Billington Lodge - Data Retention Policy

Billington Lodge seeks to ensure that it retains only data necessary to effectively conduct its program activities and work in fulfilment of its mission.

The need to retain data varies widely with the type of data and the purpose for which it was collected. Billington Lodge strives to ensure that data is only retained for the period necessary to fulfil the purpose for which it was collected and is fully deleted when no longer required. This policy sets forth Billington Lodge’s guidelines on data retention and is to

be consistently applied throughout the organization.

Scope

This policy covers all data collected by Billington Lodge and stored on Billington Lodge’s owned or leased systems and media, regardless of location. It applies to both data

collected and held electronically (including photographs, video and audio recordings) and

data that is collected and held as hard copy or paper files. The need to retain certain

information may be mandated by law, legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).

Reasons for Data Retention

Billington Lodge retains only that data that is necessary to effectively conduct its

program activities, fulfill its mission and comply with applicable laws and regulations.

Reasons for data retention include:

1. Providing an ongoing service to the data subject (e.g. sending a newsletter,

publication or ongoing program updates to an individual, ongoing training or

participation in Billington Lodge’s programs

2. Compliance with applicable laws and regulations associated with financial and

programmatic reporting by Billington Lodge to its funding agencies and other

donors

3. Compliance with applicable labor, tax and immigration laws

4. Other regulatory requirements

5. Security incident or other investigation

6. Intellectual property preservation

7. Litigation

Data Duplication

Billington Lodge seeks to avoid duplication in data storage whenever possible, though

there may be instances in which for programmatic or other business reasons it is necessary

for data to be held in more than one place. This policy applies to all data in Billington Lodge’s possession, including duplicate copies of data.

Retention Requirements

Billington Lodge has set the following guidelines for retaining all personal data as

defined in the Institute’s data privacy policy.

1. Website visitor data will be retained as long as necessary to provide the service

requested/initiated through the Billington Lodge website.

2. Contributor data will be retained for the year in which the individual has contributed and then for 6 months after the date of the last contribution. Financial information will not be retained longer than is necessary to process a single transaction.

3. Event participant data will be retained for the period of the event, including any follow up activities, such as the distribution of reports, plus a period of 6 months;

4. Program participant data (including sign in sheets) will be retained for the duration of the grant agreement that financed the program plus any additional time required under the terms of the grant agreement.

5. Personal data of subgrantees, subcontractors and vendors will be kept for the duration of the contract or agreement.

6. Employee and volunteer data will be held for the duration of employment and then 6 months after the last day of employment.

7. Recruitment data, including interview notes of unsuccessful applicants, will be held for 6 months after the closing of the position recruitment process.

8. Consultant (both paid and pro bono) data will be held for the duration of the

consulting contract plus 6 months after the end of the consultancy.

9. Board member data will be held for the duration of service on the Board plus for 6 months after the end of the member’s term..

10. Operational data related to program proposals, reporting and program management will be held for the period required by the Billington Lodge donor

Data Destruction

Data destruction ensures that Billington Lodge manages the data it controls and

processes it in an efficient and responsible manner. When the retention period for the data as

outlined above expires, Billington Lodge will actively destroy the data covered by this

policy. If an individual believes that there exists a legitimate business reason why certain data

should not be destroyed at the end of a retention period, he or she should identify this data to the Business Manager/ Board of Trustees and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by Billington Lodge’s data protection lead in consultation with legal counsel. In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.