Records Retention Schedule and Secure Destruction Policy
Last updated: November 4, 2026
Purpose
We keep records so that we can serve our clients, answer questions about our work, and meet the Law Society's rules and other laws. We don't keep personal information longer than we need it. This policy sets out how long NEO keeps each kind of record, and how records are destroyed when that time is up. It is the retention schedule our File Closing and Retention Policy refers to.
Who it applies to
Everyone at NEO who creates, keeps or destroys records.
How long we keep records
The periods below are minimums unless they say otherwise. Where a record fits more than one row, the longest period applies.
| Record | How long we keep it | Where the period comes from |
|---|---|---|
| A client's file: documents we prepared or received, letters and messages, notes, agreements, evidence, and recordings saved to the file | At least seven years after the matter ends, and longer where we think the file may be needed to answer a claim | Our retainer agreements and our Privacy Policy |
| Original documents a client gave us | Returned to the client, not destroyed | Our retainer agreements and the Paralegal Rules of Conduct |
| Identification records, including copies of identity documents | At least the longer of our relationship with the client and six years after the work is completed. Copies filed on a client's file are kept with the file. | Law Society By-Law 7.1 |
| What people send us when they contact us but don't become clients | Only as long as we need it to respond, to keep a record of what we were told and said, and to check for conflicts of interest. A name, the names of the other people involved and a short note may be kept longer, for conflict checks. | Our Privacy Policy |
| A client portal account | Stays open after the client's file is closed, until the client or we close it. Closing it doesn't delete the file. | Our Client Portal Terms of Use |
| Trust records: receipts and disbursements journals, the clients' trust ledger, monthly trust comparisons, the record of trust property and electronic trust transfer records, and the bank statements, cheque images and deposit slips for all our accounts | At least 10 years | Law Society By-Law 9 |
| Other financial records: transfers between client ledgers, general receipts and disbursements journals, invoices, the cash receipts book and referral fee records | At least six years | Law Society By-Law 9 |
| Tax records and the documents that support them | At least six years from the end of the last tax year they relate to, and longer where the Canada Revenue Agency's rules require | Canada Revenue Agency |
| The corporation's accounting records | At least six years from the end of the last fiscal period they relate to, and longer where tax rules require | Ontario's Business Corporations Act |
| The corporation's articles and by-laws, the records of its shareholders' and directors' meetings and resolutions, and its registers | Kept up to date for as long as the corporation exists | Ontario's Business Corporations Act |
| Employee and payroll records | The periods in our Employee Privacy and Personnel Records Policy: for example, three years after employment ends for an employee's name, address and start date, and five years after they are made for vacation records | Ontario's Employment Standards Act, 2000, and the rules of the Canada Revenue Agency and Service Canada |
| Job postings we advertise publicly, with their application forms | Three years after the posting is taken down | Ontario's Employment Standards Act, 2000 |
| Applications to work with us as a contractor paralegal, and student enquiries | Up to 12 months after we decide on them (for the student talent list, up to 12 months after the form is sent), then deleted, unless the person goes on to work with us | What our application forms promise |
| Records of an investigation into workplace violence or harassment | At least one year after the investigation ends | Our Workplace Violence and Workplace Harassment Policy and Program |
| Recordings of calls and meetings that aren't saved to a client's file | Only as long as they are needed for the purposes in our Recording of Calls and Meetings Policy | That policy |
| Our own count of visitors to our website | Deleted after about 30 days | Our Privacy Policy |
| Error reports when a page of our website or portal fails | Deleted 90 days after the problem is fixed | Our own practice |
| Any other personal information | Only as long as we need it for the purpose we collected it for, or as the law requires | Canada's privacy law |
By-Law 9's periods are counted back from the end of our most recent fiscal year, so at any time we hold at least the full period before that date. Our Books and Records Policy lists these financial records in full.
Why some records are kept longer
- Claims can come late. The usual two-year time limit for a claim starts only when the claim is discovered. The 15-year outer limit doesn't run while, for example, the person with the claim is a minor, or is incapable, and has no litigation guardian. That is why seven years is only the minimum for a client's file.
- Open matters. We keep a record for as long as it is needed for an open complaint, claim, audit, investigation or legal hold, or where tax rules require.
- Money in trust. A client's file can't be closed while money is still held in trust for it. Money we can't return is dealt with under our Unclaimed Trust Money Policy, and its records are kept.
- The Law Society. We never destroy a record that the Law Society has asked for.
Closing a file
When we close a client's file at the end of a matter, we record the date until which it must be kept: at least seven years later. Only an administrator can record that a closed file has been destroyed, and not before that date. Our File Closing and Retention Policy explains the rest of the closing process.
How records are destroyed
- Paper is shredded securely, never put in ordinary garbage or recycling.
- Originals go back first. A client's original documents are returned to them, not shredded.
- Electronic records are deleted from the systems that hold them.
- Backups. We keep backup copies of our database and stored files, so that our records can be restored if something goes wrong. Older database copies are replaced on a rolling basis. Information we delete may remain in a backup copy, where it is protected in the same way and used only to restore our records.
- Devices are securely wiped before they are recycled, as our ESG Policy explains.
- A record of what was destroyed. We keep a record of each client file destroyed, and when.
- Confidential to the end. Records stay confidential until they are destroyed, under our Confidentiality Policy.
Your choices
- Ask before a file is destroyed. We don't contact you again before your file is destroyed. If you want your file, or a copy of it, ask us before then.
- Deleting personal information. You may ask us at any time to delete personal information we aren't required to keep, as our Privacy Policy explains.
- Questions about how long we keep something can go to our Privacy Officer at info@neolegalservices.com.
The Law Society of Ontario's By-Law 9 (financial records) and By-Law 7.1 (identification records), and its Paralegal Rules of Conduct on client property; Ontario's Employment Standards Act, 2000, Business Corporations Act and Limitations Act, 2002; the Canada Revenue Agency's rules on how long to keep records; and the Personal Information Protection and Electronic Documents Act.
Review
This policy is reviewed at least once a year, and whenever the Law Society's By-Laws or rules change. The principal approves every change. We also review it whenever a law or rule that sets a retention period changes.
Questions
Email info@neolegalservices.com, call 647-200-3526 or toll-free 888-519-2435, or write to us at Unit 236, 1099 Kingston Road, Pickering, Ontario L1V 1B5.
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