Data protection policy

This Privacy Standard sets out how the National Council of Women of Great Britain  (“we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties.

This Privacy Standard applies to all Personal Data we process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

This Privacy Standard applies to all Company Personnel (“you”, “your”). You must read, understand and comply with this Privacy Standard when Processing Personal Data on our behalf and attend training on its requirements. This Privacy Standard sets out what we expect from you for the Company to comply with applicable law. Your compliance with this Privacy Standard is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Privacy Standard. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Privacy Standard may result in disciplinary action.

Where you have a specific responsibility in connection with Processing such as capturing Consent, reporting a Personal Data Breach, conducting a DPIA as referenced in this Privacy Standard or otherwise then you must comply with the Related Policies and Privacy Guidelines. 

This Privacy Standard (together with Related Policies and Privacy Guidelines) is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO.

Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.

All those who provide services to the National Council of Women of Great Britain are responsible for ensuring compliance with this Privacy Standard and need to implement appropriate practices, processes, controls and training to ensure that compliance.

The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines.

Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR or if you have any concerns that this Privacy Standard is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

• if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company);
• if you need to rely on Consent and/or need to capture Explicit Consent;
• if you need to draft Privacy Notices;
• if you are unsure about the retention period for the Personal Data being Processed;
• if you are unsure about what security or other measures you need to implement to protect Personal Data;
• if there has been a Personal Data Breach;
• if you are unsure on what basis to transfer Personal Data outside the EEA;
• if you need any assistance dealing with any rights invoked by a Data Subject;
• whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA or plan to use Personal Data for purposes other than what it was collected for;
• if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making;
• if you need help complying with applicable law when carrying out direct marketing activities; or
• if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors).

Personal data protection principles

We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);
• collected only for specified, explicit and legitimate purposes (Purpose Limitation);
• adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);
• accurate and where necessary kept up to date (Accuracy);
• not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);
• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);
• not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and
• made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

Lawfulness, fairness, transparency

Lawfulness and fairness

• the Data Subject has given his or her Consent;
• the Processing is necessary for the performance of a contract with the Data Subject;
• to meet our legal compliance obligations;
• to protect the Data Subject’s vital interests;
• to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.
• You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.
• The GDPR allows Processing for specific purposes, some of which are set out below:

Consent

A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.

Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Notice to the Data Subject to capture Explicit Consent. 

You will need to evidence Consent captured and keep records of all Consents in accordance with Related Policies and Privacy Guidelines so that the Company can demonstrate compliance with Consent requirements.

Investigation

We will advise you who we have asked to investigate your complaint. If your complaint is straightforward, we will usually ask somebody from the Management Committee to look into it and get back to you. In some cases, if the complaint is serious, we may ask someone from outside the organisation to investigate. We will set out to you our understanding of your complaint and ask you to confirm that we have got it right. We will also ask you to tell us what outcome you are hoping for. The person looking at your complaint will usually need to see the files we hold relevant to your complaint. If you don’t want this to happen, it is important that you tell us. If there is a simple solution to your problem, we may ask you if you are happy to accept this. We will aim to resolve concerns as quickly as possible and expect to deal with the vast majority within 30 working days. If your complaint is more complex, we will:

• Let you know within this time why we think it may take longer to investigate
• Tell you how long we expect it to take
• Give you regular updates every 20 working days on any progress made

The person who is investigating your concerns will aim first to establish the facts. The extent of this investigation will depend on how complex and how serious the issues you have raised are. In complex cases, we will draw up an investigation plan. In some instances, we may ask to meet you to discuss your complaint. Occasionally, we might suggest mediation or another method to try to resolve disputes.  When investigating your complaint, we will look at relevant evidence. This could include files, notes of conversations, letters, emails or whatever may be relevant to your complaint. If necessary, we will talk to those involved and look at our policies and any guidance.

Transparency (notifying Data Subjects)

The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

If you are collecting Personal Data from Data Subjects, directly or indirectly, then you must provide Data Subjects with a Privacy Notice in accordance with our Related Policies and Privacy Guidelines.

Purpose limitation

Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.

You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

Data minimisation

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties.

You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.

Accuracy

Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

Storage limitation

Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time. You must comply with our guidelines on Data Retention.

You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company’s applicable records retention schedules and policies. This includes requiring third parties to delete that data where applicable.

You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

Security integrity and confidentiality

Protecting Personal Data

Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Special Categories of Personal Data and Criminal Convictions Data from loss and unauthorised access, use or disclosure.

You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

• Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it;
• Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and
• Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

Reporting a Personal Data Breach

The GDPR requires Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches (the DPO). You should preserve all evidence relating to the potential Personal Data Breach.

Transfer limitation

The GDPR restricts data transfers to countries outside the EEA to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

You may only transfer Personal Data outside the EEA if one of the following conditions applies:

• the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject’s rights and freedoms;
• appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;
• the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

Data Subject’s rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

• withdraw Consent to Processing at any time;
• receive certain information about the Data Controller’s Processing activities;
• request access to their Personal Data that we hold;
• prevent our use of their Personal Data for direct marketing purposes;
• ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
• restrict Processing in specific circumstances;
• challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
• request a copy of an agreement under which Personal Data is transferred outside of the EEA;
• object to decisions based solely on Automated Processing, including profiling (ADM);
• prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
• be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
• make a complaint to the supervisory authority;
• in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format; and

You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

You must immediately forward any Data Subject request you receive to the DPO.

Accountability

The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

The Company must have adequate resources and controls in place to ensure and to document GDPR compliance including:

• appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;
• implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;
• integrating data protection into internal documents including this Privacy Standard, Related Policies, Privacy Guidelines or Privacy Notices;
• regularly training Company Personnel on the GDPR, this Privacy Standard, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and
• regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

Record keeping

The GDPR requires us to keep full and accurate records of all our data Processing activities.

You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects’ Consents and procedures for obtaining Consents in accordance with our record-keeping guidelines.

These records should include, at a minimum, the name and contact details of the Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a description of the security measures in place. To create the records, data maps should be created which should include the detail set out above together with appropriate data flows.

Training and audit

We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

You must regularly review all the systems and processes under your control to ensure they comply with this Privacy Standard and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

Privacy by Design and Data Protection Impact Assessment (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following:

• the state of the art;
• the cost of implementation;
• the nature, scope, context and purposes of Processing; and
• the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

Data controllers must also conduct DPIAs in respect to high-risk Processing.

You should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:

• use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
• Automated Processing including profiling and ADM;
• large-scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and
• large-scale, systematic monitoring of a publicly accessible area.
• A DPIA must include:
• a description of the Processing, its purposes and the Data Controller’s legitimate interests if appropriate;
• an assessment of the necessity and proportionality of the Processing in relation to its purpose;
• an assessment of the risk to individuals; and

the risk mitigation measures in place and demonstration of compliance

Automated Processing (including profiling) and Automated Decision-Making

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

• a Data Subject has Explicitly Consented;
• the Processing is authorised by law; or
• the Processing is necessary for the performance of or entering into a contract.

If certain types of Special Categories of Personal Data or Criminal Convictions Data are being processed, then grounds (b) or (c) will not be allowed but the Special Categories of Personal Data and Criminal Convictions Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject’s rights and freedoms and legitimate interests.

We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.

A DPIA must be carried out before any Automated Processing or ADM activities are undertaken.

Direct marketing

We are subject to certain rules and privacy laws when marketing to our customers.

For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt-in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

A Data Subject’s objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

Sharing Personal Data

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.

You may only share the Personal Data we hold with third parties, such as our service providers, if:

• they have a need to know the information for the purposes of providing the contracted services;
• sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;
• the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
• the transfer complies with any applicable cross-border transfer restrictions; and
• a fully executed written contract that contains GDPR-approved third party clauses has been obtained.

Changes to this Privacy Standard

We keep this Privacy Standard under regular review. This version was last updated on 1 June 2020.

About this Policy

The corporate information, records and data of the National Council of Women of Great Britain is important to how we conduct business and manage employees.

There are legal and regulatory requirements for us to retain certain data, usually for a specified amount of time. We also retain data to help our business operate and to have information available when we need it. However, we do not need to retain all data indefinitely, and retaining data can expose us to risk as well as be a cost to our business.

This Data Retention Policy explains our requirements to retain data and to dispose of data and provides guidance on appropriate data handling and disposal.

Failure to comply with this policy can expose us to fines and penalties, adverse publicity, difficulties in providing evidence when we need it and in running our business.

This policy does not form part of any employee’s contract of employment, or any contractors’ contract for services and we may amend it at any time.

For the purposes of this policy, the word “employee and /or Employees” shall be deemed to include all persons providing services to the National Council of Women of Great Britain under whatever form of contract.

Scope of the Policy

This policy covers all data that we hold or have control over. This includes physical data such as hard copy documents, contracts, notebooks, letters and invoices. It also includes electronic data such as emails, electronic documents, audio and video recordings and CCTV recordings. It applies to both personal data and non-personal data. In this policy we refer to this information and these records collectively as “data”.

This policy covers data that is held by third parties on our behalf, for example cloud storage providers or offsite records storage. It also covers data that belongs to us but is held by employees on personal devices 

This policy explains the differences between our formal or official records, disposable information, confidential information belonging to others, personal data and non-personal data. It also gives guidance on how we classify our data.

Guiding Principles

Through this policy, and our data retention practices, we aim to meet the following commitments:

• We comply with legal and regulatory requirements to retain data.
• We comply with our data protection obligations, in particular to keep personal data no longer than is necessary for the purposes for which it is processed (storage limitation principle).
• We handle, store and dispose of data responsibly and securely.
• We create and retain data where we need this to operate our business effectively, but we do not create or retain data without good business reason.
• We allocate appropriate resources, roles and responsibilities to data retention.
• We regularly remind employees of their data retention responsibilities.
• We regularly monitor and audit compliance with this policy and update this policy when required.

Roles and Responsibilities

Responsibility of all employees

We aim to comply with the laws, rules, and regulations that govern our organisation and with recognised compliance good practices. All employees must comply with this policy, the Record Retention Schedule, any communications suspending data disposal and any specific instructions from the Board. Failure to do so may subject us, our employees, and contractors to serious civil and/or criminal liability. An employee’s failure to comply with this policy may result in disciplinary sanctions, including suspension or termination. It is therefore the responsibility of everyone to understand and comply with this policy.

Records Management Officer

The designated Records Management Officer is responsible for identifying the data that we must or should retain, and determining, the proper period of retention. They also arrange for the proper storage and retrieval of data, co-ordinating with outside vendors where appropriate. and is responsible for:

• Administering the data management programme;
• Helping others implement the data management programme and related best practices;
• Planning, developing, and prescribing data disposal policies, systems, standards, and procedures; and
• Providing guidance, training, monitoring and updating in relation to this policy.

Data Protection Officer

Our Data Protection Officer (DPO) is responsible for advising on and monitoring our compliance with data protection laws which regulate personal data. 

Types of Data and Data Classifications

Formal or official records

Certain data is more important to us and is therefore listed in the Record Retention Schedule. This may be because we have a legal requirement to retain it, or because we may need it as evidence of our transactions, or because it is important to the running of our business. Please see page 15 below for more information on retention periods for this type of data.

Disposable information

Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a formal or official record as defined by this policy and the Record Retention Schedule. Examples may include:

• Duplicates of originals that have not been annotated.
• Preliminary drafts of letters, memoranda, reports, worksheets, and informal notes that do not represent significant steps or decisions in the preparation of an official record.
• Books, periodicals, manuals, training binders, and other printed materials obtained from sources outside of the National Council of Women of Great Britain and retained primarily for reference purposes.
• Spam and junk mail.

Personal data

Both formal or official records and disposable information may contain personal data; that is, data that identifies living individuals. Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). See page 14 below for more information on this.

Confidential information belonging to others

Any confidential information that an employee may have obtained from a source outside of the National Council of Women of Great Britain, such as a previous employer, must not, so long as such information remains confidential, be disclosed to or used by us. Unsolicited confidential information submitted to us should be refused, returned to the sender where possible, and deleted, if received via the internet.

Data classifications

Some of our data is more confidential than other data. Our Privacy policy explains how we classify data and how each type of data should be marked and protected.

Retention Periods

Formal or official records

Any data that is part of any of the categories listed in the Record Retention Schedule contained in the Annex to this policy, must be retained for the amount of time indicated in the Record Retention Schedule.  A record must not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or notice to preserve documents for contemplated litigation or other special situation) calls for its continued retention. If you are unsure whether to retain a certain record, contact the Records Management Officer.

Disposable information

The Record Retention Schedule will not set out retention periods for disposable information. This type of data should only be retained as long as it is needed for business purposes. Once it no longer has any business purpose or value it should be securely disposed of.

Personal data

As explained above, data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). Where data is listed in the Record Retention Schedule, we have taken into account the principle of storage limitation and balanced this against our requirements to retain the data. Where data is disposable information, you must take into account the principle of storage limitation when deciding whether to retain this data. More information can be found in in our Data Protection (Privacy) Policy.

What to do if data is not listed in the Record Retention Schedule

If data is not listed in the Record Retention Schedule, it is likely that it should be classed as disposable information. However, if you consider that there is an omission in the Record Retention Schedule, or if you are unsure, please contact the Records Management Department.

Storage, Back-Up and Disposal of Data

Storage

Our data must be stored in a safe, secure, and accessible manner. Any documents and financial files that are essential to our business operations during an emergency must be duplicated and/or backed up at least once per week and maintained off site.

Destruction

Our Records Management Officer is responsible for the continuing process of identifying the data that has met its required retention period and supervising its destruction. The destruction of confidential, financial, and employee-related hard copy data must be conducted by shredding if possible. Non-confidential data may be destroyed by recycling.

The destruction of data must stop immediately upon notification from a member of the Board that preservation of documents for contemplated litigation is required (sometimes referred to as a litigation hold). This is because we may be involved in a legal claim or an official investigation (see next paragraph). Destruction may begin again once the Board lifts the requirement for preservation.

Special Circumstances

Preservation of documents for contemplated litigation and other special situations

We require all employees and contractors to comply fully with our Record Retention Schedule and procedures as provided in this policy. All employees/contractors should note the following general exception to any stated destruction schedule: If you believe, or a member of the Board informs you, that certain records are relevant to current litigation or contemplated litigation (that is, a dispute that could result in litigation), government investigation, audit, or other event, you must preserve and not delete, dispose, destroy, or change those records, including emails and other electronic documents, until it is determined that those records are no longer needed. Preserving documents includes suspending any requirements in the Record Retention Schedule and preserving the integrity of the electronic files or other format in which the records are kept.  

If you believe this exception may apply, or have any questions regarding whether it may apply, please contact a member of the Board.

In addition, you may be asked to suspend any routine data disposal procedures in connection with certain other types of events, such as our merger with another organisation or the replacement of our information technology systems.

Breach Reporting and Audit Reporting policy breaches

We are committed to enforcing this policy as it applies to all forms of data. The effectiveness of our efforts, however, depend largely on employees. If you feel that you or someone else may have breached this policy, you should report the incident immediately to your supervisor. If you are not comfortable bringing the matter up with your immediate supervisor, or do not believe the supervisor has dealt with the matter properly, you should raise the matter with the Board. If employees do not report inappropriate conduct, we may not become aware of a possible breach of this policy and may not be able to take appropriate corrective action.

No one will be subject to and we do not allow, any form of discipline, reprisal, intimidation, or retaliation for reporting incidents of inappropriate conduct of any kind, pursuing any record destruction claim or co-operating in related investigations.

Other Relevant Policies

This policy supplements and should be read in conjunction with our other policies and procedures in force from time to time, including without limitation our:

• [IT and communications systems policy].
• [IT acceptable use policy].
• Data protection (privacy) policy.
• [Confidentiality policy].
• And any other policy from time to time in force.

Record Retention Schedule

The National Council of Women of Great Britain establishes retention or destruction schedules or procedures for specific categories of data. This is done to ensure legal compliance (for example with our data protection obligations) and accomplish other objectives, such as protecting intellectual property and controlling costs.

Employees should comply with the retention periods listed in this record retention schedule below, in accordance with the National Council of Women of Great Britain Data Retention Policy.

Company and Corporate Records

HR and Benefits Records Pensions Records

IT Records

Sales, Marketing and Customer Records

Legal Records