Data Retention Policy

RETENTION OF RECORDS POLICY

1 Introduction

1.1 This Retention of Records Policy has been approved by the Board of Trustees (the Trustees) of YMCA England & Wales. The Charity is registered with the Office of the Information Commissioner with registration number Z6768138.

1.2 The Retention of Records Policy will enable the Charity to comply with the requirements of data protection legislation. Furthermore, this policy will enable the Charity to manage and track documents and assist in providing openness and transparency to the public.

1.3 The Retention of Records Policy is required to support the organised creation, retrieval, appropriate storage and preservation of the Charity’s operational records. In addition, it is essential to support the appropriate disposal of documents with no continuing business, legal or historical significance.

1.4 As a Charity, the actual period for records to be kept will depend on a number of factors, including but not necessarily limited to:

• legal requirements
• storage costs
• the Charity’s need to access the document
• historical value
• industry standards or best practice.
• archival needs (permanent preservation).
• decision by senior management (in the absence of guidance on the above)

2 Scope of the Policy

2.1 This policy encompasses:

• records created by or on behalf of the Charity and staff in their duties for the Charity
• records received by any member of staff in the Charity
• hard copy and electronic records including but not necessarily limited to Internet and Intranet sites, databases, emails, films and videos

3 Data Protection

3.1 This policy will ensure that the Charity is complying with applicable data protection legislation, which requires that we do not retain personal data for longer than is necessary

3.2 To comply with the principles of data protection legislation, the Charity must:

• only keep information for as long as there is a business need
• keep records secure, whether electronic or paper
• ensure records are retrievable and easily traced
• allow a person access to information held about them, should they request it

3.3 It follows that the Charity must:

• destroy papers and electronic data for which there is no continuing business need and send papers that cannot be destroyed to archive for as short a time as possible
• keep data secure while it remains in any office
• keep track of where information is stored
• continue to apply these good practices to avoid stockpiling papers in the future

4 Policy

4.1 All records created by or on behalf of the Charity belong to the Charity. This includes any rights or copyright in the context, except where specifically provided under copyright legislation.

4.2 All records received on behalf of the Charity as part of its business will be its property, which may be disposed of or released as the Charity sees fit or as required by law. Originators’ and owners’ rights will be fully respected in accordance with legislation.

4.3 Responsibility for depositing and disposing of archive records lies with the Directors of each operation as the information asset owner. It is their responsibility to ensure that complete and accurate records are retained in line with legislative requirements and agreed best practice.

Responsibility for managing and tracking records lies with the relevant Director who:

• Will determine if a file is no longer required for current business usage, which can then be added to the archive.
• May choose to retain records for longer than the indicative periods given in the retention schedule, for example, if they consider records to be of significant historical value or if the issue they are concerned remains ‘live’.

5. Record Keeping

Records will be reviewed against the record retention schedule on an annual basis. Records that have passed their retention period and have no current ad-hoc requirement to retain the information (e.g. current or pending legal action or complaint) will be presented to their information asset owner for confirmation that disposal should be undertaken. A record will be maintained documenting, as a minimum, the record type, name of the record, any further metadata that will enable subsequent identification of the record being disposed (e.g. date range); date of disposal, authorising officer name and role. The decision of the information asset owner will be countersigned by the Company Secretary.

6. Secure Disposal

All deleted records will be disposed of in a secure manner. In the case of paper records, these will be shredded and all information passed through confidential waste, which is then disposed of in a confidential manner. No shredded paper records will be passed through the general paper disposal process. In relation to electronic records these will be irretrievably deleted.

Date of Policy: May 2022

Retention Schedule