Overview
Introduction
This policy sets out how Melksham Choral Society will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary. It forms part of Melksham Choral Society’s Data Protection Policy.
Roles and responsibilities
Melksham Choral Society is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Melksham Choral Society is Rosie Jay. They, together with the committee are responsible for the secure and fair retention and use of data by Melksham Choral Society. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.
Regular Data Review
A regular review of all data will take place to establish if Melksham Choral Society still has good reason to keep and use the data held at the time of the review.
As a general rule a data review will be held every 2 years and no more than 27 calendar months after the last review. The first review will take place on 28 May 2018.
Data to be reviewed
- Melksham Choral Society stores data on digital documents (e.g. spreadsheets) stored on personal devices held by committee members
- data stored on third party online services [(e.g. Google Drive, Mail Chimp)]
- physical data stored at the homes of committee members.
Who the review will be conducted by
The review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.
How data will be deleted
- physical data will be destroyed safely and securely, including shredding
- all reasonable and practical efforts will be made to remove data stored digitally
– priority will be given to any instances where data is stored in active lists (e.g. where it could be used) and to sensitive data
– where deleting the data would mean deleting other data that we have a valid lawful reason to keep (e.g. on old emails) then the data may be retained safely and securely but not used.
Criteria
The following criteria will be used to make a decision about what data to keep and what to delete.
| Question | Action | |
| Yes | No | |
| Is the data stored securely? | No action necessary | Update storage protocol in line with Data Protection policy |
| Does the original reason for having the data still apply? | Continue to use | Delete or remove data |
| Is the data being used for its original intention? | Continue to use | Either delete/remove or record lawful basis for use and get consent if necessary |
| Is there a statutory requirement to keep the data? | Keep the data at least until the statutory minimum no longer applies | Delete or remove the data unless we have reason to keep the data under other criteria. |
| Is the data accurate? | Continue to use | Ask the subject to confirm/update details |
| Where appropriate do we have consent to use the data. This consent could be implied by previous use and engagement by the individual | Continue to use | Get consent |
| Can the data be anonymised | Anonymise data | Continue to use |
Statutory Requirements
Data stored by Melksham Choral Society may be retained based in statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
- Gift Aid declarations records
- Details of payments made and received (e.g. in bank statements and accounting records)
- Trustee meeting minutes
- Contracts and agreements with suppliers/customers
- Insurance details
- Tax and employment records
Other Data Retention Procedures
Member data
- when a member leaves Melksham Choral Society and all administrative tasks relating to their membership have been completed, any potentially sensitive data held on them will be deleted – this might include bank details or medical data
- unless consent has been given data will be removed from all email mailing lists
- all other data will be stored safely and securely and reviewed as part of the next two year review.
Mailing list data
- if an individual opts out of a mailing list their data will be removed as soon as is practically possible
- all other data will be stored safely and securely and reviewed as part of the next two year review
Volunteer and freelancer data
- when a volunteer or freelancer stops working with Melksham Choral Society and all administrative tasks relating to their work have been completed any potentially sensitive data held on them will be deleted – this might include bank details or medical data
- unless consent has been given data will be removed from all email mailing lists
- all other data will be stored safely and securely and reviewed as part of the next two year review
Other data
- all other data will be included in a regular two year review.
