Purpose
This is the Data Retention Policy of 1st Burnham-on-Sea Scout Group, the Group is the registered charity (305617).
Scope
This policy covers all data in the possession or control of the Group regardless of the medium in or on which those data are held. Where statute or regulation departs from the requirements of this policy, the Group will comply with the relevant statute or regulation. This policy may be updated from time to time.
Policy
Personal data
Personal data retention is governed by current Data Protection legislation. The data must be kept accurate, up to date and retained for no longer than is necessary for the purpose for which they were obtained. Detail of retention periods can be found in Annex A – Retention periods.
Lawful purpose for processing
Where personal data is processed using the lawful basis of legitimate interest or consent, the data subject has a number of rights that they can exercise over this data, such as delete or rectify. In these situations we will clearly sign post how to either withdraw consent or challenge the legitimate interest, that has been assessed, commonly known as ‘opt out’. Where appropriate the data subject should be informed every 2 years of the consent or legitimate interest being used to process their data with an option to update this preference. A formal retention period for data processing based on consent has not been defined in this policy and is assumed as permanent until the data subject exercises their rights to cease the processing activity.
Examples of processing covered by this statement are subscribers to newsletters, photograph consents and marketing communications.
| Data Process | Data Type | Retention | Justification |
|---|---|---|---|
| Want to Join | Personal data | 1 year after enquiry or until member joins, whichever is shorter. After a Year all will be contacted to ask if they want to remain on the list. | To keep them informed of their joining status |
| Joining – including the role and dates of joining | Personal and Sensitive data (special category) | After leaving the data will be reduced to only include name, date of birth, awards, training records, events attended, roles and permits held and any complaints in summary format. This remaining data will be retained for 100 years. | The 100 years retention of data is required for evidence requests from statutory agencies |
| Youth award registrations | Personal and Sensitive data (special category including citation) | 6 months after the member turns 25 | To retain their award registrations for the duration of the eligibility period |
| Youth award completions | Personal data and Sensitive data (special category including citation) | Permanent for basic data; name, county, award, membership number, completion date | Historic record of award completions |
| Research surveys | Personal and Sensitive data (special category) | 18 months | To keep a collation of completing members and compare answers from the previous year |
| Scouts Experience Survey | Personal and Sensitive data (special category) | 15 Years | To keep a collation of completing members and compare answers from the previous years |
| Incident – personal injury (including sexual abuse/psychological damage) | Personal and Sensitive data (special category) | 4 years after incident, or 4 years after alleged victim turns 18 if later | Fight a case – Limitation act 1980 |
| Incident – not involving personal injury | Personal and Sensitive data (special category) | 7 years after incident, or 7 years after alleged victim turns 18 if later | Fight a case – Limitation act 1980 |
| Data Process | Data Type | Retention | Justification |
|---|---|---|---|
| Individual Givers | Personal Data | 5 years post last donation | To keep an individual informed of their donation and other fundraising campaigns |
| Gift aid declaration | 6 years after the end of the year or accounting period that includes the last donation | HMRC Tax Audit | |
| Direct debit mandate | 6 years after the end of the year or accounting period that includes the last Direct Debit | As proof of Direct Debit Instruction (DDI) and to assist in claims against that DDI | |
| Partnerships | Personal Data | 3 Years | To answer queries on the donations and maintain a record of partner donors |
| Data Process | Data Type | Retention | Justification |
|---|---|---|---|
| Ad-hoc events | Personal and Sensitive data (special category) | 2 months after event. Scouting Young People attendance records will be retained for 100 years | Required for enquiries on the event and responding to incidents. The 100 years retention of data is required for evidence requests from statutory agencies |
| Annual events | Personal and Sensitive data (special category) | 18 months after event for personal data, 2 months after event for sensitive data (special category). Scouting Young People/Adult Leaders attendance records will be retained for 100 years | To re-invite the guests to the same event in the following year. The 100 years retention of data is required for evidence requests from statutory agencies |
| International events | Personal and Sensitive data (special category) | 5 years after event for personal data, 2 months after event for sensitive data (special category). Scouting Young People attendance records will be retained for 100 years | To re-invite the guests to the same event at the next cycle, which are every 4 years. The 100 years retention of data is required for evidence requests from statutory agencies |
| Data Process | Data Type | Retention | Justification |
|---|---|---|---|
| Hall Hire attendee | Personal data | 18 months after last booking | Required for enquiries on purchases |
| Transaction data | 6 Years after the end of the tax year for that purchase | HMRC Tax Audit | |
| Prospect customers – enquiries | Personal data | 18 months after enquiry | To keep in communication with the enquirer |
