After an unsuccessful tender, review the personal data in the bid file against the purposes that still require it. Keep records needed for a genuine continuing business or legal purpose, protect those records and dispose of unnecessary personal data appropriately. Losing a bid does not automatically mean the whole file must be deleted immediately, but it is a sensible trigger for a documented retention review.
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Section 25 of the Personal Data Protection Act addresses retention when legal or business purposes no longer require the personal data. Apply the review to the actual records rather than adopting an indefinite “keep all tenders” rule.
Separate the bid history from personal supporting documents
The commercial proposal, pricing assumptions and submission correspondence may have a different retention purpose from copies of staff CVs, identity documents or named subcontractor contacts. Identify which parts of the file are needed to understand the tender outcome, support a genuine dispute or meet another applicable obligation.
A single folder can hide those differences. Keep a record inventory showing the document category, responsible owner, continuing purpose and intended review. Do not treat possession of a complete bid pack as evidence that every document remains necessary.
Ask whether any issue is still live
Check for an appeal, clarification, contractual obligation, invoice, audit question or dispute relevant to the tender. Where records may need to be preserved for legal proceedings, obtain advice before disposal. Retention should be justified by the circumstances, not by an unsupported fear that everything might be useful someday.
Also identify confidentiality and contractual commitments concerning material supplied by another party. A company’s internal retention decision should not overlook an agreed return or deletion arrangement.
Example: the proposal remains useful, the staff documents do not
A company wants to retain its technical approach and cost model for evaluating why a tender failed. The original bid also contains staff CVs and personal contact details supplied for that particular procurement. The company can assess whether those personal attachments remain necessary instead of copying the complete pack into a general sales library.
Control retained copies
- Restrict the retained file to people with a relevant task.
- Remove unnecessary working copies and exports through an approved process.
- Check whether subcontractors or bid consultants hold copies.
- Record the review date and the person responsible.
- Keep legal preservation instructions separate from ordinary disposal decisions.
Do not promise that every copy has disappeared if backups or another authorised retention arrangement remain. Establish what the relevant systems and providers can actually do.
Record disposal accurately
Use a suitable process for paper and electronic records. Keep a factual disposal record identifying the category and action without unnecessarily recreating the personal data being removed. If the company retains a limited record of the tender, explain what remains and why.
A review should end with an actual decision and follow-through. A policy saying that files “will be reviewed” is not evidence that a particular tender’s attachments have been assessed.
Is there one PDPA retention period for every failed tender?
Assess the relevant legal and business purposes and any other applicable requirements. Do not substitute a generic period for a record-specific review.
Can the sales team reuse staff CVs in another proposal?
That is a separate use requiring its own assessment, including accuracy, purpose and any necessary permission. Retaining a document does not automatically authorise reuse.
Related guidance
- Mapping the personal data your company holds
- Organising a data protection management programme
- Background on company data protection obligations
Help with company compliance and privacy matters
If you would like assistance organising your company’s compliance procedures or obtaining advice on a privacy issue, email [email protected] or WhatsApp +65 8501 7133. Our team can assist with corporate secretarial, accounting and tax matters. Where legal advice is needed, advisers from our associated law firms can assist. This is general information; legal advice should address the facts of the particular request or dispute.