Data Retention Policy

Overview

 

Introduction

This policy sets out how Music in Fermanagh will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.

It forms part of Music in Fermanagh Data Protection Policy. 


Roles and responsibilities

Music in Fermanagh is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Music in Fermanagh is Fiona Plunket. They, together with the committee are responsible for the secure and fair retention and use of data by Music in Fermanagh. 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 Music in Fermanagh 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 took place on 15 August 2022.

Data to be reviewed

  • Music in Fermanagh 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. Shopify Email)

  • 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 Music in Fermanagh 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 retention procedures

Member data

  • When a member leaves Music in Fermanagh 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 Music in Fermanagh 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