Preservation of Records
1. PURPOSE
This policy is established and approved by the Board of the Company in accordance with the guidelines set forth in the Master Circular - 'Know Your Customer' (KYC) Guidelines – Anti Money Laundering Standards (AML) - 'Prevention of Money Laundering Act, 2002 - Obligations of Non-Banking Financial Companies (NBFCs) in terms of Rules notified thereunder,' dated 1st July 2015. The purpose of this policy is to ensure that PayMe India Financial Services Private Limited (hereinafter referred to as "the Company") takes appropriate measures to evolve a system for the proper maintenance and preservation of records and documents, as required by law, in a manner that allows data to be retrieved easily and quickly whenever required or when requested by competent authorities.
2. DEFINITIONS
Board of Directors or Board: The Board of Directors of PayMe India Financial Services Private Limited, as constituted from time to time.
Company: PayMe India Financial Services Private Limited.
Documents: All papers, records, files, books, electronic storage devices (physical/digital data), and similar items required to be maintained under any law or regulation for the time being in force.
3. OBJECTIVE
This policy establishes standards for managing, storing, and preserving documents of the Company as well as data of its customers.
Standards for managing, storing, and preserving documents of the Company are broadly classified into the following two categories:
A. Documents of a Permanent Nature (as per Annexure 1):
The Company shall maintain and preserve documents of a permanent nature, subject to modifications, amendments, additions, deletions, or any changes made therein from time to time.
All modifications, amendments, additions, deletions in these documents shall also be preserved permanently by the Company.
B. Documents to be Maintained for a Specified Time Period After Transaction Completion (as per Annexure 2):
The Company shall preserve documents for a term not less than five years after the completion of the relevant transactions, subject to modifications, amendments, additions, deletions, or any changes made therein from time to time.
Standards for managing, storing, and preserving data of the Company’s customers are broadly classified into the following two categories:
A. Preservation of data of on-boarding Customers/new to customers:
The Company recognizes the importance of protecting the data and privacy of existing customers or newly on-boarded customers who have availed or about to avail the services or product of our Company. This policy is designed to ensure the responsible and secure preservation and storage of their data. Company can store the personal as well as financial data of the customers along with transaction history and communication records .
B. Preservation of data of customers not associated with company:
The Company may store the financial data of the customers, who are not associated anymore with the company, for maximum upto 6 months only. However, company can store the basic details of the customer like name, phone number, e-mail id and address for future perspective.
# Documents of Undisbursed or Rejected Cases:
The Company will preserve documents for a period of 6 Months or as decided by the management on a case-to-case basis.
All modifications, amendments, additions, or deletions in these documents shall also be preserved for a term not less than five years.
3. ROLES & RESPONSIBILITIES
The respective Departmental Heads of the Company shall be responsible for the maintenance, preservation, and destruction of documents in their areas of operations, in accordance with the provisions of the Regulatory including but not limited to Prevention of Money Laundering Act 2002, Companies Act 2013, , Income Tax Act 1961 and Amendments thereto as specified by concerned authorities on time to time basis.
DESTRUCTION OF DOCUMENTS
After the expiry of the statutory retention period, the preserved documents may be destroyed in accordance with instructions approved by the department head(s). Records that are duplicate, unimportant, or irrelevant may also be destroyed as part of normal administrative practice. This applies to both physical and electronic documents/records. Destruction of documents can be undertaken periodically with the approval of the Head of the Department concerned, and a record of the documents destroyed must be maintained. In case any Legal obligation arises to disclose any record as specified by the competent authority, the company may, for that perspective, retain the information even after such destruction for a further period of 5 years* .
AMENDMENTS
The Board or the Management Committee may, subject to applicable laws, amend or substitute any provision(s) or replace this policy with a new policy. Any such amendment or modification shall not be inconsistent with the applicable provisions of any law for the time being in force.
*Annexure 1*
Documents whose preservation shall be permanent in nature.
| S. No. | Nature of Document(s) |
| 01 | Registration Certificates |
| 02 | Licenses & Statutory Approvals |
| 03 | Statutory Registers required under applicable laws |
| 04 | Audited financial statements/ Annual Reports |
| 05 | Minutes of General Meeting |
| 06 | Minutes of Board Meeting |
| 07 | Minutes of various Committee Meetings |
| 08 | Material Agreements/Contracts |
| 09 | Orders issued by Courts/Statutory bodies |
| 10 | Investment Documents/proofs including certificates etc. |
| 11 | Share Certificates/Debentures Certificates/ CPs |
| 12 | Tax records |
| 13 | Any other document as may be required to maintain permanently in terms of applicable law(s), maintained and preserved from time to time. |
*Annexure 2*
Documents with preservation period of not less than five years* after completion of the relevant transactions
| S.No. | Nature of Document(s) |
| 01 | Books of Accounts/ Records of transaction & ledger book |
| 02 | Annual Return(s) |
| 03 | Customer’s KYC documents |
| 04 | PDC of the customers# |
| 05 | Call recordings of calls made to the customers (Customer Service Team & collections) |
| 06 | Insurance Policies/ Claims under various policies |
| 07 | Correspondences with the Regulators |
| 08 | Non-Statutory Registers/Documents |
| 09 | Any other document as may be required to maintain in terms of applicable law(s), maintained and preserved from time to time. |
# PDC of the customers will be returned or shredded in case of loan cancellation or closure or maturity as per customer request.