Uplift Data Retention and Destruction Policy (Updated September 2020)
1) Purpose
The purpose of this Policy is to ensure that necessary records, data, and documents of Uplift are adequately protected and maintained and to ensure that records that are no longer needed by Uplift or are of no value are discarded at the proper time.
This Policy is also for the purpose of aiding employees of Uplift in understanding their obligations in retaining electronic documents – including emails, Google Drive files, hard and soft copy documents, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.
2) Principle
Uplift keeps personal data only for as long as is necessary for a specific organisational purpose and ensures it is securely disposed of. Any personal data is only to be kept where there is an organisational or legal need to do so and where the relevant purpose is communicated to the individual either by Uplift’s data protection policy or personally. All personal data is disposed of in a secure manner.
3) Practice and administration
Uplift retains data on members for 5 years after a user’s last interaction with Uplift campaigns. An interaction is inclusive of but not limited to signing a petition, sending an email through Uplift technology, attending an Uplift event, and opening an Uplift email.
The Data Protection Manager is responsible for ensuring that the is processes and procedures are in place and implemented to ensure that the Policy is followed.
Attached as Appendix A is a Data Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of Uplift and the retention and disposal of electronic documents.
The Administrator is also authorised to: make modifications to the Record Retention Schedule from time to time to ensure that it is in compliance with local, national and international laws and includes the appropriate document and record categories for Uplift; monitor all laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.
4) Suspension of Record Disposal In Event of Litigation or Claims
In the event Uplift is served with any legal writ or request for documents or any employee becomes aware of a governmental investigation or audit concerning Uplift or the commencement of any litigation against or concerning Uplift, such employee shall inform the Data Protection Manager and any further disposal of documents shall be suspended until such time as the DPM with the advice of counsel, determines otherwise. The DPM shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.
5) Contact
We are not required by law to have a “Data Protection Officer” – however we have a Data Protection Manager. Please let us know if you have any queries or concerns whatsoever about the way in which your data is being processed by either emailing the Data Protection Manager at [email protected] and/or our wider team at [email protected]
6) Applicability
This Policy applies to all physical and digital records generated in the course of Uplift’s operation, including both original documents and reproductions.
This Policy was approved by the Board of Directors of Uplift on 22 September 2020.
Appendix A – Data Retention Schedule
| RECORD | RETENTION PERIOD | ASSET OFFICER | ACTION |
|---|---|---|---|
| Information, data or record | Period for retaining record & accompanying notes | Who is responsible for reviewing periods | Destroy, archive, review etc | Members: Name, Email, location, event responses, address, phone number, Action history | 5 years | Director | Destroy |
| Members: Survey responses | 5 years | Director | Destroy |
| Members: All communication | 5 years | Director | Destroy |
| Job applicants: Email, name, county, country, address, phone number, employment history | 6 months after post closes | Operations Manager | Destroy |
| Volunteers: Email, name, county, country, address, phone number, PPSN, bank account, employment history | 1 year after role ends | Operations Manager | Destroy |
| Employees: PPSN, bank account, employment history | 1 year after end of employment | Operations Manager | Destroy |
| Employees: Email, name, county, country, address, phone number | 5 years | Director | Destroy |