Introduction. 3
Schedule Structure. 3
Retention Calculation. 4
Definitions. 4
Contractual Retention Requirements. 5
Off-Site Storage. 5
Systems Storage. 6
Schedules by Business Function. 7
TELUS Health One. 4

Introduction

This Record Retention Schedule (“Schedule”) is meant to be read and interpreted in accordance with the Records Management Policy (“Policy”) and supersedes all previous versions of any Company retention schedules. This Schedule identifies specific retention periods that apply to U.S. and Canadian hard copy and electronic Records that require retention for legal, recordkeeping or business reasons. These retention periods will be used to enhance the Company’s enterprise-wide Record retention strategy as it continues to develop over time and be fully implemented.

The Schedule lists the retention Periods for the Official Record or final version of the Record, regardless of media or location of storage. Official Records that have met the Retention Period set out in this Schedule should be disposed of as long as they are not subject to a Legal Hold or Tax Audit Hold. Official Records may be stored in physical or electronic format.

Drafts, duplicates or convenience copies of Official Records should not be retained for longer than is necessary to perform a job responsibility and in no instance longer than the Retention Period for the Official Records, unless those records are subject to a Tax Audit Hold or Legal Hold.

The terms used in the Policy apply to this Schedule, with any newly introduced terms defined below.

Schedule Structure

Business Function: The Schedule is primarily organized by Business Function. Each Business Function represents a major category of business activity such as Finance and Accounting, Human Resources, or Tax. Each Business Function is listed in the Table of Contents. The Business Function is not intended to represent a specific department, but instead, to identify a broad category of activity or subject area.

Where a specific department or line of business has documents which are unique to that department or line of business, a separate Record category has been assigned.

Retention Calculation

Event Driven: All Records that have event-driven retention periods, such as “Lease of Property” or “Termination of Employment,” contain a retention period that is calculated from the event date. For example, if an employee departs in August of a particular year, his/her official Personnel Records are eligible for destruction 8 years after the date the employee departed.

Non-Event Driven: If the retention period has no event associated with it, the Records must be retained for that period of time plus the remainder of the year in which they are created. Using another example, if a Record is created some time during the middle of the year and it has a retention period of 8 years, it must be kept for the remainder of the year in which it is created plus an additional 8 years.

Indefinite: If a Record has an “Indefinite” retention period, it indicates that the exact retention period is not able to be determined at this time. Records with an Indefinite retention period will be reviewed periodically to determine if there is any legal or business need to retain them.

Retention Calculation Examples 

Definitions

Destruction: The process of eliminating or deleting a record once it has met its Retention Period and any Tax Audit Holds or Legal Holds have been released.

Non-Record: External documents and publications such as articles, newsletters or press releases that do not require retention. Non-Record materials should be disposed of as soon as they are no longer needed for reference, which is usually no longer than two years.

Official Records: Complete and final Records that require retention for legal, recordkeeping, or business reasons. Official Records provide evidence of the Company’s business functions, policies, decisions, procedures, operations, provision of service and internal and external transactions.

Official Records Owner: The Department, Line of Business or Function responsible for maintaining the Official Record to comply with retention requirements as identified in this Schedule. The Official Records owner is typically, but not always, the Department, Line of Business or Function that created the record.

Tax Audit Hold: The procedure used to temporarily suspend destruction of certain Records due to an existing tax audit, even if the Records are eligible for destruction.

Unofficial Records: Records that are not required to be retained for legal, recordkeeping, or business needs unless they are subject to a Tax Audit Hold or a Legal Hold. These may include drafts, duplicates, or “convenience” copies of Official Records. These may be destroyed when they no longer serve a purpose. 

Contractual Retention Requirements

Where a contract contains a retention requirement that is longer than the applicable retention period set out in this Schedule, the contract retention requirement supersedes the Company Retention Period. Where a contains a retention requirement that is shorter than the applicable Retention Period, a subject matter expert for the Business Function should be consulted for guidance.

Off-Site Storage

Iron Mountain is the approved off-site storage vendor for TELUS Health in North America. Duplicates, drafts, and convenience copies of Official Records are not eligible for storage at Iron Mountain.

Systems Storage

Systems and applications must also have Records stored in a manner that allows for retention and destruction consistent with this Schedule.

Schedules by Business Function 

TELUS Health One

Records related to or generated through the provision of these services by the Company including, but not limited to, TELUS Health One, rewards, recognition and perks, records of health, wellness, nutrition, fitness coaching, or other related services.