Privacy : Data Retention Policy
Data Retention – TO TAKE EFFECT FROM 25.05.18
We are committed ensuring the responsible, safe and legitimate collection, retention and usage of information about individuals in order to protect their privacy whilst providing controlled access to that information by those with a legitimate and permitted interest.
This policy outlines the arrangements for retaining personal data.
- Only retain data for the period for which it is needed. This period shall be defined first by regulation/statute/law, where applicable, and thereafter by internal policy;
- Personal bank details, where they are necessarily held for the purposes of making payment under our responsibilities as an employer, or as an organisation paying expenses to its volunteers, shall be held in line with current HMRC guidance (6 years). Bank details are held on a computer and are password protected, with a copy held off site.
- For ESFA volunteers and national competition entrants, personal contact details shall be held for the season in which they are necessary, and then removed from the electronic database prior to the end of September of the following season, unless you give your permission for them to be retained and re-used. Personal details are held on network-enabled PCs on The FA’s server, and in hard copy, in the ESFA’s annual handbook. Copies of the ESFA handbook are retained as part of the Association’s historic archive.
- Player details you provide us with may be retained beyond this period if that player has been subject to disciplinary action and those records shall be maintained for the duration specified by The FA’s regulations (5 years)
- Records of protests lodged under the ESFA’s General Competition Rules shall be retained in line with The FA’s regulations
- Safeguarding case files shall be kept in line with The FA’s regulations.
- For players representing English Schoolboys/Schoolgirls national teams, data will be retained for the archive and the roll of honour, but contact details will be removed from the records unless you specifically ask us to keep in touch. Parent/carer/guardian contact details will also be removed, unless otherwise requested, at the end of the season in which the player played.
- Volunteers who are recognised in any of the ESFA’s rolls of honour shall continue to have their name held for the record, in the Association’s public record and the archive.
- Records of complaints shall be removed from all ESFA systems (electronic and paper-based) within two weeks of the conclusion of the complaints procedure
- At the end of each season, the ESFA shall conduct a “data purge” to ensure that the conditions laid down in this policy are upheld.
References and tools to support the Policy
- Data protection policy and privacy notices
- FA handbook
- FA IT acceptable use policy
- Safeguarding policy and guidance
- Complaints procedure
- Staff handbook
- Governance handbook
- Contract of employment
- ESFA website – esfa.co.uk
- The Office of the Information Commissioner – www.ico.gov.uk
Policy Review Arrangements
This policy will be reviewed at least annually.