2.9.In de Deloitte Policy Manual 3710 (hierna: DPM 3710) – retention of engagement documentation staat onder andere:
Retention Requirements for All Engagements
‘1. Member Firms should establish and document policies and procedures on the retention of documentation in paper and electronic form for all Engagements, consistent with Local Laws and subject to the requirements set forth in this Section. (…)
Archiving of Audit, Assurance and Related Services Engagement Files
6. If it necessary to modify an archived Engagement file or add new working papers to an archived Engagement file, the Engagement Team should, regardless of the nature of the modifications or additions, document the following:
• When and by whom they were made, and, if applicable, reviewed
• The specific reasons for making such modifications
• Their effect, if any, on the Member Firm’s conclusions.
When an archived Engagement file is required to be modified engagement documentation shout not be deleted or discarded, however, information may be added.
7. Changes to an Engagement file archive should be subject to an appropriate governance and oversight process established by the Member Firm Audit & Assurance Quality Leader and should not delete or overwrite the original archive Engagement file documents.
Production of Archives Files
16. In the event that an engagement's files are required to be produced as part of an
internal or external inspection, government or regulatory investigation, or legal
proceeding, including but not limited to an external regulatory inspection, peer review
or Deloitte practice review, a regulatory or criminal investigation, subpoena, or court
case, the file should be extracted from the Member Firm's archives and should be
produced without any alteration, addition or redaction. Where laws or regulations
require that certain information (e.g. personal data) be redacted or withheld from work
papers being provided as part of an internal or external inspection, the recipient should
be notified of this fact and the process of withholding or redacting such information
clearly communicated. Where such redactions are necessary as part of a legal
proceeding, the Member Firm should consult with Legal Counsel on the appropriate way
for this to be disclosed and accomplished. (…)’