Data Retention Policy

Introduction

 

This data retention policy sets out the obligations of Thanet Road Runners Athletics Club (“us/we/our”) and the basis upon which we shall retain, review and destroy data held by us, or within our custody or control.

 

This policy applies to our entire organisation including our officers, committee members and subcontractors and sets out what the retention periods are and when any such data may be deleted.

 

 

Objectives

 

It is necessary to retain and process certain information to enable our club to operate. We may store data in the following places:

 

 

This policy applies equally to paper, electronic media and any other method used to store personal data. The period of retention only commences when the record is closed. We are bound by various obligations under the law in relation to this and therefore, to comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully in respect of their personal data under the General Data Protection Regulation (“the Regulation”).

 

The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

 

This Policy sets out the procedures that are to be followed when dealing with personal data and how we aim to comply with the Regulation in so far as it is possible. In summary, the Regulation states that all personal data shall be:

 

a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;

 

b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

 

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

 

d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;

 

e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;

 

f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

 

The Fourth and Fifth Data Protection Principles require that any data should not be kept longer than necessary for the purpose for which it is processed and when it is no longer required, it shall be deleted and that the data should be adequate, relevant and limited for the purpose in which it is processed.

 

With this in mind, this policy should be read in conjunction with our other policies which are relevant such as our privacy policy.

 

 

Security and Storage

 

All data and records are stored securely to avoid misuse or loss. We will process all personal data we hold by taking appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

 

We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if there is agreement by them to comply with those procedures and policies, or if there are adequate measures in place.

 

Examples of our storage facilities are as follows:

 

Google GSuite – Google Drive

 

We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

 

(a) Confidentiality means that only people who are authorised to use the data can access it.

 

(b) Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.

 

(c) Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the clubs provided Google Drive instead of individuals PCs.

 

 

Retention Policy

 

Data retention is defined as the retention of data for a specific period of time and for back up purposes.

 

We shall not keep any personal data longer than necessary but acknowledge that this will be dependent on the different types of documents and data that we have responsibility for. As such, our general data retention period shall be for a period of 1 year. Our specific data retention periods are set out below:

 

Type of data
Type of data subject
Type of processing
Purpose of processing
Type of recipient to whom personal data is transferred
Retention period
Data accuracy and minimisation on review date
Members Adults Personal Identifiable Data (PID) Club Member Contract Participation in the service (TRAC membership) None 30 days from expiry of membership June 2019
Members Youth Personal Identifiable Data (PID) Club Member Contract Participation in the service (TRAC membership) None 30 days from expiry of membership June 2019
Suppliers/Contractors Contact details Third Parties Contract Provision of services to the club None 1 year June 2019
Volunteers personal information Volunteers Legitimate interests Provision of services to the club None 1 year June 2019
Other Running Club Members and Affiliations Contact Details Other Clubs and associations Legitimate interests Sharing of data and best practices None 1 year June 2019
Sensitive medical data for members Club members Contract Participation in the service (TRAC membership) Emergency Services 30 days from expiry of membership June 2019
Race entry data Personal details entered by race entrants Consent (for future race qualification) Race data for members None 3 years June 2021
Other Running Club Members and Affiliations Contact Details Other clubs and associations Legitimate interests Sharing of data and best practices None 1 year June 2019
Race entry data Personal details entered by race entrants Consent (for future race qualification) Race data for members None 3 years June 2021
Historical Race Data

Minimal personal data

(Name, gender, age category)

Legitimate interests

Results are intrinsic to manage the sport of Athletics on all levels of competition & goals.

None Always None

 

From time to time, it may be necessary to retain or access historic personal data under certain circumstances such as if we have contractually agreed to do so or if we have become involved in unforeseen events like litigation or business disaster recoveries.

 

 

Destruction and Disposal

 

Upon expiry of our retention periods, we shall delete confidential or sensitive records categorised as requiring high protection and very high protection, and we shall either delete or anonymise less important documents.

 

Our Records Management Officer (Club Secretary) is responsible for the continuing process of identifying the records that have met their required retention period and supervising their destruction. The destruction of confidential, financial, and personnel-related records shall be securely destroyed electronically or by shredding if possible. Non-confidential records may be destroyed by recycling

 

IMPORTANT

The club’s Data Retention Policy works in conjunction with the Privacy Policy and Privacy Notice.

We use cookies to give you the best online experience. By agreeing you accept the use of cookies in accordance with our cookie policy.

Privacy Settings saved!
Privacy Settings

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. Control your personal Cookie Services here.

These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site.

We track anonymized user information to improve our website.

  • _ga
  • _gid
  • _gat
  • __utmc
  • __utmb
  • __utmt

Decline all Services
Accept all Services