Retention Policy

Version 1.0 - 3rd September 2025

Purpose

This is the Data Retention Policy of The Gainsborough District Scout Council (Registered Charity (England & Wales): 522374).

The purpose of this policy is to specify The Gainsborough District Scout Council's guidelines for retaining different types of personal data and for how long.

For clarity, this policy does not include the movement data retention provision. This is because each Local Scout Group are their own distinct data controllers, separate to The Gainsborough District Scout Council.

Scope

This policy covers all data in the possession or control of The Gainsborough District Scout Council regardless of the medium in or on which those data are held. Where statute or regulation departs from the requirements of this policy, The Gainsborough District Scout Council will comply with the relevant statute or regulation. This policy may be updated from time to time.

Policy

Personal data

Personal data retention is governed by current Data Protection legislation. This data must be kept accurate, up to date and retained for no longer than is necessary for the purpose for which they were obtained. Detail of retention periods can be found here.

Where a person has requested that we delete all data we hold about them, we may need to retain basic personal data to evidence that we have completed the request.

Lawful purpose for processing

Personal Data can only be processed (including how it is retained) where there is a lawful basis.

The Gainsborough District Scout Council relies on different lawful bases depending on what the Personal Data is being used for. In some cases, The Gainsborough District Scout Council has a legal need or right to keep the data, but in other cases The Gainsborough District Scout Council relies on Data subjects consenting or The Gainsborough District Scout Council legitimate interests, where this needs to be actively managed.

Data subjects also have a number of rights that they can exercise over their Personal Data, such as to delete or rectify it.

Maintaining consent or legitimate reasons for retention

The Gainsborough District Scout Council needs to communicate with these data subjects to clearly sign post them to their ability to withdraw their consent or challenge the legitimate interest that has been assessed, this is commonly known as ‘opt out’. Where appropriate the data subject should be informed every 2 years of the consent or legitimate interest being used to process their data with an option to update this preference.

A formal retention period for data processing based on consent has not been defined in this policy and is assumed as permanent until the data subject exercises their rights to cease the processing activity. Examples of processing covered by this statement are subscribers to newsletters, photograph consents and marketing communications.