We should look at this one again to ensure it is not a blocker for the 2019 data purge

In T207135#5482659, @Lokal_Profil wrote:

We should look at this one again to ensure it is not a blocker for the 2019 data purge

I will check what time the HR department at my job has. The current time for keeping applications was based on the information I got from them, but they might have changed it.

In T207135#5485165, @Historiker wrote:

In T207135#5482659, @Lokal_Profil wrote:

We should look at this one again to ensure it is not a blocker for the 2019 data purge

I will check what time the HR department at my job has. The current time for keeping applications was based on the information I got from them, but they might have changed it.

Thanks!

In T207135#5485165, @Historiker wrote:

In T207135#5482659, @Lokal_Profil wrote:

We should look at this one again to ensure it is not a blocker for the 2019 data purge

I will check what time the HR department at my job has. The current time for keeping applications was based on the information I got from them, but they might have changed it.

@Historiker Did you get any response from the HR department?

Also to answer. Do the same rules apply to interns or is it tied to a salary.

@Historiker Did you get a response from your HR department?

The info from @Historiker still says 10 years.

The only two sections in the linked document that lead me to believe something different are:

Föräldraledighet

Till dess att barnet fyllt tolv år har en förälder har rätt till ledighet för vård av barn. Vissa av dessa dagar är semesterlönegrundande. Barnets ålder och uppgift om antalet dagar med föräldraledighet ska därför sparas två år efter det sista möjliga dagen för föräldraledighet, uppgifter om föräldraledighet därför arkiveras tills barnet fyllt 14 år i praktiken.

In practice that means any employee who got a child during their employment would need records retained up to 14 years after the employment has ended.

Anställningsavtal

Två år efter att anställningen har upphört kan anställningsavtal gallras. Dock måste företaget dokumentera anställningstiden på något sätt så länge en ny anställning kan bli aktuell. Arbetstagare får tillgodoräkna sig anställningstid från alla anställningar oavsett hur långt tillbaka i tiden som de ligger. Detta enligt lagen om anställningsskyddsregler om anställningstid . Det innebär i praktiken att uppgift om anställningstid måste sparas till dess arbetstagare fyllt 67 år.

Which translates into having to save this document forever
Note that this is in no way urgent. The first employee left the organisation 2012-12-30 so their records would be purges in 2023 at the earliest,

The more urgent aspect of this is likely how we deal with corresponding data about:

• Interns (Praktikanter)
• Prao-students

Especially the latter since they are by definition minors at the time.

In T207135#6776725, @Lokal_Profil wrote:

The more urgent aspect of this is likely how we deal with corresponding data about:

• Interns (Praktikanter)
• Prao-students

Especially the latter since they are by definition minors at the time.

Still have no info on this nor sure where we could find it =/

In T207135#7777127, @Lokal_Profil wrote:

In T207135#6776725, @Lokal_Profil wrote:

The more urgent aspect of this is likely how we deal with corresponding data about:

• Interns (Praktikanter)
• Prao-students

Especially the latter since they are by definition minors at the time.

Still have no info on this nor sure where we could find it =/

My initial thinking is that there likely is no point for us to handle Interns (Praktikanter) differently than paid staffs "anställningsavtal", as a new hire theoretically could be possible. If we later find that this is not the case we can adjust our "rensningsrutin" and remove their documents.

One way to find the info could perhaps be to reach out to and ask Integritetsskyddsmyndigheten. If they are unable to answer specific questions, we could reach out to Stockholm stad and request their documents regarding both interns and prao (i.e. "begära ut offentlig handling").

In T207135#7789982, @Jopparn wrote:

In T207135#7777127, @Lokal_Profil wrote:

In T207135#6776725, @Lokal_Profil wrote:

The more urgent aspect of this is likely how we deal with corresponding data about:

• Interns (Praktikanter)
• Prao-students

Especially the latter since they are by definition minors at the time.

Still have no info on this nor sure where we could find it =/

My initial thinking is that there likely is no point for us to handle Interns (Praktikanter) differently than paid staffs "anställningsavtal", as a new hire theoretically could be possible. If we later find that this is not the case we can adjust our "rensningsrutin" and remove their documents.

There are some differences since we are legally obliged to keep some info on paid staff whereas I don't believe the same requirements apply to interns. For the actual contract that can probably be saved almost indefinitely but for e.g. evaluations we want to hold on to them for as long as the person is likely to want to use us as a reference and for information on e.g. absences and dietary requirements we probably want to get rid of the information sooner.

One way to find the info could perhaps be to reach out to and ask Integritetsskyddsmyndigheten. If they are unable to answer specific questions, we could reach out to Stockholm stad and request their documents regarding both interns and prao (i.e. "begära ut offentlig handling").

I don't believe Integritetsskyddsmyndigheten answers individual questions like that. Asking Stockholms stad for the info is a good idea. Might try to use handlingar.se for this.

Data requested from Stockholms stad.

https://handlingar.se/sv/request/rutiner_for_lagring_av_personupp

Stockholms stad has replied with their rules for what personnel records get created and when they get purged (gallrad). The records of interns are handled the same as for employees. For "feriearbetande ungdomar" (which we can probably compare to our Prao category) the records are stored separately but purged according to the same rules.

I'll make a summary of categories for how long various types of records are kept. Note that the wast majority of employee records are saved indefinitely.

In T207135#7973895, @Lokal_Profil wrote:

Stockholms stad has replied with their rules for what personnel records get created and when they get purged (gallrad). The records of interns are handled the same as for employees. For "feriearbetande ungdomar" (which we can probably compare to our Prao category) the records are stored separately but purged according to the same rules.

I'll make a summary of categories for how long various types of records are kept. Note that the wast majority of employee records are saved indefinitely.

Note that the original document from Stockholms stad seems to have gotten lost when handlingar.se removed all pre-existing data

In T207135#9026761, @Lokal_Profil wrote:

In T207135#7973895, @Lokal_Profil wrote:

Stockholms stad has replied with their rules for what personnel records get created and when they get purged (gallrad). The records of interns are handled the same as for employees. For "feriearbetande ungdomar" (which we can probably compare to our Prao category) the records are stored separately but purged according to the same rules.

I'll make a summary of categories for how long various types of records are kept. Note that the wast majority of employee records are saved indefinitely.

Note that the original document from Stockholms stad seems to have gotten lost when handlingar.se removed all pre-existing data

I did however find my own summary based of that document.

For a lot of document types the data is never purges. This includes, but is not limited to:

• Any information related to disciplinary actions
• Any documents related to recruitment and hiring (if the person was hired)
• Documentation on salary changes

These are in general the documents we would consider to be part of the Personalakt.

Other documents are purged as soon as they are not relevant e.g. meeting notes, diary notes etc. which were intended to serve as a basis for action plans, official decisions or as supporting documentation in case of disputes etc.
These are in general the documents held directly by the ED.

Based on this I would suggest the following for staff records (and equivalent records on interns and Prao):

1. Documents in the Personalakt are not purged, but X years after the employment has ended we go through the Personalakt to ensure it only contains relevant documents (not informal notes etc.)
2. Documents held by the ED on staff interactions are purged after Y years, but the documents should probably be reviewed continuously to ensure they don't contain information which should actually be part of the Personalakt.

My suggestion would be to have both X and Y = 2-3 years. Especially the ED-notes can be very sensitive.
Rule 1 could be expanded with a list of document types which can be purged/don't need to be kept to further clarify.

@Historiker @Jopparn

In T207135#9026761, @Lokal_Profil wrote:

Note that the original document from Stockholms stad seems to have gotten lost when handlingar.se removed all pre-existing data

Wayback Machine has an archived copy of the conversation but unfortunately this does not include the attached documents.

For future memory there is also https://vismaspcs.se/ditt-foretagande/sakerhet/gallring-gdpr-lon which is likely more relevant

Finally implementing this should also coincide with T287489: GDPR document for staff hiring ("Personuppgiftspolicy – Behandling av anställdas personuppgifter") to avoid the need for additional updates.