RETENTION OF RECORDS POLICY
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 essential 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:
- 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 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
4.1 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.
- 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.
- 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 deleted and the recycle bin emptied or by deleting and reformatting the drive of the computer the file is held on.
Date of Policy: July 2019
|Type of Information||Retention Period||Data Owner (title or title equivalent)|
|Supporter Personal Information||Our business need will determine the length of time for which personal information will be retained.
Information connected to donations will be retained until ten full financial years have elapsed since a donors’ last gift OR two full financial years have elapsed from our notification of their death. Thereafter all data relating to the data subject will be deleted as part of an annual data hygiene programme.
Supporter data held in microsites, such as Mailchimp, will be retained until one full financial year has elapsed since a donors’ last gift.
Exceptions: The name and address of people who ask not to be mailed will be kept for as long as necessary to ensure that they are not mailed again.
The records of Donors who have expressed an interest in leaving a gift in their Will to YMCA will be retained until they expressly state that they will not be leaving such a gift or until four full financial years have elapsed from our notification of their death. This will enable us to identify the correlation between expressions of interest and subsequent actions.
Information required for the purpose of legacy administration will be retained until two full financial years have elapsed since the full Legacy gift has been received.
|Head of Fundraising|
|Grants Casework and Beneficiary||Holdings reviewed at the two-year point.
Information connected to beneficiaries will be
retained for a maximum of seven years after the end of service delivery relationship plus the
current financial years.
|Head of Fundraising|
|Financial Information – including:
records of banking transactions,
tax records, audits.
|Retention period ranges from between six years to ten years from the end of the Financial Year in which the transaction was made, in line with
|Head of Finance|
|Gift Aid records||Retention of record for six years||Head of Retail|
|Details of Injuries or Accident Reports/Records
|Six years from time of accident occurring.
|Recruitment Information for Unsuccessful Applicants: Job Application Forms, CV’s and other details including interview notes||Seven months after unsuccessful applicant
notified of outcome – Equality Act 1980
|Personnel and employment records:
• Job description and terms & conditions
• Appraisal records, objectives, performance reviews or targets agreed
• Development/training needs and records of completed activities.
|Six years after employment has ceased
|Pay, payroll and benefits information (HMRC requirements)||Seven years after employee has left employment – Taxes Management Act
|Wages, salary, expenses and overtime||Seven years – Taxes Management Act||Payroll Manager|
|Redundancy details||Six years after employment has ceased||Head of HR|
|Life assurance||Six years after employment has ceased||Head of|
|Records of pension contributions deducted||Seven years after employee has left employment – Taxes Management Act
|Statutory Maternity pay records, calculations or certificates||Three years after the end of the tax year to which maternity period ends||Head of HR|
|Statutory sick pay records, calculations, certificates and self-certification||Three years after the end of each tax year||Finance Controller|
|Case studies (stories of beneficiaries) that are not in the public domain||From 6 years after consent expires||Head of Policy, Campaigns and International|
|Campaigner data||From 6 years within our platform||Head of Policy, Campaigns and International|
|Insurance policies, claims and correspondence||Three years after lapse or after settlement||Resources Director|
|Employers Liability insurance certificate||40 years – consistent with Employers Liability (Compulsory Insurance) Regulations 1998||Resources Director|
|Accident Reports and Correspondence||Three years after settlement||Head of Health and Safety|
|Trustee minutes, minutes of general meetings and other resolutions||Minimum 10 years from the date of the meeting or from the date of passing a resolution||Company secretary|
|Annual accounts and annual review||Permanently||Director of Resources|
|Health and safety records||Three years for general records (and permanently for records relating to hazardous materials)||Head of Health and Safety|
|Contracts with customers and suppliers||6 years after expiry of termination of the contract||Financial Controller|
|Property deeds||Permanent – Limitations Act 1980||Company Secretary|
|Leases||12 years after the lease and liabilities under the lease have been terminated – Limitations Act 1980||Company Secretary|