BACKUP RETENTION AND DESTRUCTION POLICY

  1. Purpose
    The purpose of this Policy is to ensure that necessary data and documents of are adequately protected and maintained and to ensure that records that are no longer needed by  or are of no value are discarded at the proper time.  This Policy is also for the purpose of aiding employees of N-Squared eCommerce Company Limited in understanding their obligations in retaining electronic documents – including e-mail, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.
  2. Policy
    This Policy represents  N-Squared eCommerce Company Limited’s policy regarding the retention and disposal of data  and the retention and disposal of electronic documents.
  3. Administration
    Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for data of N-Squared eCommerce Company Limited and the retention and disposal of electronic documents.  The Data Protection Officer (the “Administrator”) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Data Retention Schedule is followed.  The Administrator is also authorized to: make modifications to the Data Retention Schedule from time to time to ensure that it is in compliance with laws and includes the appropriate document and data categories for N-Squared eCommerce Company Limited; monitor laws affecting data retention; annually review the data retention and disposal program; and monitor compliance with this Policy.
  4. Suspension of Data Disposal In Event of Litigation or Claims
    In the event N-Squared eCommerce Company Limited is served with any subpoena or request for documents or any employee becomes aware of an investigation or audit concerning N-Squared eCommerce Company Limited or the commencement of any litigation against or concerning N-Squared eCommerce Company Limited, such employee shall inform the Administrator and any further disposal of documents shall be suspended until shall time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of data.
  5. Applicability
    This Policy applies to data generated in the course of N-Squared eCommerce Company Limited’s operation, including both original and reproductions.

Data TypeRetention Period
Electronics Data5 years or complied with the governing laws
Transactional Data5 years or complied with the governing laws
APPENDIX A: BACKUP RETENTION SCHEDULE