Pipecue

How long should a plumbing company keep customer records?

There is no number in the Act. The obligation is to keep information only as long as it is needed, decide what that means for your shop, and write the decision down.

People expect a figure here — seven years, or two, or whatever their accountant said. PIPEDA does not give one. The principle limiting use, disclosure and retention says personal information that is no longer required to fulfil the identified purposes should be destroyed, erased or made anonymous, and it deliberately stops short of a period, because the right period depends on what you collected the information for.

The regulator does expect organisations to develop guidelines and implement procedures for retention, including minimum and maximum retention periods, and to review regularly whether information is still needed. So while there is no number handed to you, there is an expectation that you have arrived at one.

The distinction that does the work

Separate the records you have an independent reason to keep from the ones you are only keeping out of habit. An invoice for completed work has a tax and warranty life measured in years, and other laws speak to it. A quote request for a job you never won has no such life. Once you have lost the job — or once enough time has passed that you plainly have — the purpose is finished.

The most common retention problem in a trade business is not old invoices. It is quote requests for jobs that were never won, sitting in an inbox indefinitely because deleting them was never anyone's task.

A defensible schedule for a small shop

This is illustrative rather than prescriptive — the point is that a written schedule exists and that each line has a reason, not that these particular numbers are correct for you:

  • Quote requests that did not convert — the shortest period on your list. The purpose ended when the job did not happen.
  • Completed job records and invoices — as long as tax, warranty and limitation periods require. This is where your accountant's answer belongs.
  • Anything sensitive you collected incidentally — photos of the inside of someone's home, gate codes, alarm details — the shortest life of anything you hold.
  • Marketing lists — until consent is withdrawn, and reviewed on a schedule rather than never.

Deleting means deleting

The obligation is to destroy, erase or anonymise so the information cannot be reconstructed or recovered. Moving an email to a folder called Archive is not destruction. Neither is deleting the row in one system while a copy sits in an export on a laptop.

For most small shops the honest first step is not writing a policy. It is finding out how many copies of the same customer list exist — the software, the inbox, the spreadsheet someone made, the phone — because you cannot delete on a schedule what you have not located.

This is a plain-language summary of published guidance, not legal advice. Every claim above is sourced below. For a decision that carries real consequence for your business, talk to a lawyer who practises privacy law in your province.

Sources

Checked against the Office of the Privacy Commissioner of Canada on .

Related