[sheet: Cover & Version Control]

[sheet: Cover & Version Control]
Field | Value
Document Title | Data Retention Schedule — Northgate Telecommunications PLC
Document Reference | NTP-DRS-2023-001
Related Engagement | SC/NTP/2023-0213/PDS
Prepared By | Priscilla Wynn, Working Associate, Calderwood & Harkness LLP
Reviewed By | Sara Hendricks, Lead Associate, Calderwood & Harkness LLP
Approved By | Sanjay Mehta, Data Protection Officer, Northgate Telecommunications PLC
Approved By (Legal) | Fiona Gallagher, General Counsel & Company Secretary, Northgate Telecommunications PLC
Version | 1.0
Date of Issue | 1 September 2023
Classification | Confidential — Internal Use Only
Scope | All categories of personal data processed by Northgate Telecommunications PLC and its EU subsidiaries (Northgate Ireland Ltd, Northgate GmbH, Northgate B.V., Northgate France SAS, Northgate Iberia S.L.) across UK and EU operations
Data Subjects Covered | ~6.3 million consumer subscribers, ~42,000 enterprise clients, ~11,400 employees, ~28,000 contractors/temporary workers/job applicants/website visitors
Next Review Date | 1 September 2024
Review Frequency | Annual, or upon material change in processing activities or applicable law
ICO Registration Number | ZA482917
Lead EU Supervisory Authority | Data Protection Commission (Ireland)
[sheet: Consumer Subscriber Data]
Ref No. | Data Category | Description / Examples | Processing Purpose | Lawful Basis | ROPA Reference | Applicable Entity | Retention Period | Retention Start Trigger | Regulatory / Legal Basis for Retention | Deletion / Anonymisation Method | Responsible Business Unit | Responsible Data Steward | Special Category Data (Yes/No) | Notes
CS-001 | Subscriber account registration data | Full name, postal address, email address, date of birth, telephone number | Service provision and contract performance | Contract performance (Art. 6(1)(b)) | ROPA-UK-003; ROPA-EU-IE-002 | NTP PLC (UK); Northgate Ireland Ltd; Northgate GmbH; Northgate B.V.; Northgate France SAS; Northgate Iberia S.L. | Duration of contract + 6 years | Date of contract termination or account closure | Limitation Act 1980 (6-year limitation period); equivalent EU member state limitation periods | Automated deletion from production systems; anonymisation of analytics datasets | Customer Operations | VP, Customer Operations | No | Applies to all UK and EU subscriber accounts
CS-002 | Communications data (traffic data and metadata) | Call detail records, session data, connection timestamps, duration, originating/terminating numbers, cell tower IDs | Provision of telecommunications services; network management; compliance with lawful interception obligations | Legal obligation (Art. 6(1)(c)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-007; ROPA-UK-041 | NTP PLC (UK) | 12 months from date of communication (general retention); up to 24 months where required by specific retention notice under IPA 2016 | Date of communication | Investigatory Powers Act 2016, Part 4 (communications data retention); Data Retention and Acquisition Regulations 2018 | Automated purge from communications data stores; cryptographic erasure of backup media | Network Operations; Legal & Compliance | Thomas Okoye, CISO | No | Retention notices issued by Secretary of State under IPA 2016 may require extended retention for specific categories; DPIA-010 applies
CS-003 | Subscriber location data | Cell-level location data, GPS coordinates (where provided), Wi-Fi access point data | Network service provision; network optimisation | Legitimate interest (Art. 6(1)(f)); Consent (Art. 6(1)(a)) for value-added location services | ROPA-UK-012; ROPA-EU-DE-005 | NTP PLC (UK); Northgate GmbH | Real-time processing only for network management (no retention beyond session); 90 days for network optimisation analytics (pseudonymised); duration of consent for value-added services | End of communication session; date of last processing for analytics | Privacy and Electronic Communications (EC Directive) Regulations 2003 (UK PECR), Reg. 14; ePrivacy Directive 2002/58/EC, Art. 9 | Automatic purge of raw location data at session end; pseudonymised analytics data deleted after 90 days | Network Operations; Product & Engineering (NorthCloud) | Laura Dearden, VP Product & Engineering | No | Transfer to Caldwell Analytics Inc. for network analytics is pseudonymised; see TIA-001 and DPIA-011
CS-004 | Billing and payment data | Invoice amounts, payment card details (tokenised), billing address, payment history, direct debit mandates | Billing, revenue collection, financial record-keeping | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-005; ROPA-EU-IE-004 | NTP PLC (UK); all EU subsidiaries | Duration of contract + 7 years | Date of contract termination or final payment (whichever is later) | Companies Act 2006, s.386 (accounting records — 6 years); HMRC requirements; VAT Act 1994 (6 years); equivalent EU member state tax legislation | Secure deletion from payment processing systems; tokenised card data destroyed upon contract end + 90 days; anonymisation of financial analytics | Finance | Head of Finance | No | Payment card tokens retained separately from PAN; PCI DSS controls apply
CS-005 | Customer service interaction records | Call recordings, chat transcripts, email correspondence, complaint records | Customer support, quality assurance, dispute resolution | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) for complaint handling | ROPA-UK-009; ROPA-EU-FR-003 | NTP PLC (UK); Northgate France SAS | 3 years from date of interaction; 6 years where complaint is subject to regulatory or legal proceedings | Date of interaction or final resolution of complaint | Limitation Act 1980; Ofcom General Conditions of Entitlement (complaint handling); ARCEP requirements (France) | Automated deletion from CRM system; call recordings purged from storage | Customer Operations | VP, Customer Operations | No
CS-006 | Marketing and profiling data | Marketing preferences, consent records, behavioural profiling data, segmentation data, advertising IDs, cross-device identifiers | Direct marketing, profiling, targeted advertising on NorthCloud freemium tier | Consent (Art. 6(1)(a)); Legitimate interest (Art. 6(1)(f)) for existing customer soft opt-in | ROPA-UK-015; ROPA-EU-IE-008 | NTP PLC (UK); Northgate Ireland Ltd | Duration of consent + 30 days for consent withdrawal processing; profiling data: 12 months from last active engagement; consent records retained for 6 years post-withdrawal as evidence of lawful basis | Date of consent withdrawal or last active engagement | UK PECR, Reg. 22; ePrivacy Directive, Art. 13; ICO Direct Marketing Guidance; ICO Enforcement Notice ENF/2021/0934 remediation requirements | Profiling data: automated anonymisation; consent records: archived then deleted after retention period; advertising IDs: purged from ad-tech platforms | Marketing; Product & Engineering (NorthCloud) | Laura Dearden, VP Product & Engineering | No | DPIA-007 applies; enhanced consent mechanisms implemented following ICO enforcement action (£320,000 fine, September 2021)
CS-007 | Network performance and analytics data transferred to Caldwell Analytics Inc. | Pseudonymised subscriber metadata, device identifiers, network performance metrics | AI-driven network analytics and predictive maintenance | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-022; ROPA-EU-DE-009 | NTP PLC (UK); Northgate GmbH | Duration of NTP–Caldwell MSA + 90 days for deletion by Caldwell; pseudonymised data retained by NTP for 18 months from collection | Date of data collection; date of MSA termination | NTP–Caldwell Master Services Agreement (executed 1 June 2021); EU SCCs (Module 2, executed 17 July 2023); UK IDTA (executed 17 July 2023) | Caldwell contractually required to delete/return within 90 days of MSA termination; NTP data anonymised after 18 months; AES-256 encryption at rest; cryptographic erasure | Network Operations; Product & Engineering | Thomas Okoye, CISO | No | DPIA-011 and TIA-001 apply; supplementary measures include AES-256 encryption, TLS 1.3, pseudonymisation, contractual audit rights
CS-008 | IoT device telemetry data (connected-vehicle) | Device endpoint identifiers, telemetry readings, geolocation, sensor data | IoT connectivity platform analytics; connected-vehicle telemetry product | Legitimate interest (Art. 6(1)(f)); Contract performance (Art. 6(1)(b)) | ROPA-UK-031 | NTP PLC (UK) | Duration of service contract + 12 months; transfer to Moritaka Systems K.K. retained for duration of partnership agreement | Date of contract termination or device decommissioning | EU adequacy decision for Japan; TIA-006 supplementary measures | Automated deletion from IoT platform; anonymisation of aggregated telemetry datasets | Product & Engineering (IoT) | Laura Dearden, VP Product & Engineering | No | ~12,000 IoT device endpoints; data shared with Moritaka Systems K.K. (Tokyo) under EU adequacy decision + supplementary measures
CS-009 | Cookies and website tracking data | Cookie identifiers, browsing behaviour, IP addresses, device fingerprints, session data from NorthCloud portal | Website functionality, analytics, advertising | Consent (Art. 6(1)(a)) for non-essential cookies; Legitimate interest for strictly necessary cookies | ROPA-UK-018; ROPA-EU-IE-010 | NTP PLC (UK); Northgate Ireland Ltd | Session cookies: duration of browsing session; persistent analytics cookies: 13 months maximum; advertising cookies: 13 months maximum; consent records: 6 years | Date of cookie placement; date of consent | UK PECR, Reg. 6; ePrivacy Directive, Art. 5(3); ICO Cookie Guidance; CNIL cookie guidelines (13-month maximum) | Automatic expiry of cookies; server-side logs purged on schedule; consent management platform records archived | Digital & Marketing | VP, Customer Operations | No | Remediation following ICO ENF/2021/0934 ensures granular consent mechanisms in place
CS-010 | Subscriber identity verification data | Copies of government-issued ID, proof of address documents, identity verification results | Identity verification for account opening and SIM registration | Legal obligation (Art. 6(1)(c)); Contract performance (Art. 6(1)(b)) | ROPA-UK-004; ROPA-EU-IE-003 | NTP PLC (UK); Northgate Ireland Ltd; Northgate GmbH | Duration of contract + 6 years | Date of contract termination or account closure | Limitation Act 1980; Ofcom General Conditions of Entitlement; EU Electronic Communications Code | Secure deletion from identity verification platform; physical copies shredded | Customer Operations | VP, Customer Operations | No | ID copies encrypted at rest with AES-256; access restricted to authorised personnel
CS-011 | Subscriber device and SIM data | IMEI numbers, SIM card numbers (ICCID), MSISDN, device make/model, eSIM profiles | Service provisioning, device management, fraud prevention | Contract performance (Art. 6(1)(b)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-006; ROPA-EU-IE-005 | NTP PLC (UK); all EU subsidiaries | Duration of contract + 3 years | Date of contract termination or device deactivation | Limitation Act 1980; Ofcom General Conditions; GSMA IMEI Database requirements | Automated deletion from provisioning systems; anonymisation for fraud analytics | Network Operations; Customer Operations | VP, Customer Operations | No | IMEI data shared with GSMA IMEI Database for stolen device blacklisting
CS-012 | Subscriber credit check data | Credit reference agency results, credit scores, affordability assessment outcomes | Credit risk assessment for postpaid contracts | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-008 | NTP PLC (UK) | Duration of contract + 6 years; declined applications: 12 months from date of credit check | Date of contract termination or date of credit check (for declined applications) | Consumer Credit Act 1974; Limitation Act 1980; ICO guidance on credit referencing | Automated deletion from credit management systems; anonymisation of credit analytics | Finance; Customer Operations | Head of Finance | No | DPIA-006 applies (Customer credit scoring and fraud detection)
CS-013 | Number portability records | Porting authorisation codes, donor/recipient network details, porting timestamps | Number portability administration | Legal obligation (Art. 6(1)(c)) | ROPA-UK-010 | NTP PLC (UK); all EU subsidiaries | Duration of contract + 12 months; failed port requests: 6 months from request date | Date of successful port completion or contract termination | Ofcom General Conditions of Entitlement (C7 — Number Portability); EU Electronic Communications Code, Art. 106 | Automated deletion from number management systems | Network Operations; Customer Operations | VP, Customer Operations | No
CS-014 | NorthCloud freemium tier user data | Username, email address, usage metrics, feature engagement data, free trial activation records | Freemium SaaS service delivery, conversion analytics | Contract performance (Art. 6(1)(b)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-019; ROPA-EU-IE-011 | NTP PLC (UK); Northgate Ireland Ltd | Duration of active account + 12 months of inactivity; if no login for 12 months, account deactivated and data deleted after further 90 days | Date of last account login or active engagement | GDPR Art. 5(1)(e) storage limitation | Automated account deactivation after 12 months inactivity; data purge 90 days post-deactivation; anonymisation of usage analytics | Product & Engineering (NorthCloud) | Laura Dearden, VP Product & Engineering | No | Approximately 1.2 million freemium tier users; conversion rate to paid tiers ~4.8%
CS-015 | Value-added service data | Service subscription records, content preferences, parental control settings, premium content purchase history | Value-added service delivery (music streaming, cloud storage, security packages) | Contract performance (Art. 6(1)(b)); Consent (Art. 6(1)(a)) where applicable | ROPA-UK-014; ROPA-EU-IE-007 | NTP PLC (UK); Northgate Ireland Ltd | Duration of VAS subscription + 3 years | Date of VAS cancellation or main contract termination | Limitation Act 1980; Digital Content Regulations; Consumer Rights Act 2015 | Automated deletion from VAS platforms; content preference data anonymised | Product & Engineering; Customer Operations | Laura Dearden, VP Product & Engineering | No
CS-016 | Roaming data | Roaming partner network identifiers, visited network records, roaming call detail records, data usage in roamed networks | International roaming service provision, inter-operator settlement | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-011; ROPA-EU-IE-006 | NTP PLC (UK); all EU subsidiaries | 12 months from date of roaming event for service records; 7 years for financial settlement records | Date of roaming event or date of final financial settlement | EU Roaming Regulation (EU) 2022/612; BEREC guidelines; Companies Act 2006 (financial records) | Automated purge of service records; financial settlement records deleted per schedule | Network Operations; Finance | Head of Finance | No | Inter-operator agreements with 120+ roaming partners
CS-017 | Emergency services (999/112) communication records | Caller location data provided to emergency services, call records, subscriber identification for emergency calls | Compliance with emergency caller location obligations | Legal obligation (Art. 6(1)(c)) | ROPA-UK-013 | NTP PLC (UK); all EU subsidiaries | 12 months from date of emergency call | Date of emergency call | Communications Act 2003, s.56; Ofcom General Conditions (C4 — Emergency Access); EU Electronic Communications Code, Art. 109 | Automated purge from emergency services data stores | Network Operations | Thomas Okoye, CISO | No | Location accuracy requirements per Ofcom and BEREC specifications
CS-018 | Subscriber complaint and Ombudsman referral records | Ombudsman Services referral documentation, ADR case files, Ofcom complaint escalation records | Alternative dispute resolution, regulatory complaint handling | Legal obligation (Art. 6(1)(c)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-016 | NTP PLC (UK) | 6 years from date of final resolution of complaint or ADR determination | Date of final resolution or Ombudsman determination | Ofcom General Conditions (C4.6 — ADR); Limitation Act 1980; Ombudsman Services terms of reference | Automated deletion from complaint management system; physical ADR files shredded | Customer Operations; Legal & Compliance | VP, Customer Operations | No
CS-019 | Subscriber vulnerability and accessibility data | Vulnerability flags, accessibility requirements, priority fault repair eligibility, third-party nominee contact details | Vulnerability support, accessibility service delivery, Ofcom mandatory measures | Legal obligation (Art. 6(1)(c)); Legitimate interest (Art. 6(1)(f)); Explicit consent (Art. 9(2)(a)) where health data involved | ROPA-UK-017 | NTP PLC (UK) | Duration of contract + 6 years; health-related vulnerability data: duration of contract + 3 years | Date of contract termination or removal of vulnerability flag | Ofcom General Conditions (C5 — Rules on Vulnerable Consumers); Equality Act 2010; Communications Act 2003 | Automated deletion from CRM; enhanced access controls during retention | Customer Operations | VP, Customer Operations | Yes — health data where vulnerability relates to medical condition (Art. 9 GDPR) | DPIA-004 applies; enhanced consent and access controls for health-related vulnerability data
CS-020 | Subscriber social media interaction data | Social media posts directed to NTP accounts, direct messages, social media complaint records, sentiment analysis outputs | Customer support via social media channels, brand monitoring | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-020 | NTP PLC (UK); Northgate Ireland Ltd | 2 years from date of interaction; sentiment analysis outputs: anonymised after 6 months | Date of interaction | GDPR Art. 5(1)(e) storage limitation; ICO social media guidance | Automated deletion from social media management platform; anonymisation of sentiment datasets | Marketing; Customer Operations | VP, Customer Operations | No
CS-021 | Subscriber app usage and diagnostics data | NTP mobile app usage logs, crash reports, feature interaction data, in-app diagnostics | App performance monitoring, bug resolution, feature improvement | Legitimate interest (Art. 6(1)(f)); Consent (Art. 6(1)(a)) for optional diagnostics sharing | ROPA-UK-021; ROPA-EU-IE-009 | NTP PLC (UK); Northgate Ireland Ltd | 6 months from date of collection; anonymised aggregate crash analytics: 24 months | Date of data collection | GDPR Art. 5(1)(e) storage limitation; UK PECR for device access | Automated purge from app analytics platform; anonymisation pipeline for aggregate data | Product & Engineering | Laura Dearden, VP Product & Engineering | No
[sheet: Enterprise Client Data]
Ref No. | Data Category | Description / Examples | Processing Purpose | Lawful Basis | ROPA Reference | Applicable Entity | Retention Period | Retention Start Trigger | Regulatory / Legal Basis for Retention | Deletion / Anonymisation Method | Responsible Business Unit | Responsible Data Steward | Special Category Data (Yes/No) | Notes
EC-001 | Enterprise client contact details | Business contact name, job title, business email, business phone, office address | Contract management, service delivery, account management | Legitimate interest (Art. 6(1)(f)); Contract performance (Art. 6(1)(b)) | ROPA-UK-025; ROPA-EU-IE-012; ROPA-EU-DE-011; ROPA-EU-NL-006; ROPA-EU-FR-005; ROPA-EU-ES-003 | NTP PLC; all EU subsidiaries | Duration of commercial relationship + 6 years | Date of contract termination or last commercial engagement | Limitation Act 1980; equivalent EU limitation periods | Automated deletion from CRM; manual review of archived records | Enterprise Sales | Head of Enterprise Sales | No | Covers ~42,000 enterprise clients across UK and 14 EU/EEA member states
EC-002 | NorthCloud enterprise platform usage data | User login credentials (hashed), access logs, feature usage analytics, API call logs, tenant configuration data | SaaS platform service delivery, security monitoring, product improvement | Contract performance (Art. 6(1)(b)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-026; ROPA-EU-IE-013 | NTP PLC; Northgate Ireland Ltd | Duration of subscription + 90 days (for data return/deletion); access logs: 12 months; usage analytics: 24 months (anonymised after 6 months) | End of subscription term or account deactivation | NorthCloud Terms of Service; GDPR Art. 5(1)(e) storage limitation | Automated account deactivation and data purge; anonymisation pipeline for usage analytics | Product & Engineering (NorthCloud) | Laura Dearden, VP Product & Engineering | No | NorthCloud hosted by Pinnacle Cloud Services Ltd (data centres in London, Frankfurt, Amsterdam, Dublin); amended DPA executed 28 June 2023
EC-003 | Enterprise contract and procurement records | Signed contracts, purchase orders, SLAs, NDAs, commercial correspondence | Contract performance, legal record-keeping, dispute resolution | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-027 | NTP PLC; all EU subsidiaries | Duration of contract + 7 years | Date of contract expiry or termination | Companies Act 2006, s.386; Limitation Act 1980 (6 years for breach of contract); Irish Statute of Limitations 1957 | Secure archiving then deletion from document management system | Legal & Compliance; Procurement | Fiona Gallagher, General Counsel | No
EC-004 | Enterprise credit and financial assessment data | Credit check results, financial statements of clients, payment performance data, fraud detection scores | Credit risk assessment, fraud prevention | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-029 | NTP PLC | Duration of contract + 6 years; fraud detection records: 6 years from date of incident or assessment | Date of contract termination or date of assessment | Limitation Act 1980; Proceeds of Crime Act 2002; Money Laundering Regulations 2017 | Automated deletion from credit management systems; anonymisation of fraud analytics datasets | Finance; Legal & Compliance | Head of Finance | No | DPIA-006 applies (Customer credit scoring and fraud detection)
EC-005 | Enterprise billing and invoicing records | Invoice data, purchase order references, payment history, VAT records, credit notes, aged debt records | Revenue collection, financial reporting, tax compliance | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-028; ROPA-EU-IE-014 | NTP PLC; all EU subsidiaries | Duration of contract + 7 years | Date of final invoice or contract termination (whichever is later) | Companies Act 2006, s.386; VAT Act 1994 (6 years); HMRC requirements; equivalent EU tax legislation | Secure deletion from ERP/billing systems; anonymisation of financial analytics | Finance | Head of Finance | No
EC-006 | Enterprise SLA performance and service quality data | Service availability metrics, incident response times, SLA breach records, penalty calculations, service credits issued | SLA monitoring, service quality reporting, contractual compliance | Contract performance (Art. 6(1)(b)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-030 | NTP PLC; all EU subsidiaries | Duration of contract + 6 years | Date of contract termination | Limitation Act 1980; contractual SLA terms | Automated deletion from service management platform; archived reports deleted per schedule | Enterprise Sales; Network Operations | Head of Enterprise Sales | No | SLA data may contain incidental personal data (e.g., named contacts in incident tickets)
EC-007 | Enterprise technical support and incident records | Support tickets, incident reports, technical diagnostics, named engineer contact details, remote access session logs | Technical support delivery, incident resolution, root cause analysis | Contract performance (Art. 6(1)(b)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-032; ROPA-EU-DE-012 | NTP PLC; Northgate GmbH | 3 years from date of incident closure; major incidents (P1/P2): 6 years from closure | Date of incident closure or final resolution | Limitation Act 1980; NIS Regulations (security incident record-keeping) | Automated deletion from ITSM platform; remote access session recordings purged | IT Operations; Enterprise Sales | Thomas Okoye, CISO | No
EC-008 | Enterprise marketing and business development data | B2B marketing preferences, event attendance records, business development correspondence, lead scoring data | B2B marketing, lead generation, event management | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-033; ROPA-EU-IE-015 | NTP PLC; Northgate Ireland Ltd | Duration of commercial relationship + 2 years; prospects without engagement: 12 months from last contact | Date of last commercial engagement or contact | UK PECR, Reg. 22 (B2B exemption for corporate subscribers); ePrivacy Directive | Automated deletion from marketing automation platform; lead data purged from CRM | Enterprise Sales; Marketing | Head of Enterprise Sales | No | B2B soft opt-in applies under UK PECR for corporate subscribers
EC-009 | Enterprise API and integration data | API keys, integration configuration, webhooks, developer portal account data, sandbox environment data | Platform integration services, developer support | Contract performance (Art. 6(1)(b)) | ROPA-UK-034 | NTP PLC; Northgate Ireland Ltd | Duration of subscription + 30 days; sandbox data: deleted within 7 days of subscription termination | End of subscription term or API key revocation | NorthCloud Terms of Service; GDPR Art. 5(1)(e) | Automated API key revocation and purge; sandbox environment destroyed; developer portal accounts deactivated | Product & Engineering (NorthCloud) | Laura Dearden, VP Product & Engineering | No
EC-010 | Enterprise managed services customer employee data | Employee names, device assignments, mobile numbers, usage data for enterprise mobility management clients | Managed mobility service delivery on behalf of enterprise clients | Contract performance (Art. 6(1)(b)) | ROPA-UK-035; ROPA-EU-NL-007 | NTP PLC; Northgate B.V. | Duration of managed services contract + 90 days for data return/deletion | Date of managed services contract termination | GDPR Art. 28 (processor obligations); NTP acts as processor on behalf of enterprise clients as controllers | Data returned to enterprise client or securely deleted within 90 days of contract end; certified deletion confirmation provided | Enterprise Sales; Network Operations | Head of Enterprise Sales | No | NTP acts as processor; enterprise client is controller; approximately 8,500 enterprise client employees covered
EC-011 | Enterprise partner and reseller contact data | Channel partner contact names, reseller accreditation records, commission records, partner portal access credentials | Channel management, reseller administration, commission processing | Contract performance (Art. 6(1)(b)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-036; ROPA-EU-ES-004 | NTP PLC; Northgate Iberia S.L. | Duration of partner agreement + 6 years | Date of partner agreement termination | Limitation Act 1980; equivalent EU limitation periods | Automated deletion from partner management platform; commission records archived then deleted | Enterprise Sales | Head of Enterprise Sales | No | Approximately 350 channel partners and resellers across UK and EU
[sheet: Employee & HR Data]
Ref No. | Data Category | Description / Examples | Processing Purpose | Lawful Basis | ROPA Reference | Applicable Entity | Retention Period | Retention Start Trigger | Regulatory / Legal Basis for Retention | Deletion / Anonymisation Method | Responsible Business Unit | Responsible Data Steward | Special Category Data (Yes/No) | Notes
EH-001 | Employee personnel records | Name, home address, date of birth, national insurance number, passport/ID copies, emergency contacts, employment contract, job title, department, work location | Employment administration, contract performance, legal compliance | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-040; ROPA-EU-IE-015; ROPA-EU-DE-014 | NTP PLC; all EU subsidiaries | Duration of employment + 7 years | Date of termination of employment | Limitation Act 1980 (6-year contractual claims); Employment Rights Act 1996; Income Tax (Earnings and Pensions) Act 2003; HMRC requirements; German AO (Abgabenordnung) 10-year retention for tax records | Secure deletion from HRIS; physical files shredded | People & HR | Philippa Crane, Head of People & HR | No | ~11,400 employees globally; ~8,200 UK/EU
EH-002 | Payroll and compensation data | Salary details, bank account details, tax codes, pension contributions, bonus records, P60/P45 records, payslips | Payroll processing, tax compliance, pension administration | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-042; ROPA-EU-IE-016 | NTP PLC; all EU subsidiaries | Duration of employment + 7 years (UK); duration of employment + 10 years (Germany, for tax records) | Date of termination of employment or date of final payroll run | Income Tax (Earnings and Pensions) Act 2003; Taxes Management Act 1970; HMRC record-keeping requirements; German AO, s.147 (10 years); French Code du Travail | Automated deletion from payroll systems; archived backup tapes cryptographically erased | People & HR; Finance | Philippa Crane, Head of People & HR | No | Expatriate payroll for ~45 US-assigned employees processed by Sunderland-Hayes Payroll Services Inc. (New York); TIA-004 applies
EH-003 | Employee health and wellbeing data | Occupational health records, sick leave records, disability accommodations, NorthPulse wellbeing monitoring data, return-to-work assessments | Occupational health management, statutory sick pay, reasonable adjustments, employee wellbeing programme | Legal obligation (Art. 6(1)(c)) for SSP/disability; Explicit consent (Art. 9(2)(a)) for NorthPulse; Employment/social security law (Art. 9(2)(b)) | ROPA-UK-045; ROPA-EU-IE-017 | NTP PLC; Northgate Ireland Ltd | Occupational health records: duration of employment + 40 years (for exposure records under COSHH); sick leave records: duration of employment + 3 years; NorthPulse data: duration of participation + 12 months; anonymised aggregate reports retained indefinitely | Date of termination of employment; date of withdrawal from NorthPulse programme | Control of Substances Hazardous to Health Regulations 2002 (40 years for health surveillance); Equality Act 2010; Employment Rights Act 1996 | NorthPulse individual data anonymised upon programme exit + 12 months; occupational health records archived in secure restricted-access system; physical records shredded upon expiry | People & HR; Occupational Health | Philippa Crane, Head of People & HR | Yes — health data (Art. 9 GDPR) | DPIA-003 (NorthPulse) applies; voluntary participation; special category data — enhanced security controls and access restrictions
EH-004 | Trade union membership data | Trade union affiliation, union representative status, collective bargaining correspondence | Industrial relations, collective bargaining, statutory consultation obligations | Legal obligation (Art. 6(1)(c)); Employment/social security law (Art. 9(2)(b)) | ROPA-UK-046 | NTP PLC | Duration of employment + 6 years; collective bargaining records: duration of agreement + 6 years | Date of termination of employment or expiry of agreement | Trade Union and Labour Relations (Consolidation) Act 1992; Limitation Act 1980 | Secure deletion from HRIS; physical union correspondence shredded | People & HR; Legal & Compliance | Philippa Crane, Head of People & HR | Yes — trade union membership (Art. 9 GDPR) | Special category data — access restricted to HR and Legal functions
EH-005 | Biometric access control data | Fingerprint templates, facial geometry templates for data centre access | Physical security of data centre facilities (London, Frankfurt, Amsterdam, Dublin) | Legitimate interest (Art. 6(1)(f)); Explicit consent (Art. 9(2)(a)) | ROPA-UK-048; ROPA-EU-DE-015; ROPA-EU-NL-009; ROPA-EU-IE-018 | NTP PLC; Northgate GmbH; Northgate B.V.; Northgate Ireland Ltd | Duration of employment/contractor engagement + 30 days; immediately upon access revocation for terminated personnel | Date of access revocation or employment/engagement termination | GDPR Art. 9 (special category — biometric data); UK GDPR; German BDSG §26; Dutch UAVG | Biometric templates cryptographically erased from access control systems within 30 days of access revocation; no backup retention of biometric templates | IT Security / Facilities | Thomas Okoye, CISO | Yes — biometric data (Art. 9 GDPR) | DPIA-005 applies; templates stored as irreversible hashes; not used for facial recognition identification (DPIA-008 pilot discontinued per NTP Board decision 14 June 2023)
EH-006 | Recruitment and applicant data | CVs, cover letters, interview notes, assessment results, references, right-to-work documentation, pre-employment screening results | Recruitment, candidate evaluation, employment eligibility verification | Legitimate interest (Art. 6(1)(f)) for unsuccessful candidates; Contract performance (Art. 6(1)(b)) pre-contractual steps for successful candidates | ROPA-UK-050; ROPA-EU-IE-019; ROPA-EU-DE-016 | NTP PLC; all EU subsidiaries | Successful candidates: transferred to personnel file (see EH-001); unsuccessful candidates: 6 months from date of decision unless consent obtained for talent pool (then 24 months) | Date of hiring decision (unsuccessful candidates); date of employment start (successful candidates) | Equality Act 2010 (discrimination claims — 6-month limitation for employment tribunal); German AGG (Allgemeines Gleichbehandlungsgesetz) — 2 months; extended to 6 months for UK consistency | Automated deletion from applicant tracking system; CVs and interview notes securely purged | People & HR | Philippa Crane, Head of People & HR | No | Part of ~28,000 contractors/temp workers/applicants/website visitors
EH-007 | Cross-border HR analytics and workforce planning data | Aggregated workforce demographics, performance metrics, attrition analytics, compensation benchmarking, diversity statistics | Workforce planning, organisational development, regulatory reporting | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-052; ROPA-EU-IE-020; ROPA-EU-DE-017 | NTP PLC; all EU subsidiaries | Anonymised aggregate data: retained indefinitely; individual-level data: duration of employment + 12 months then anonymised | Date of termination of employment | GDPR Art. 5(1)(e); Equality Act 2010 reporting; Gender Pay Gap reporting | Individual-level data anonymised via k-anonymity and aggregation; anonymised datasets retained for trend analysis | People & HR; Finance | Philippa Crane, Head of People & HR | No | DPIA-009 applies; cross-border transfers between NTP entities
EH-008 | Expatriate employee payroll data (US-assigned) | Salary, US tax withholding (W-2), social security, banking details for ~45 US-assigned expatriate employees | Cross-border payroll administration | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-053 | NTP PLC | Duration of US assignment + 7 years | Date of end of US assignment or termination of employment | US IRS record retention requirements; Income Tax (Earnings and Pensions) Act 2003; TIA-004 supplementary measures | Sunderland-Hayes contractually required to delete/return within 60 days of assignment end + 7-year retention; NTP archives in restricted HRIS partition | People & HR; Finance | Philippa Crane, Head of People & HR | No | Data transferred to Sunderland-Hayes Payroll Services Inc. (1400 Broadway, Suite 2200, New York, NY 10018, USA) under UK IDTA; TIA-004 applies; ~45 expatriate employees
EH-009 | Performance management records | Annual appraisal records, performance improvement plans, objective-setting documentation, 360-degree feedback reports, disciplinary warnings | Performance management, talent development, disciplinary processes | Legitimate interest (Art. 6(1)(f)); Contract performance (Art. 6(1)(b)) | ROPA-UK-043; ROPA-EU-IE-021 | NTP PLC; all EU subsidiaries | Duration of employment + 6 years; disciplinary warnings: per warning duration (typically 6–12 months on live file) then archived for duration of employment + 6 years | Date of termination of employment | Employment Rights Act 1996; Limitation Act 1980; ACAS Code of Practice on Disciplinary and Grievance Procedures | Automated deletion from HRIS; physical appraisal files shredded | People & HR | Philippa Crane, Head of People & HR | No
EH-010 | Training and professional development records | Training attendance, certifications, CPD records, mandatory compliance training completion, e-learning progress records | Skills development, regulatory compliance training tracking, professional accreditation | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) for mandatory training | ROPA-UK-044 | NTP PLC; all EU subsidiaries | Duration of employment + 3 years; mandatory regulatory training records: duration of employment + 7 years | Date of termination of employment | Health and Safety at Work etc. Act 1974; regulatory training requirements; GDPR Art. 39(1)(b) (DPO training) | Automated deletion from learning management system; archived certificates deleted per schedule | People & HR | Philippa Crane, Head of People & HR | No | Includes GDPR awareness training records for all 11,400 employees
EH-011 | Employee grievance and whistleblowing records | Grievance submissions, investigation reports, whistleblowing disclosures, witness statements, outcome letters | Grievance resolution, whistleblower protection, regulatory compliance | Legal obligation (Art. 6(1)(c)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-047 | NTP PLC; all EU subsidiaries | Duration of employment + 6 years; whistleblowing records involving regulatory reporting: 10 years from date of final resolution | Date of final resolution of grievance or whistleblowing investigation | Employment Rights Act 1996; Public Interest Disclosure Act 1998; Limitation Act 1980; EU Whistleblower Protection Directive (EU) 2019/1937 | Archived in secure restricted-access system; deletion upon expiry with HR Director and General Counsel sign-off | People & HR; Legal & Compliance | Philippa Crane, Head of People & HR | No | Whistleblower identity protected; access restricted to authorised investigation personnel
EH-012 | Employee IT equipment and device records | Device assignments, laptop serial numbers, mobile device IMEI, software licence assignments, device return records | IT asset management, employee offboarding, security controls | Legitimate interest (Art. 6(1)(f)); Contract performance (Art. 6(1)(b)) | ROPA-UK-049 | NTP PLC; all EU subsidiaries | Duration of employment + 12 months; device return confirmation: 3 years | Date of termination of employment or device return | GDPR Art. 5(1)(e); internal IT Asset Management Policy | Automated deletion from IT asset management system; devices securely wiped upon return per NIST SP 800-88 | IT Operations | Thomas Okoye, CISO | No
EH-013 | Contractor and temporary worker records | Contractor names, company affiliations, contract terms, IR35 assessment records, security clearance status, access credentials | Contractor management, IR35 compliance, access provisioning | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) for IR35 | ROPA-UK-051 | NTP PLC; all EU subsidiaries | Duration of engagement + 6 years; IR35 assessment records: 6 years from end of tax year in which engagement ended | Date of contract/engagement termination | IR35 off-payroll working rules (Finance Act 2021); Limitation Act 1980; HMRC requirements | Automated deletion from contractor management system; IR35 records archived then deleted per HMRC schedule | People & HR; Procurement | Philippa Crane, Head of People & HR | No | Part of ~28,000 contractors/temp workers/applicants/website visitors
EH-014 | Employee diversity and equality monitoring data | Ethnicity, gender identity, sexual orientation, disability status, religious belief (voluntarily provided) | Equality monitoring, diversity reporting, Gender Pay Gap reporting, public sector equality duty (for government contracts) | Explicit consent (Art. 9(2)(a)); Substantial public interest (Art. 9(2)(g)) for equality monitoring | ROPA-UK-054 | NTP PLC | Anonymised and aggregated immediately upon collection for reporting; individual-level data: duration of employment + 12 months then deleted | Date of termination of employment | Equality Act 2010; Gender Pay Gap Information Regulations 2017; DPA 2018, Sch. 1, Para. 8 (equality monitoring) | Individual responses anonymised immediately; aggregated reports retained indefinitely; individual-level data deleted from HRIS after retention period | People & HR | Philippa Crane, Head of People & HR | Yes — racial/ethnic origin, religious beliefs, sexual orientation, health data (Art. 9 GDPR) | Voluntary disclosure; anonymisation at point of collection for aggregate reporting; DPIA-009 applies
EH-015 | Employee travel and expense records | Travel bookings, expense claims, receipts, corporate card statements, travel itineraries | Expense reimbursement, financial control, tax compliance | Contract performance (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-055 | NTP PLC; all EU subsidiaries | Duration of employment + 7 years | Date of expense claim submission or date of termination of employment (whichever is later) | HMRC requirements; Companies Act 2006; VAT Act 1994 | Automated deletion from expense management system; physical receipts shredded after digitisation | Finance; People & HR | Head of Finance | No
EH-016 | Employee workplace monitoring data | Email metadata (not content), internet usage logs, building access swipe data, print logs | IT security, acceptable use policy enforcement, workplace safety | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-056; ROPA-EU-DE-018 | NTP PLC; Northgate GmbH | 6 months from date of log entry; extended to 12 months where disciplinary or security investigation initiated | Date of log entry or date of investigation closure | GDPR Art. 5(1)(e); German BDSG §26 (employee monitoring restrictions); ICO Employment Practices Code | Automated log rotation and purge; investigation-related data archived then deleted per schedule | IT Security; People & HR | Thomas Okoye, CISO | No | LIA completed for workplace monitoring; German works council (Betriebsrat) consulted for Northgate GmbH
[sheet: Operational & Security Data]
Ref No. | Data Category | Description / Examples | Processing Purpose | Lawful Basis | ROPA Reference | Applicable Entity | Retention Period | Retention Start Trigger | Regulatory / Legal Basis for Retention | Deletion / Anonymisation Method | Responsible Business Unit | Responsible Data Steward | Special Category Data (Yes/No) | Notes
OS-001 | CCTV footage (non-biometric) | Video surveillance footage at offices, data centres, and facilities (excluding facial recognition) | Physical security, crime prevention, health & safety | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-060; ROPA-EU-DE-018; ROPA-EU-NL-011; ROPA-EU-IE-022 | NTP PLC; Northgate GmbH; Northgate B.V.; Northgate Ireland Ltd | 30 days from date of recording; extended to 90 days if incident under investigation | Date of recording | ICO CCTV Code of Practice; Surveillance Camera Code of Practice (UK); BDSG §4 (Germany); DPIA-008 outcome — facial recognition pilot discontinued 14 June 2023 | Automatic overwrite of CCTV storage after 30 days; incident-related footage exported and retained in case management system for 90 days then deleted | Facilities / IT Security | Thomas Okoye, CISO | No | Facial recognition pilot (DPIA-008) was recommended for discontinuation and accepted by NTP Board 14 June 2023; standard CCTV retained without biometric processing
OS-002 | Network traffic logs and anomaly detection data | Packet headers, flow data, intrusion detection alerts, network anomaly flags containing subscriber metadata | Network security, anomaly detection, cybersecurity incident response | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) for security of processing under Art. 32 | ROPA-UK-062 | NTP PLC | 90 days for routine logs; 12 months for confirmed security incidents; 24 months for data retained under regulatory investigation | Date of log entry or date of incident closure | GDPR Art. 32; Network and Information Systems Regulations 2018 (NIS Regulations); Ofcom Security Guidance | Automated log rotation and purge; incident data archived then deleted per schedule | IT Security / Network Operations | Thomas Okoye, CISO | No | DPIA-002 applies (Network traffic analysis and anomaly detection)
OS-003 | Lawful intercept and communications data retention | Data retained under lawful interception warrants and data retention notices (call data records, subscriber information, traffic data) | Compliance with lawful interception obligations | Legal obligation (Art. 6(1)(c)) | ROPA-UK-065 | NTP PLC (UK only) | As specified in individual retention notices or warrants; default: 12 months from date of communication | Date of communication | Investigatory Powers Act 2016, Parts 4 and 6; Regulation of Investigatory Powers Act 2000; Data Retention and Acquisition Regulations 2018 | Automated deletion upon expiry of retention notice period; restricted access with audit trail; data subject access restrictions apply under DPA 2018, Sch. 2, Part 1 | Legal & Compliance; Network Operations | Fiona Gallagher, General Counsel | No | DPIA-010 applies; highly restricted access; exemption from certain DSAR obligations per DPA 2018 Sch. 2
OS-004 | IT system access logs and authentication records | User login/logout timestamps, IP addresses, device identifiers, multi-factor authentication records, privileged access logs | IT security monitoring, access control audit, regulatory compliance | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-067; ROPA-EU-IE-024 | NTP PLC; all EU subsidiaries | 12 months from date of log entry; privileged access logs: 24 months | Date of log entry | GDPR Art. 32; NIS Regulations; ISO 27001 controls | Automated log rotation and secure purge; archived logs cryptographically erased | IT Security | Thomas Okoye, CISO | No | Covers access to systems hosted by Pinnacle Cloud Services Ltd; Pinnacle DPA (amended 28 June 2023) includes audit log retention obligations
OS-005 | Data centre physical access logs | Entry/exit timestamps, badge swipe records, visitor logs, vehicle registration data at London, Frankfurt, Amsterdam, Dublin data centres | Physical security, access audit trail | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-069; ROPA-EU-DE-019; ROPA-EU-NL-012; ROPA-EU-IE-025 | NTP PLC; Northgate GmbH; Northgate B.V.; Northgate Ireland Ltd | 12 months from date of entry; visitor logs: 6 months | Date of access event | GDPR Art. 32; ISO 27001; data centre certification requirements | Automated purge from access management system; visitor log shredding (physical) | Facilities / IT Security | Thomas Okoye, CISO | No | Linked to biometric access controls (EH-005); DPIA-005 applies to biometric component
OS-006 | Pinnacle Cloud Services infrastructure support data | System configuration data, incident tickets, change management logs containing NTP employee and subscriber identifiers accessed by Pinnacle India Pvt Ltd and Pinnacle APAC Pte Ltd | Cloud infrastructure management, incident response, change management | Legitimate interest (Art. 6(1)(f)); Contract performance (Art. 6(1)(b)) | ROPA-UK-070 | NTP PLC (controller); Pinnacle Cloud Services Ltd (processor); Pinnacle India Pvt Ltd and Pinnacle APAC Pte Ltd (sub-processors) | Duration of Pinnacle DPA + 90 days for deletion/return; incident tickets: 24 months | Date of incident or change management event; date of DPA termination | Amended DPA (NTP/Pinnacle, executed 28 June 2023); EU SCCs Module 3 (Processor to Sub-processor); UK Addendum; TIA-002 (India) and TIA-003 (Singapore) | Pinnacle contractually obligated to delete/return within 90 days of DPA termination; sub-processor data deletion verified via audit rights | IT Operations; Legal & Compliance | Thomas Okoye, CISO | No | TIA-002 covers Pinnacle India (Gurugram); TIA-003 covers Pinnacle APAC (Singapore); supplementary measures include AES-256 encryption, TLS 1.3, pseudonymisation
OS-007 | Security incident and forensic investigation data | Forensic images, malware samples, threat intelligence feeds, incident response timelines, affected user lists | Cybersecurity incident investigation, forensic analysis, regulatory reporting | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-063 | NTP PLC; all EU subsidiaries | Duration of investigation + 24 months; data subject to law enforcement request: retained until law enforcement confirms release | Date of incident closure or law enforcement release | GDPR Art. 32; NIS Regulations; Computer Misuse Act 1990; DPA 2018 | Forensic images securely wiped after retention period; malware samples retained in isolated sandbox; affected user lists deleted from incident management system | IT Security; Legal & Compliance | Thomas Okoye, CISO | No | Escalation to NCA Cyber Crime Unit where appropriate; legal hold may extend retention
OS-008 | Vulnerability scanning and penetration testing data | Vulnerability scan reports, penetration test results, remediation tracking data (may contain system owner identifiers) | Security vulnerability management, compliance with NIS Regulations, ISO 27001 certification | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-064 | NTP PLC; all EU subsidiaries | 24 months from date of scan/test; historical trend data: anonymised and retained for 5 years | Date of scan or penetration test completion | NIS Regulations; ISO 27001; Ofcom Security Guidance; PCI DSS (for payment systems) | Automated deletion from vulnerability management platform; anonymised trend data archived | IT Security | Thomas Okoye, CISO | No | Annual penetration tests conducted by independent third party
OS-009 | Email and communications archival (corporate) | Corporate email archives, Northgate Data Systems/Meridian Solutions logs, video conferencing recordings (where authorised) | Regulatory compliance, e-discovery readiness, internal investigations | Legitimate interest (Art. 6(1)(f)); Legal obligation (Art. 6(1)(c)) | ROPA-UK-066 | NTP PLC; all EU subsidiaries | 3 years from date of communication; extended under legal hold as required; video recordings: 12 months unless subject to legal hold | Date of communication or recording | Limitation Act 1980; Companies Act 2006; Civil Procedure Rules (e-discovery obligations); FCA requirements (where applicable) | Automated archival and purge from email system; legal hold overrides automated deletion; video recordings deleted from conferencing platform | IT Operations; Legal & Compliance | Thomas Okoye, CISO | No | Legal hold process managed by General Counsel; automated retention policies configured in Ashgrove Software
OS-010 | Backup and disaster recovery data | System backups containing personal data across all categories (encrypted), disaster recovery snapshots | Business continuity, disaster recovery | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-068 | NTP PLC; all EU subsidiaries | 90 days for incremental backups; 12 months for monthly full backups; backups containing data past primary retention period: cryptographically erased within 30 days of identification | Date of backup creation | GDPR Art. 5(1)(e) and Art. 17(1) (right to erasure — backup exception per ICO guidance); ISO 22301 business continuity | Cryptographic erasure of backup media; backup rotation schedule enforced; erasure verification logs maintained | IT Operations | Thomas Okoye, CISO | No | Challenge: ensuring erasure requests propagated to backup systems; automated tagging of erasure-flagged records implemented
OS-011 | DNS and web proxy logs | DNS query logs, web proxy access logs, URL filtering records containing employee and subscriber identifiers | Network security monitoring, acceptable use enforcement, threat detection | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-071 | NTP PLC | 90 days for routine DNS/proxy logs; 12 months for logs associated with confirmed security events | Date of log entry | GDPR Art. 32; NIS Regulations | Automated log rotation and purge; security event logs archived then deleted per schedule | IT Security / Network Operations | Thomas Okoye, CISO | No
OS-012 | Environmental monitoring and BMS data | Building management system logs, environmental sensor data (temperature, humidity, power), maintenance engineer identifiers | Data centre environmental control, preventive maintenance, capacity planning | Legitimate interest (Art. 6(1)(f)) | ROPA-UK-072; ROPA-EU-DE-020; ROPA-EU-NL-013; ROPA-EU-IE-026 | NTP PLC; Northgate GmbH; Northgate B.V.; Northgate Ireland Ltd | 24 months from date of log entry; maintenance engineer identifiers: 12 months | Date of log entry or maintenance event | ISO 27001; data centre Tier III/IV certification requirements | Automated purge from BMS; anonymisation of environmental trend data | Facilities | Thomas Okoye, CISO | No | Minimal personal data; primarily operational telemetry with incidental personnel identifiers
OS-013 | Supply chain and vendor personnel data | Vendor engineer names, contact details, security clearance records, site access credentials for third-party maintenance personnel | Vendor management, site access control, supply chain security | Legitimate interest (Art. 6(1)(f)); Contract performance (Art. 6(1)(b)) | ROPA-UK-073 | NTP PLC; all EU subsidiaries | Duration of vendor contract + 3 years; security clearance records: duration of clearance + 12 months | Date of vendor contract termination or clearance expiry | Limitation Act 1980; ISO 27001 supply chain controls | Automated deletion from vendor management system; access credentials revoked immediately upon contract end | Procurement; IT Security | Thomas Okoye, CISO | No
[sheet: Corporate & Legal Data]
Ref No. | Data Category | Description / Examples | Processing Purpose | Lawful Basis | ROPA Reference | Applicable Entity | Retention Period | Retention Start Trigger | Regulatory / Legal Basis for Retention | Deletion / Anonymisation Method | Responsible Business Unit | Responsible Data Steward | Special Category Data (Yes/No) | Notes
CL-001 | Board and governance records | Board minutes, committee papers, director personal details, declarations of interest, share ownership records | Corporate governance, statutory compliance, regulatory filings | Legal obligation (Art. 6(1)(c)) | ROPA-UK-075 | NTP PLC | Permanent retention for Board minutes and statutory registers; director personal data: duration of directorship + 10 years | Date of director resignation or removal | Companies Act 2006, ss.248, 355; UK Corporate Governance Code; Listing Rules | Physical archives maintained; digital records in secure governance portal with restricted access | Legal & Compliance; Company Secretariat | Fiona Gallagher, General Counsel & Company Secretary | No
CL-002 | Regulatory correspondence and enforcement records | ICO/DPC correspondence, enforcement notices, regulatory submissions, inquiry response documentation | Regulatory compliance, enforcement defence, institutional knowledge | Legal obligation (Art. 6(1)(c)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-077 | NTP PLC; Northgate Ireland Ltd | Duration of regulatory matter + 10 years from final resolution; ICO Enforcement Notice ENF/2021/0934: indefinite retention as precedent record; DPC inquiry IN-22-11-3: duration of inquiry + 10 years | Date of final determination or closure of regulatory matter | GDPR Art. 5(2) accountability; DPA 2018; Communications Act 2003; Data Protection Act 2018 | Archived in legal hold system; deletion only upon expiry of retention period and sign-off by General Counsel | Legal & Compliance | Fiona Gallagher, General Counsel | No | ICO fine of £320,000 paid (ENF/2021/0934); DPC inquiry IN-22-11-3 remains active as of engagement close (8 September 2023)
CL-003 | Data subject rights request records | DSARs, rectification/erasure/restriction/portability requests, identity verification records, response correspondence, decision logs | Compliance with data subject rights (GDPR Arts. 15-22), accountability, defence of legal claims | Legal obligation (Art. 6(1)(c)) | ROPA-UK-078; ROPA-EU-IE-027 | NTP PLC; all EU subsidiaries | 3 years from date of completion of request response | Date of final response to data subject | GDPR Arts. 15-22; DPA 2018; Limitation Act 1980 (potential claims); EDPB Guidelines on data subject rights | Automated deletion from DSAR management system (Sundial Solutions); physical correspondence shredded | Legal & Compliance; DPO Office | Sanjay Mehta, Data Protection Officer | No | SLAs per Data Subject Rights Procedure: response within 1 calendar month, extendable by 2 months for complex requests
CL-004 | Data breach records | Breach investigation reports, root cause analyses, notification records (ICO/DPC/data subjects), remediation logs | Breach notification compliance, accountability, continuous improvement | Legal obligation (Art. 6(1)(c)) | ROPA-UK-080 | NTP PLC; all EU subsidiaries | 5 years from date of breach closure; indefinite if breach resulted in regulatory enforcement or litigation | Date of breach closure or final resolution of enforcement/litigation | GDPR Arts. 33-34; DPA 2018; Breach Notification Procedure (72-hour notification protocol) | Archived in legal hold system; deletion upon expiry subject to General Counsel sign-off | Legal & Compliance; IT Security; DPO Office | Sanjay Mehta, Data Protection Officer | No | Escalation chain: CISO (Thomas Okoye) → DPO (Sanjay Mehta) → General Counsel (Fiona Gallagher); 72-hour notification to ICO/DPC
CL-005 | GDPR compliance programme records | ROPA documentation, DPIAs, TIAs, LIAs, policies, training records, audit reports, engagement records with Calderwood & Harkness LLP and Ashdown Consulting Group Ltd | Accountability, compliance demonstration, audit readiness | Legal obligation (Art. 6(1)(c)); Legitimate interest (Art. 6(1)(f)) | ROPA-UK-082 | NTP PLC; all EU subsidiaries | Duration of processing activity to which record relates + 7 years; engagement records with C&H (SC/NTP/2023-0213/PDS): 7 years from engagement close (8 September 2023); training records: 3 years from date of training | Date of completion/closure of relevant activity, engagement, or training event | GDPR Art. 5(2) accountability; Art. 24 controller responsibility; Art. 30 ROPA obligation; Art. 35 DPIA obligation; DPA 2018 | Archived in compliance management system (Sundial Solutions); physical documents in secure archive; deletion upon expiry with DPO authorisation | Legal & Compliance; DPO Office | Sanjay Mehta, Data Protection Officer | No | Includes all 147 ROPA entries, 11 DPIAs, 6 TIAs, Legitimate Interest Assessments for 64 activities; Whitmore Kendall LLP (statutory auditors) consulted on Audit & Risk Committee reporting framework
CL-006 | Anti-money laundering and financial crime records | KYC documentation, suspicious activity reports, sanctions screening results | Prevention of money laundering, terrorist financing, sanctions compliance | Legal obligation (Art. 6(1)(c)) | ROPA-UK-084 | NTP PLC | 5 years from end of business relationship or completion of one-off transaction | Date of end of business relationship or transaction | Proceeds of Crime Act 2002; Money Laundering,