Document
Retention Period
Beginning of Retention Period
Legal Reference
EMPLOYMENT RECORDS
Contracts (new hire agreements, severance, etc.)
Contracts: Minimum 10 years (in case certificate of employment is requested)
From termination
Employment Contracts Act (55/2001), Ch. 6, Sec. 7
Time records (work hours, rest periods, vacation/sick/ holiday, etc.)
1. Notes and documentation relating to payroll: Minimum 6 years; 2. Motor vehicle drivers' personal driver's logs: Minimum 1 year; 3. Working hours register: Minimum 2 years; 4. Holiday records: Minimum 2 years
1. From end of fiscal year; 2. From date driver's records are submitted to employer; 3. Active employee: From end of year record was made, Terminated employee: From termination; 4. Active employee: From end of year record was made, Terminated employee: From termination
1. Accounting Act (1336/1997, Ch. 2, Sec. 10); 2 & 3. Working Hours Act (605/1996, Ch. 7 & 8); 4. Annual Holidays Act (162/2005, Ch. 6, Sec. 29 & 34)
Performance records (performance reviews, promotions/demotions, licenses/certifications, investigations, disciplinary actions, etc.)
1. Performance records: Minimum 5 years (in case certificate of employment is requested); 2. Disciplinary/ grievance records: Maximum 10 years
From termination
1. Employment Contracts Act (55/2001), Ch. 6, Sec. 7; 2. Limitations Act (728/2003), Sec. 7; and, the Finnish Business Archive Association's non-binding recommendation
Data and personnel files
General: Retain as long as necessary for pre-defined purpose(s) of use and necessity requirement is met. Maximum 2 years if there is no need to retain data for longer period.
From termination
Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3; Employment Contracts Act (55/2001), Ch. 13, Sec. 9; The Finnish Data Protection Authority's non-binding recommendation
Government verification records (work papers, immigration, eligibility to work, etc.)
1. Alien records: Minimum 4 years; 2. Contracted work - certificates and records specified in the law: Minimum 2 years
From termination
1. Aliens Act (301/2004), Ch. 5, Sec. 86a; 2. Act on the Contractor’s Obligations and Liability when Work is Contracted Out (1233/2006), Sec. 5
Collective bargaining/union
May be retained permanently, provided does not include personal data; If includes personal data: Maximum as long as necessary for pre-defined purpose
From end of recording
Best practice; GDPR art 5(1)(e); Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3
Background checks and drug tests
Background checks: Maximum 6 months; Drug tests: Delete immediately when no longer necessary for purpose. Reason and need for processing should be re-evaluated at maximum of five-year intervals. Note: Finnish Data Protection Ombudsman recommends deletion/re-evaluation be carried out at maximum two-year intervals.
From receiving results of test or check
Act on Background Checks (726/2014), Ch. 6, Sec. 45; Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 5 and Ch. 3, Sec. 6; The Finnish Data Protection Authority's non-binding recommendation on "Työelämän tietosuojan käsikirja", updated June 21, 2018.
Acknowledgements, policy agreements and required notices
May be retained permanently, provided there's no personal data; If includes personal data: Maximum as long as necessary for pre-defined purpose
From creation
Best practice; GDPR art 5(1)(e); Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3
Recruitment (interview notes, resumes/CVs, reference checks, etc.)
1. Unsuccessful applicants: Minimum one year based on potential for employee claims (compensation and discrimination). Non-binding recommendation from Finnish Business Archive Association is to retain application forms and interview notes for two years; 2. Successful applicants: Recommended to retain job application and resume for employment plus 5 years; If necessary to store longer, retain only as long as necessary for recruitment process.
1 & 2. From end of recruitment process; If required to provide a certificate on employee's working skills and behavior: From termination of employment
1. Unsuccessful applicants: Non-discrimination Act (1325/2014), Ch 5, Sec. 26; Act on Equality between Women and Men (609/1986), Sec. 12; 2. Successful applicants: Employment contracts Act (55/2001), Ch. 6, Sec. 7 Best practice
Tracking/recordings (biometric, geo-location, online tracking, camera recordings, etc.)
1. Camera recordings: Retain only as long as necessary and no longer than 1 year, unless an approved exception, such as unfinished harassment investigation; 2. Location data: Retain only as long as necessary for purpose, then delete or anonymize, unless otherwise provided by law; 3. Biometric data: Retain only as long as necessary for pre-defined purpose
From end of recording/collection
1. Act on the Protection of Privacy in Working Life (759/2004), Ch. 5, Sec. 17; 2. Act on Electronic Communications Services, Ch. 20, Sec. 160; 3. GDPR art 5(1)(e); Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3
Miscellaneous 1
List of young workers: List must be up-to-date and outdated information should be deleted immediately
From recruitment or from employment
Young Workers’ Act (998/1993) Ch. 4
BENEFIT/PENSION/EQUITY RECORDS
Benefits (plan documents, enrollment records)
1. For information part of accounting material/ payroll records: Minimum 10 years; 2. Other documents: As long as necessary for purpose
1. From end of fiscal year; 2. From collection
Accounting Act (1336/1997), Ch. 2, Sec. 10; Act on taxation procedure on self-assessed taxes (768/2016), Ch. 4, Sec. 28
Pension records
1. Insurance and pension records: Minimum 10 years; 2. For information part of accounting material: Minimum 6 years
1. End of validity of insurance policy; 2. From end of fiscal year
1. & 2. Insurance Contracts Act (543/1994); Employees Pensions Act (395/2006); Limitations Act (728/2003), Sec. 7; Accounting Act (1336/1997), Ch. 2, Sec. 10
Equity records
General: No specific requirements, retain as long as necessary; Accounting related material: Minimum 6 years; Note: Shareholder records should be retained throughout company's operations
From end of fiscal year
Accounting Act (1336/1997), Ch. 2, Sec. 10; Limited Liability Companies Act (624/2006), Ch. 3, Sec. 15
PAYROLL/WAGE/TAX RECORDS
Payroll and wage data (payslips, etc.)
Payroll records: Minimum 10 years; Notes and supplemental documentation relating to payroll: Minimum 6 years
From end of fiscal year
Accounting Act 1336/1997 (Ch. 2, Sec. 10); Employment Contracts Act (55/2001, Ch. 13); Prepayment Act (1118/1996); Act on taxation procedure on self-assessed taxes (768/2016), Ch. 4, Sec. 28
Tax records
Minimum 10 years
From end of fiscal year
Accounting Act (1336/1997, Ch. 2, Sec. 10)
MEDICAL/SAFETY/LEAVE RECORDS
Leave (family, medical, etc.)
1. Notes and supplemental documentation relating to payroll: Minimum 6 years; 2. Holiday records: Minimum 2 years
1. From end of fiscal year; 2. Active employee: From end of year record was made; Terminated employee: From termination
1. Accounting Act (1336/1997, Ch. 2, Sec. 10); 2. Working Hours Act (605/1996, Ch. 7 & 8); Annual Holidays Act (162/2005, Sec. 29 & 34)
Injury and illness incident reports
Minimum 10 years (based on limitation concerning bodily injury caused to an employee)
From incident
Employment Contracts Act (55/2001), Ch. 13, Sec. 9; Limitations Act (728/2003), Sec. 7
Medical records
Only permitted for limited purposes. Erase immediately when no longer necessary for purpose. Reason/need for processing should be re-evaluated at maximum five-year intervals. Note: Finnish Data Protection Ombudsman recommends deletion or re-evaluation at maximum two-year intervals.
From recording
Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 5; Non-binding recommendation from the Finnish Data Protection Authority found in "Työelämän tietosuojan käsikirja", updated June 21, 2018.
Hazardous material and other exposure records
1. List of employees exposed to biological agents: Minimum 40 or 10 years depending on agent; 2. List of employees exposed to carcinogens (the ASA Register): Minimum 80 years
From end of exposure
1. Occupational Safety and Health Act (738/2002), Ch. 5, Sec. 40a; 2. Act on Respecting a Registry of Employees Exposed in Their Work to Carcinogenic Agents and Substances (717/2001), Sec. 5
Ultimate Software's HR Compliance Assist team relies on a network of internal and external compliance experts and lawyers to provide clients with best practices and recommendations on topics such as HR document retention, employee data privacy, and HR electronic records. HR Compliance Assist also provides local compliance monitoring and alert services in select countries where Ultimate Software's customers have employees. HR Compliance Assist is a service exclusively available to Ultimate Software customers.
