Notaries

Scratch versions and intakes at the notary: destroy without disciplinary risk

14 January 2026 · 6 min read · DeSnipperaar

The most underrated pile in many notarial offices is not the minutes archive, but the cabinet of working material. Scratch versions of deeds, intake forms, photocopied extracts and identity documents: papers that arise at every execution and then keep lying around. Often far longer than is permitted. This article is about the practical destruction of those piles, without coming into conflict with your duty of confidentiality or with the disciplinary judge.

What are "ancillary documents"?

By ancillary documents we mean everything that arises around a deed but is not part of the protocol. Think of:

• Intake forms with name, address, BSN, civil status.
• Copies of identity documents (often with BSN still visible).
• BRP, Chamber of Commerce and Land Registry extracts printed for checking.
• Scratch versions and intermediate versions of deeds and powers of attorney.
• Pre-nuptial agreement drafts that were never executed.
• Bank statements and invoice overviews for estates.
• Email correspondence with clients, printed on paper.

All of these documents fall under your duty of confidentiality (Wna art. 22). They do not belong on the old paper pile.

GDPR storage limitation

The GDPR requires that personal data is not kept longer than necessary (art. 5(1)(e)). For notaries, "necessary" is tied to:

• The Wwft five-year period for client due diligence.
• The limitation period for liability (often 20 years for damage tied to a deed).
• The tax retention period of seven years for financial administration.

For working material with no direct link to one of these periods, for example intake forms from clients who ultimately did not execute, you do not have to wait five or seven years. Once the basis falls away, it may go. See our explanation in Wwft retention: which documents fall under the five years?.

BSN-bearing extracts: special attention

The BSN is a legally protected identification number. BRP extracts, ID copies and BSN-bearing correspondence require at least DIN 66399 P-5 on destruction. Lower levels (P-3 or P-4) are insufficient; reconstruction from the shreds is then theoretically still possible. With regular office shredders (strip-cut models) you are effectively always too low.

An office shredder for BSN documents is like a paper raincoat: it feels right, but it stops nothing that actually matters.

Why a mobile shredder fits

For notaries the file is confidential up to the last moment. Even in a sealed transport container the question remains: can the client, in a disciplinary complaint, demonstrate that the premises were secure? Mobile document destruction removes that question. The shredder truck parks at your door, your staff member carries the box to the hopper, the destruction process is visible through the side window, and within the hour you receive a certificate with date, weight and method.

Practical features that are usual for notarial practice:

• The truck arrives at the agreed time. Outside peak hours or in the evening on request.
• Your own staff member supervises the hand-over; the external operator does not touch the documents before they go into the hopper.
• The certificate is issued on the spot; you can file it directly as proof of GDPR compliance.
• No minimum order, no contract: half a cubic metre is also fine.

Disciplinary risk: how do you prevent it?

Disciplinary complaints about handling of client data do occur. They usually concern not what you destroyed, but what you insufficiently protected: files that ended up outside the building, data that reached third parties, or material that lingered longer than was responsible. Three rules of thumb limit your exposure:

1. Document your cycle. When do you clear files, which periods do you apply, who signs off?
2. Keep destruction certificates. At least seven years, in your office archive.
3. Choose a method without a chain. Mobile destruction eliminates transport risk.

What may go without further ado?

• Scratch versions and intermediate versions of deeds after execution.
• Intake forms from cases that did not go ahead, once a reasonable period has elapsed.
• Old BRP extracts that only served for checking and are not attached to the minute.
• Print-outs of client correspondence that is also recorded digitally.

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For the sector approach see our page Document destruction for notaries. Also read which documents may go from the notarial protocol and how to prepare for a KNB audit. Have a specific situation you are unsure about? We are happy to think along before anything goes into the container that should have been kept.