Data Protection: Guidance on data deletion

Introduction

Within IRIS Accountancy Suite (IAS) there are some useful features that can assist with any data retention/minimisation requirements to delete data after a certain time frame, including features that can help to determine age of data and identify what data to delete:

IRIS Practice Management users can set up a service to allow the monitoring of when a client starts or leaves.

• The New Client standard service feature can be used for this. See KnowledgeBase articles:
  

• IAS-11924: Recording clients leaving and joining the practice
  
  and

• IAS-6679: What is the 'Take on new client' standard job type for

• The Practice Management | Data Mining feature can be used to search on the Services | Date Started or the Date Terminated fields. This could be used to produce a list of ex-clients based on date criteria.

There are various other methods existing IRIS customers use to flag and manage ex-clients:

• use a client category to label clients as ex-clients. The client category is populated with values for month and year left, then reports and lists can be generated using that property as a filter to determine clients associated with it.
  

• use attributes on the clients to say they are ex-clients.

• use the client ID and enter, for example, ZZZ at the beginning to flag them as ex-clients.

• within the client browser there is the option to show the database view of clients not registered in any products which could be an indicator they are no longer in use.

The data that is entered and saved in IAS can be deleted with the appropriate staff permissions:

• on a client by client basis - select Client | Delete

• for clients in bulk - select Client | Bulk Delete or System Maintenance | Bulk Delete

• on a staff by staff basis – select System Maintenance | Staff | Staff Maintenance | View | Delete

• also delete staff email addresses – select System Maintenance | Practice | E-mail Accounts

• Where Time and Fees data has been posted against a staff member, the staff member cannot be deleted but this can be mitigated by anonymising the staff member. To anonymise the staff member log into Staff Maintenance | Staff | Staff Maintenance, highlight the staff member and select View.

• The data that is held in IAS for each client can also be deleted on a product / service basis. This might sometimes be required so the client as an entity is retained but the data for services provided to the client can be removed. Also, as IAS is an integrated database the businesses, people and trusts are linked with other entities and may have data entered between the integrated entities. When using the client delete process any data entered against the integrated entities is identified within the delete pre-pass list for deletion. Occasionally it may be preferred that integrated entity data is retained. For example, if deleting a business and not wanting to affect the persons tax information where employment income is entered.
  
• Within IAS there are some limitations around deleting data to highlight:
  
• It is not possible to delete client or staff data if there is IRIS Time & Fees postings against:
  
• the client – if there is any IRIS Time & Fees posted against that client you will need to de-register it in IRIS Time & Fees first before it can be deleted.  This is identified as part of the client delete process or separately, see KnowledgeBase article IAS-6092: How can I de-register and then delete a client from Time and Fees?
  
• the staff member – if there is any IRIS Time & Fees data posted against the staff member, the staff member cannot be deleted but this can be mitigated by anonymising the staff member.

It is not possible to delete a client if they are a shareholder within another company. Where the shareholding they have needs to be removed or altered, select the business in which they hold shares, then select Client Maintenance | Shares | Members | highlight the Member and select Delete.

For each of the products the following delete processes may be useful for leaving the client as an entity within IRIS Accountancy Suite but deleting product/service specific data, options are listed by what will remove the most data per product to the least data without deleting the client as an entity:

• IRIS General

• Delete each accounting period end date – select Client | View | Periods | Delete. This removes the Accounts Production data screen information, associated posting entries in Accounts Production, associated posting entries in Business Tax and Fixed Asset Register records for the period end.
  
• Delete relationships to other clients
  
• Involvements – select Client | View | Related [tab]| Involvements. Select View and Delete.
  
• Marriages - select Client | View | Marriages. Select View and Delete.
  
• Delete contacts
  
• Internal - select Client | View | Contacts [tab]. Under the Internal Contacts section select View and Delete.
  
• External - select Client | View | Contacts [tab]. Select View and Delete. Under the External l Contacts section select View and Delete.
  
• Delete client history per event – select Client Maintenance | History [tab] | View | Delete
  

• Delete people or businesses who are not clients.

• Delete bank accounts – select System Maintenance | System | Browse Bank Accounts

• Delete branches/alternative accountants /alternative auditors - select Client | View | Auditor or Accountant. Select the branch/alternative accountant/alternative auditor and then click  the magnifying glass and highlight the branch/alternative accountant/alternative auditor, finally select View and Delete.
  

• Accounts Production/Auditor/Charities:

• Delete the entire post file – select Posting | Post File Maintenance | Delete. Also, see KnowledgeBase article IAS-1024: How do I reduce the number of clients on my Package limit?
  

• Delete each accounting period end date – select Edit | Account Period End Dates | Delete. See IRIS General reference below for all data that is removed as part of this delete process.

• Delete individual posting entries – select Posting | Post File Maintenance | View | Delete. Also, see KnowledgeBase article IAS-2055: How to delete a Posting Entry?

• Delete data screen entries - these can only be deleted as part of the accounting period end date delete process referenced above. Alternatively select Edit | Data Screens | File | Revert to Default Values and this will clear out any personal notes.
  
• Delete each branch – select Edit | Branches | Delete
  
• Delete each enterprise (farms only) - select Edit | Enterprises | Delete
  
• Delete each fund/activity/grant – select Edit | Funds/Activities/Grants | Delete
  
• Delete the entire share register – select Edit | Share Register | Status | Delete
  
• Delete the director's shareholdings per accounting period end date – select Edit | Shareholdings | select Director, Shareholdings, Select Accounting Period End Date | Delete
  
• Delete partner profit shares per profit share date – select Edit | Partner Profit Shares | Delete date
  

• Company Secretarial

• Delete some company secretarial data – select Client | De-register Client | OK. This removes the printing and e-filing status records for the forms but leaves the logged history/form entries intact.
  

• Delete the entire share register - select Edit | Share Register | Status | Delete

• Delete being a member/shareholder in a company – select the company, Edit | Share Register | Members [tab] | Delete.

• Careful review and consideration needs to be given to the entries that are identified for deletion using this process as it may adversely affect the accuracy of the selected company's share register.

• Delete people with significant control – select Edit | People with Significant Control | View | Delete
  

• Delete mortgages and charges – select Edit | Charges | Edit | Delete

• Delete the individual form, history and e-filing data – select Reports | Company Forms | View Entry | Delete

• Delete individual meetings – select Edit | Meetings | View | Delete

• Delete personal authentication data – select Edit | Personal Authentication Data | View | remove the data in each of the fields and click Save.
  
• Delete search information saved from Companies House – select Client | Companies house Online Service | Main/Free Online Service | Filter results to show saved results for the selected client | highlight results | Delete
  
• Delete documents downloaded and saved from Companies House– select Reports | CHOS Download Documents | select all relevant documents and click Action | Delete
  

• Company Formations

• Delete the entire share register - select Edit | Share Register | Status | Delete
  
• Delete people with significant control – select Edit | People with Significant Control | View | Delete
  
• Delete the form, history and e-filing data – select Reports | Company Forms | View Entry | Delete
  
• Delete the Memorandum and Articles – these can only be deleted as part of the client delete process. Alternatively select Edit | Memorandum and Articles | Edit | Apply Default Values and this will clear out any personal notes.
  
• Delete personal authentication data – select Edit | Personal Authentication Data | View | remove the data in each of the fields and click Save.
  
  

• Personal Tax  

• Delete one tax year – select Edit | Delete Tax Year Data|
  

• Delete specific involvements with other clients – select Client | View | Related [tab] | Involvements.

• Data entered against Employment or Trade, Profession or Vocation will also be removed as part of the disassociation between clients.

• Delete an accounting period for the trade – select Trade Profession or Vocation | select Sole Trade or Partnerships | select the accounting period and click Delete. Also, see KnowledgeBase article IAS-12034: How to delete an accounting period via Personal Tax.
  
• Delete each individual capital asset – select Edit | Capital Assets | Assets/Shareholdings/Other Capital Gains | Delete
  

• Delete the individual's losses and other information - select Edit | Losses | remove the values in each of the fields and click OK.

• Delete all or individual e-Checklists – select Administration | e-Checklists | e-Checklist Status | Delete

• Delete internet returns – select Reports | Transmit Internet Returns | All Returns or Selected Client | Delete

• Delete individual client account postings – select Administration | Client Account | Delete
  
  

• Business Tax

• Delete one tax year for non-resident only (SA700) – select Edit | Delete Tax Year Data
  

• Delete each accounting period end date – select Client | View | Periods | Delete. See IRIS General reference below for all data that is removed as part of this delete process.

• Delete individual business tax posting files – select Edit | Posting | Delete

• Delete individual Accounts Production posting files – select Accounts Production | Posting | Post File Maintenance | View | Delete. Also, see KnowledgeBase article IAS-2055: How to delete a Posting Entry?

• Delete each individual capital asset – select Edit | Capital Assets | Assets/Shareholdings/Other Capital Gains | Delete

• Delete the capital losses and other information - select Edit | Capital Assets | Edit Losses and Other Information | remove the values in each of the fields and click OK.

• Delete losses – select Edit | Losses | remove the values in each of the fields and click OK.

• Delete capital allowances – select Edit | Capital Allowances | A – Maintain Asset Details | Delete Asset

• Delete all trades – select Edit | Multiple Trades | Trade Maintenance | Delete

• Delete group relief – select Data Entry | Group and Consortium (CT600C) | remove the values in each of the fields and click OK.

• Delete one tax year for partnership returns only (SA800) – select Trades | Partnerships | Overwrite/Leave Alone | No – Leave alone. Remove the data from the data entry screens.

• Delete internet returns – select Reports | Transmit Internet Returns | All Returns or Selected Client | Delete

• Delete individual client account postings – select Administration | Client Account | Delete
  

• Trust Tax

• Delete one tax year – Select Edit | Delete Tax Year Data
  

• Delete specific involvements with other clients – select Client | View | Related [tab] | Involvements.

• Data entered against Trade, Profession or Vocation will also be removed as part of the disassociation between clients.

• Delete each individual capital asset – select Edit | Capital Assets | Assets/Shareholdings/Other Capital Gains | Delete
  

• Delete the individuals losses and other information - select Edit | Losses | remove the values in each of the fields and click OK.

• Delete internet returns – select Reports | Transmit Internet Returns | All Returns or Selected Client | Delete

• Delete individual client account postings – select Administration | Client Account | Delete
  

• Fixed Asset Register

• Delete each accounting period end date – select Client | View | Periods | Delete. See IRIS General reference below for all data that is removed as part of this delete process.
  

• Delete each individual asset – select Edit | Asset Browser | Delete Asset
  

• P11D

• Delete one tax year – select Edit | Delete this year's data
  

• Delete each individuals' employment benefits – select Edit | Employment benefits | Delete

• Delete each individuals' car benefits (detail) – select Edit | Car benefits | Delete

• Delete internet returns – select Reports | Transmit Internet Returns | All Returns or Selected Client | Delete
  

• Practice Management

• Delete client notes - select Client | View | Notes [tab]. Highlight the note and select Delete.
  

• Delete communication tracking – From the Staff Control Panel select the Communications [tab]. Highlight the appropriate item, select Action… | Delete.

• Any data pertaining to IRIS Docs must be manually removed from IRIS Docs.

• Delete attributes – from System Maintenance, select Practice | Client Attributes. Select Delete Category or Delete Attribute.
  

• Delete tasks - From the Staff Control Panel highlight the task and select Delete. The task is also automatically deleted where a) the client or b) Assigned to staff member is deleted.
  

• Time and Fees  

• De-register the client from Time and Fees - See KnowledgeBase article IAS-6092: How can I de-register and then delete a client from Time and Fees?. As part of the house keeping process, the client ID and the name is inserted into the narrative fields and whilst this does not pose any risk, data controllers are able to change the Client ID and Name to anonymise the client prior to running the Time and Fees housekeeping process.
  
• Where data has been posted against a staff member, the staff member cannot be deleted but this can be mitigated by anonymising the staff member.

We are currently creating a client cleansing process which will make it easier to delete an entity's records but retain minimal data required for the preservation of integrated client’s data. We hope to make this available in a release soon.