Chapter 10 — Retention and individual rights
Lesson map
Lesson 10 published. Map, example, EX046.
flowchart TD
N0["Learning outcomes"]
N1["10.1 Retention schedule"]
N2["10.2 Deletion in practice"]
N3["10.3 Access requests"]
N4["10.4 Other rights"]
N0 --> N1 --> N2 --> N3 --> N4
N4 --> EX["Worked example"]
EX --> Q["Exercise EX046"]
Logical drawing
flowchart LR
N0["Learning outcomes"]
N1["10.1 Retention schedule"]
N2["10.2 Deletion in practice"]
N3["10.3 Access requests"]
N4["10.4 Other rights"]
N0 --> N1 --> N2 --> N3 --> N4 --> Q["EX046"]
[Learning outcomes]
|
v
[10.1 Retention schedule]
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v
[10.2 Deletion in practice]
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v
[10.3 Access requests]
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v
[10.4 Other rights]
|
v
[Worked example] --> [Exercise EX046]
Learning outcomes
You will (1) set a simple retention schedule; (2) delete data safely; (3) respond to requests from individuals.
10.1 Retention schedule
Grace drafts a retention schedule with owners. Client referrals are kept for one year after the last parcel, long enough to handle repeat referrals and queries. Donor gift records are kept for the period tax rules require for gift aid claims. Volunteer records are kept for a short period after leaving, except safeguarding records, which follow sector guidance. Each entry has a reason. The trustee overseeing data approves the schedule. Grace shares the schedule with all owners and adds it to the inventory so that each set of data shows how long it will be kept.
10.2 Deletion in practice
Grace arranges a monthly routine: the case system lists referrals past one year since the last parcel, a lead checks them and deletes them, recording the count. The five-year-old paper forms found in the inventory are shredded securely with a record kept. She asks the donor database supplier to set automatic deletion for lapsed records after the tax period. Mr. Nowak notes that routine deletion is easier than occasional large clear-outs. The first monthly run deletes a large number of old referrals, and the lead records the count in the log.
10.3 Access requests
A former client asks what information Northbank holds about her. Grace checks the inventory to find all places: the case system, the referral mailbox and the charity phone at her food bank. She gathers the information, removes details about other people, such as the referrer's internal notes about other family members, and responds within a month. She records the request and response in a log. The former client thanks Northbank for the clear reply, and Grace notes that the inventory made the search take an afternoon instead of the days it might otherwise have taken.
10.4 Other rights
A donor asks to stop receiving appeals. Grace marks the record as no marketing rather than deleting it, so the donor is not added again from an old list. Another person asks for a wrong address to be corrected, and Grace corrects it in the database and the newsletter service. She notes that each right needs a clear process, and that the inventory makes it possible to find every copy of a person's data. She writes a one-page procedure for each type of request.
Worked example
Grace sets retention including one year after the last parcel for referrals, runs monthly deletion and shreds old forms, answers a former client's access request within a month and handles marketing objections and corrections across systems.
Synthetic case. The schedule and requests are synthetic; the GDPR is real.
Errors and limits
Deleting a donor who objects to marketing risks re-adding them from old lists; suppress instead.
Exercises
- EX046 — Referral retention. How long are referrals kept after the last parcel? Rubric: 3 = one year;; 2 = partly correct;; 1 = wrong;; 0 = none.
- EX047 — Deletion checker. Who checks referrals before deletion? Rubric: 3 = a food bank lead;; 2 = partly correct;; 1 = other;; 0 = none.
- EX048 — Access search. Where did Grace search for the former client's data? Rubric: 3 = case system, referral mailbox and charity phone;; 2 = all;; 1 = some;; 0 = none.
- EX049 — Objection handling. How was the donor's objection handled? Rubric: 3 = marked no marketing, not deleted;; 2 = partly correct;; 1 = deleted;; 0 = none.
- EX050 — Correction scope. Where was the wrong address corrected? Rubric: 3 = database and newsletter service;; 2 = both;; 1 = one;; 0 = none.
Continue studying — lesson 10 (chapter 10 of 12)
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