain provider	CKB-DR-36	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address as well as employee information	Business Operation	Communications	Reviewed in line with relevant data categories
Third party delivery company	CKB-DR-37	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Business Operation	Order delivery	12 months
Third party communication software	CKB-DR-38	Personal Information	Non employee data subject	Personal data including name, address, contact details, order details and IP address	Business Operation	Facilitates delivery of order confirmation e-mail	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party accountancy firm (EU territories)	CKB-DR-39	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Financial accountancy	Financial accountancy	In line with financial accounting requirements
Third party non EU territory compliance firm	CKB-DR-40	Personal Information	Employee data subject	Personal data including name and contact details plus order details	Business Operation	Business Operation	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party accountancy firm (non EU territory)	CKB-DR-41	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Financial accountancy	Financial accountancy	In line with financial accounting requirements (engagement records will be retained indefinitely)
Marketplace portal authorised access	CKB-DR-42	Personal Information	Employee data subject	Personal data including name, address, contact details, IP address, proof if ID	Business Operation	Marketplace portal authorised access	Review if a change in employee personnel/ job role no longer requiring portal access
Third party website developers	CKB-DR-43	Personal Information	Non employee data subject	Personal data including name, address, contact details, order details and IP address	Customer Order Management	Required to test site	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party delivery company	CKB-DR-44	Personal Information	Non employee data subject and employee data subject	Personal data including name and address, IP address	Business Operation	Order delivery	Retained in line with statutory and legislative requirements
Third party mobile phone device and software provider	CKB-DR-45	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address as well as employee information	Business Operation	Communications	Reviewed in line with relevant data categories
Third party cookie consent facilitator	CKB-DR-46	Personal Information	Non employee data subject	Personal data including IP address	Legal compliance	GDPR requirement	Indefinitely to provide confirmation of consent at any given time (re-consent is required every 2 months)
Third party business benefit provider	CKB-DR-47	Personal Information	Employee data subject	Personal data including name, address, contact details, and IP address	Business Operation	Business Benefits	Retained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party business benefit provider	CKB-DR-48	Personal Information	Employee data subject	Personal data including name, address, contact details and IP address	Business benefits	Financial accountancy	Max 150 years post an individual staff member's data of birth
Staff HR files	CKB-DR-49	Personal Information	Employee data subject	Personal data including name, address, contact details, emergency contact details, sickness/ health record, application and employment documentation including contracts, pay rates, training and performance reviews	Business Operation	Legal compliance	6 years after employment terminates
Job applications	CKB-DR-50	Personal Information	Non employee data subject	job application, CV, interview notes, eligibility to work documentation	Business Operation	Legal compliance	6 months after notifying unsuccessful candidates of the outcome of their application
Accident records	CKB-DR-51	Personal Information	Non employee data subject and employee data subject	Personal data including name. Sensitive data concerning accident	Business Operation	Legal compliance	6 years from the date the accident record was made
Third party online training provider	CKB-DR-52	Personal Information	Employee data subject	Personal data including name, contact details and IP address	Business Operation	Staff training/ legal compliance	Indefinitely with active account
Third party training provider	CKB-DR-53	Personal Information	Employee data subject	Personal data including name and contact details	Business Operation	Staff training/ legal compliance	Retained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party communication provider	CKB-DR-54	Personal Information	Employee data subject	Personal data including name and contact details	Business Operation	Communications	Retained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party communication provider	CKB-DR-55	Non Personal Information	Non employee data subject	Phone numbers	Business Operation	Communications	In line with financial accounting requirements
Third party malware scanning Firm	CKB-DR-56	Personal Information	Employee data subjects	Personal data including name, address, contact details and IP address	Business Protection	Business protection and security	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party offsite storage	CKB-DR-57	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address as well as employee salary information, etc	Financial accountancy	Financial accountancy	In line with financial accounting requirements, currently 6 years
Third party logistics company	CKB-DR-58	Personal Information	Employee data subjects	Personal data including name, contact details and IP address	Business Operation	Business Operation	Retained for at least 4 years or longer if required by law
Third party business benefit administrator	CKB-DR-59	Personal Information	Employee data subjects	Personal data including name, address, contact details and IP address	Business Operation	Business Benefits	Retained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party courier service	CKB-DR-60	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Business Operation	Order delivery	Retained for as long as it needs it to carry out a particular purpose or meet a particular obligation.
Third party website security (firewall, malware, and incident reporting software)	CKB-DR-61	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Business Protection	Business protection and security	Retain data for as long as there is a contractual need (including maintaining accurate business records) and also thereafter if required or permitted by law.
Third party confidential waste shredding service (on site)	CKB-DR-62	Personal Information	Employee data subject	Name and contact details	Business Operation	Business Operation	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party accountancy firm (non EU territory)	CKB-DR-63	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Financial accountancy	Financial accountancy	Retain data in line with financial accounting requirements
Third party UK supplier of personalised lanyards	CKB-DR-64	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Business Operation	Business Operation	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party carrier service	CKB-DR-65	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and order details	Business Operation	Business Operation	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party shopping cart provider	CKB-DR-66	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Customer Order Management	Required to process order and store account	Indefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party security company	CKB-DR-67	Personal Information	Employee data subject	Personal data including name, address, contact details, order details and IP address as well as images and sound	Business Protection & Security	Business Protection	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law. Recordings retained for 30 days
Third party business benefit provider	CKB-DR-68	Personal Information	Employee data subject	Personal data including name, address, contact details, and IP address	Business benefits	Service delivery and financial accountancy	Retain data for as long as necessary to satisfy legal, accounting and reporting requirements. Quotes retained for 3 years and claims information retained for 10 years
Third party returns facilitator	CKB-DR-69	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Business Operation	Business Operation	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party EU Representative (GDPR)	CKB-DR-70	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Legal compliance	GDPR requirement	In line with legal and financial requirements
Third party EU TM/ IP protection firm	CKB-DR-71	Personal Information	Employee data subject	Personal data including name, address, contact details and IP address	Business Protection	Business Protection	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party TM/ IP protection firm	CKB-DR-72	Personal Information	Employee data subject	Personal data including name, address, contact details and IP address	Business Protection	Business Protection	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party web translation software	CKB-DR-73	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details and IP address	Business Operation	Business Operation	Retain data for as long as there is a contractual need
Third party web security technology provider	CKB-DR-74	Personal Information	Employee data subject	Personal data including name, address, contact details and IP address	Business protection	Business Protection & Security	Retain data In line with financial requirements and for 2 years post contract end
Third party logistics company	CKB DR-75	Personal Information	Employee data subject	Personal data including name, address, contact details and IP address	Business Operation	Business Operation	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party delivery company – stock into fulfilment	CKB-DR-76	Personal Information	Employee data subject	Personal data including name, contact details and IP address	Business Operation	Business Operation	Retain data for as long as there is a contractual need and also thereafter if required or permitted by law.
Third party development support for websites	CKB-DR-77	Personal Information	Employee data subject	Personal data including name, contact details and IP address	Business Operation	Business Operation	Retain data for 6 months after support use ends
Third party accountancy platform (EU territories)	CKB-DR-78	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Financial Accountancy	Financial Accountancy	In line with legal and financial accounting requirements
Third party accountancy tool	CKB-DR-79	Personal Information	Non employee data subject and employee data subject	Personal data including name, address, contact details, order details and IP address	Financial Accountancy	Financial Accountancy	In line with legal and financial accounting requirements

'Indefinitely' note - the statute of limitations is 20 years for certain product claim classifications