Background
Due to the increasing risk associated with digital information and data breaches, The Winston Churchill Memorial Trust (Trust, we, our) seeks to ensure that we only retain data necessary to effectively conduct our functions and activities in fulfilment of our mission.
The need to retain data depends on the type of information and the purpose for which the information was collected.
Purpose
The Trust has developed this Data Retention Policy (Policy) to provide guidance on the protection of our data, ensuring that all data is retained for the period necessary to fulfil its purpose, and then disposed of in a lawful and appropriate manner.
Scope
This Policy applies to:
- application information provided by an Applicant for a Churchill Fellowship (Application data)
- information about a Fellow and the Referee from reference forms completed by a Referee (Reference data)
- bank account details provided by a Churchill Fellow for payment of their allowances from the Trust (Bank Account data)
collected and maintained, in any format by the Trust for the purpose of evaluating and considering an Applicant’s suitability to be a Fellow as well as administering Churchill Fellowship related transactions.
The Trust maintains ownership of all Application data, Reference data and Bank Account data, unless otherwise specified.
Responsibilities
This Policy applies to all:
- Trust Staff
- Service providers, such as the Trust’s digital consultants
- Trust volunteers (such as assessors)
Retention
The data must be retained for:
- (Application data) 6 months after each application round close date
- (Reference data) 1 year after a Fellow has completed their Fellowship program
- (Bank Account data) 1 week after the final Overseas Living Allowance payment has been transferred to a Fellow
These retention periods are required to:
- (Application data) assess applications and provide the Trust with reasonable time to complete any necessary follow-up with unsuccessful Applicants
- (Reference data) maintain the contact information and references of Referees as a contingency measure to reach out in case a Fellow fails to fulfil their Fellowship responsibilities
- (Bank Account data) transfer funds to a Churchill Fellow so that they can complete their Churchill Fellowship.
Disposal
Appropriate data disposal ensures that the Trust manages the data it controls and processes it in an efficient and responsible manner. When the Retention Period for the data expires, the Trust will destroy the data covered by this Policy.
Before a decision is made to dispose of the data, the following points should be taken into consideration according to the appropriate legislation:
- the data is no longer required, or likely to be required by any statutory authority/ government agency;
- destruction or disposal will not damage the Trust;
- no work is outstanding; and
- no litigation, investigation or access request is current or pending which is relying on that data or for which the data may be required.
Destruction of the data is to be undertaken through:
- (Application data) digital deletion of all Applicant’s personal information with the help of our digital consultants service provider. Personal information includes data such as name, date of birth, email, street address and phone number. We will keep deidentified Application data such as city, postcode, gender and project information.
- (Reference data) digital deletion of all Reference data
- (Bank Account data) digital deletion of all Bank Account data
If Trust Staff, service providers or Trust volunteers are unsure of whether to dispose of the data, they must consult with the Trust CEO prior to disposal.
Related documents
Evaluation of this policy
This Policy shall be reviewed every 2 years by the Trust CEO or following changes to relevant legislation.