Insurance and Financial Planning

In insurance and financial planning, information on client files and the documents used to create them must be kept by the firm, independent partnership, or independent representative for a minimum period of five years following whichever of these events occurs later:

• the definitive closure of the client’s file
• the date the last service was provided to the client
• the expiration without renewal, or replacement of the last product sold to the client

Once the five (5) years have passed, the files may be kept for longer for risk management purposes and to allow an advisor to defend themselves in the case of a disciplinary complaint, a civil claim or other. In that case, an additional protection measure must be implemented to ensure files containing confidential information are protected at a high level. Obviously, these files should not be kept indefinitely to limit the risks in the case of a privacy breach.

Here are good practices governing how inactive records should be kept:

• Store inactive physical files in a secure location with restricted access until they can be safely and completely destroyed.
• Use a digital format to keep inactive electronic files with adequate safeguards that restrict access.
• Keep inactive electronic files separate from active files.