Data retention policy

Introduction

Re-engage collects a large amount of data while carrying out our various charitable activities. The information is collected from a range of sources including, but not limited to, staff, volunteers, older people, funders and donors, referrers, and organisations, most of this data is personal data about individuals.

The bulk of this data is stored as electronic records. Appropriate retention of data is necessary for our operational performance and in some cases is required to fulfil statutory or other regulatory and donor requirements or to evidence events and agreements in disputes.

The retention of data can lead to unnecessary and excessive use of electronic storage space which can create significant cost. Importantly, the indefinite retention of personal data can breach the UK GDPR. Failure to comply with the GDPR can lead to financial penalties from the Information Commissioner’s Office. It is therefore essential that Re-engage has appropriate systems and processes in place for the preservation and timely disposal of records in line with business requirements and relevant legislation.

1. Scope

This Data Retention Policy applies to:

• all staff, volunteers, consultants, contractors, trustees and, as appropriate, partnership organisations, partner staff and third parties of Re-engage.
• all records that are created, handled, stored, or processed by Re-engage, electronically (soft copy) or in paper (hard copy) form. All those people or groups to whom this policy applies should, as appropriate, be aware of this policy.

1.1 Procedures associated with this document

• Back-up and disaster recovery procedure
• Data protection policy
• Data security policy
• Register of systems

2. Easy read data retention principles

1. All emails, documents, and other data relating to people using our services – older people, volunteers, should be stored in the relevant system as directed by type.
2. Any initial collection forms, or processing steps in between collecting the data and storage in OPUS, should be securely deleted at the first opportunity, unless otherwise agreed.
3. All documents and materials produced for Re-engage must be stored on SharePoint.

1. Subject access and erasure requests

Anyone we hold personal data about has the right to ask us to disclose what information we hold about them and be forgotten by us (have their data erased). This includes service beneficiaries, donors, staff and volunteers. If you receive a formal request for information about a data subject, or a request to be forgotten, you must do the following:

• If the request is by phone, you should ask the caller to put their request in writing (this allows us to have a formal record of the request)
• Establish who should answer the request – depending on the type of data and the simplicity of the request, it may be appropriate to deal with the request yourself. Otherwise, you may need to pass the request to a manager or member of the senior management team
• If you are in any doubt as to whether the person requesting the data is the data subject themselves, please contact our internal Data Protection Officer(s) for further guidance.
• We must respond to a Subject Access Request or Subject Erasure Request within a strict time frame (this is currently 40 calendar days), and failure to do so will place Re-engage in breach of data protection law.
• Processing subject erasure (anonymisation) requests: In some circumstances and in order to retain analytical data relating to operational performance, it is not necessary to delete records rather than anonymise them. A record is effectively anonymised when it:
  • does not relate to an identified or identifiable individual; or
  • is rendered anonymous in such a way that individuals are not (or are no longer) identifiable

The extent to which we can anonymise data depends on the purpose for which it is retained. For individuals recorded in OPUS, it is acceptable to scrub personal and sensitive data (including attached emails and documents) from their record. Other areas – such as finance or HR records depend on legal requirements. Any data erasure/anonymisation request must be carried out in consideration of the data retention schedules (below), clarify legal requirements to keep data and may override the request.

Re-engage’s data protection officer is the director of finance and resources.

2. Data storage systems / locations

2.1 Formstack

Collects, processes, and stores personal and sensitive data for processing in other systems. Data is stored in Formstack and transposed via Power Automate into OPUS and retained against the individual’s record. The Formstack database is retained to ensure accurate data ingestion. Formstack data may be archived to Excel spreadsheets in order to release storage capacity in the Formstack database. Where this occurs, the spreadsheets will be securely stored, and password protected, on Re-engage SharePoint.

2.2 OPUS

CRM and Fundraising system storing personal and sensitive data relating to volunteers, older people, funders and donors, and referrers. The system also stores data on organisations and corporate bodies. OPUS is built on Microsoft Dynamics 365, using Power Automate and Power Apps. Access is granted with approval from OPUS administrators.

2.3 Together.ly

A ‘tele-health’ platform, that facilitates delivery of our call companion program, with an API connection to OPUS. Together.ly holds telephone numbers and names of matched volunteers and contacts. When a match is broken the numbers are removed from Together.ly but the history of calls is retained. The system stores the date and duration of calls and has a facility to record calls. It is Re-engage policy not to record calls without the informed consent of the volunteer and older person. The system is password protected and numbers can only be viewed by administrators.

2.4 Office 365 (including SharePoint, Teams, Outlook, OneDrive)

2.4.1 Personal and sensitive data relating to individuals in OPUS

• Emails from and relating to individuals must be appended to their record in OPUS.
• Documents from and relating to individuals should be scanned (if not received electronically) and appended to their record in OPUS.

If retention of original physical document is thought essential, the document should be:

1. Scanned and appended to the individual’s record in OPUS
2. Stored securely under lock and key, in line with document management rules

2.4.2 Operational data relating to business activities

• All documents essential to Re-engage must be stored on SharePoint.

2.5 QuickBooks

Financial reporting system storing names and addresses of donors, supporters, suppliers, volunteers, trustees, and staff members for the purpose of financial accounting.

2.6 BreatheHR

HR management system storing employee information, names and addresses, details of employment terms such as hours of work. Used to manage people-related functions and processes. It's a self-service system that allows employees to report absences, request holidays, update personal information and more. Managers and HR users control permission-setting tools to grant or restrict employee access to sensitive information. This is key to data and employee information security.

2.7 Volunteero

MEL system storing older people and volunteer contact details.  Used to facilitate gathering of evaluation data by means of allowing self-service of missions.

3. Data review schedule

Where possible, automated retention processes should be established in line with data retention schedules (below). Reviews of data will be carried out annually, for example OPUS will be reviewed to identify and delete any records that no longer meet storage requirements. This process will be carried out for all the systems listed above.

4. Data retention schedules

4.1 Personal and sensitive data (Formstack, OPUS, Office 365)

4.2 Finance data (QuickBooks)

4.3 HR data

4.4 Legal and Info Gov data

4.5 Trustee and incorporation data

4.6 Marketing and communications