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GDPR

GDPR – Data Retention Policy

  1. Introduction

This Policy sets out the obligations of Staff Development Forum, a company registered in the United Kingdom under number 6682352 whose registered office is at 62 Sheffield Road, Hoyland, Barnsley. South Yorkshire. S74 0DQ (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 (DPA 2018) and EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

  1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above)
  2. When the data subject withdraws their consent
  3. When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest
  4. When the personal data is processed unlawfully (i.e. in breach of the GDPR)
  5. When the personal data must be erased to comply with a legal obligation or
  6. Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company for subscription to the newsletter purposes and the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.

  1. Aims and Objectives
    • The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR.
    • In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.
  1. Scope
    • This Policy applies to all personal data held SDF and by third-party data processors processing personal data on the Company’s behalf.
    • Personal data, as held by SDF is stored in the following ways and in the following locations:
      1. Computers and mobile devices owned by employees, agents, and sub-contractors.
      2. Physical records stored in 62 Sheffield Road, Hoyland, South Yorkshire.

Lawful Basis for Processing:
Data collected for JiscMail and mailing list purposes is provided voluntarily by individuals and processed on the lawful basis of consent, in compliance with Article 6(1)(a) of the UK GDPR.

Consent Withdrawal:
Subscribers have the right to withdraw their consent at any time. This can be done by:

  • Clicking the unsubscribe link included in every communication from the mailing list.
  • Sending a request to withdraw consent to office@sdf.ac.uk.

Once consent is withdrawn, the individual’s data will be removed from our systems within 30 days, unless there are other lawful bases for retaining it (e.g., for compliance with legal obligations).

  1. Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy.

  • Subject Access Requests (SARs): Individuals may request access to, erasure of, or portability of their personal data by submitting a written request to the designated contact (see Section 8). A step-by-step guide is available upon request.
  • Verification: To ensure data security, the Company will verify the identity of the requester before fulfilling any SAR or data portability request. Verification may include providing identification documents or answering security questions.
  • Timeframes:
    • The Company will respond to SARs within one month of receipt.
    • This period may be extended by two additional months for complex requests, with an explanation provided to the requester within the initial one-month period.
    • If a request cannot be fulfilled within these timeframes, the requester will be informed, and the reasons will be documented.
  • Exceptions to Erasure (A):
    • Data cannot be erased if it is required to comply with legal obligations or for the establishment, exercise, or defence of legal claims.
    • Examples include compliance with HMRC regulations, contractual obligations, or governance requirements.
  • Transparency and Communication (B):
    • The Company will confirm the outcome of SARs, including erasure requests, to the requester. If a request is refused, the reasons will be clearly communicated, along with information about the right to lodge a complaint with the Information Commissioner’s Office (ICO).

A – How to Request Erasure or Data Portability

1. Submitting a Request

If you wish to request the erasure of your personal data or exercise your right to data portability, please follow the steps below:

  • Prepare Your Request
    • Clearly state whether your request is for erasure or data portability.
    • Include details of the personal data you are referring to and any relevant context (e.g., the purpose for which you believe the data was collected).
    • Specify whether you are requesting data in a structured, machine-readable format or a direct transfer to another organisation (for portability requests).
  • Contact Us
    • Send your request in writing to:
      • Email: office@sdf.ac.uk
      • Post: Data Protection Officer, Staff Development Forum,Obsidian Offices, 4 Chantry Court, Chester CH1 4QN
  • Identity Verification
    • To protect your data, we may ask you to provide proof of identity (e.g., a copy of a government-issued ID).
    • If requesting on behalf of someone else, additional authorisation documents will be required.

2. How We Will Respond

  • Acknowledgement
    • We will acknowledge receipt of your request within 3 business days and confirm if we need additional information.
  • Processing Your Request
    • Erasure Requests
      • If your request meets the criteria (e.g., the data is no longer necessary for the original purpose), we will erase your data and confirm the action.
      • If your request is denied, we will explain the reason (e.g., legal obligation to retain the data).
    • Data Portability Requests
      • We will provide your data in a structured, commonly used, machine-readable format, or transfer it to the organisation you specify (where feasible).
  • Timeframes
    • We aim to complete requests within 30 calendar days of receiving all necessary information.
    • For complex requests, we may extend this by up to two months and will inform you of the reason for the delay.
  • Contact for Questions
    • If you have questions or require assistance with your request, please contact our Data Protection Officer (DPO) – see section 8.

3. Exceptions

Certain requests may not be fulfilled, such as:

  • If the data is required to comply with legal obligations.
  • If retaining the data is necessary for the establishment, exercise, or defence of legal claims.
  • If the request is manifestly unfounded or excessive.

We will provide clear reasoning if we are unable to fulfil your request.

B – Transparency and Communication

To ensure fairness and clarity, we will keep data subjects informed throughout the process of handling their requests for erasure or data portability.

  • Acknowledging Your Request
  • Upon receiving your request, we will send an acknowledgement email or letterwithin 3 business days. This will include:
    • Confirmation that your request has been received.
    • A reference number for tracking your request.
    • An outline of the next steps in the process.
  • Regular Updates
  • If the request is straightforward, we will inform you once it has been fulfilled or provide an explanation if it is denied.
  • For more complex requests or delays, we will:
    • Notify you within the standard 30-day time frame that additional time is required (up to two months).
    • Provide updates at regular intervals to keep you informed about the progress.
  • Confirmation of Action Taken
  • For Erasure Requests:
    • If your personal data is erased, we will provide you with a written confirmation stating:
      • The scope of the data erased.
      • The date the erasure was completed.
      • Any data we are legally required to retain, with reasons.
    • If we are unable to erase certain data, we will explain why (e.g., compliance with a legal obligation).
  • For Data Portability Requests:
    • We will provide your data in a structured, commonly used, and machine-readable format (e.g., CSV, XML).
    • If you request a direct transfer to another organisation, we will confirm once the transfer is completed or explain any technical limitations.
  • Clear Denial Communication
  • If your request cannot be fulfilled, we will provide:
    • A detailed explanation of the reasons for refusal (e.g., legal obligations, overriding legitimate interests).
    • Information on how to challenge our decision or escalate the matter to the Information Commissioner’s Office (ICO).
  • Contact Details for Further Assistance

If you have questions about the outcome of your request or require clarification, you can contact:

  • Data Protection Officers (DPO): Dr Rossana Gent and Mr J. Ashton-Kinlin, office@sdf.ac.uk
  • We are committed to ensuring you fully understand our actions and decisions.
  1. Technical and Organisational Data Security Measures
    • The following technical measures are in place within the Company to protect the security of personal data. Please refer to Parts 22 to 26 of the Company’s Data Protection Policy for further details:
      1. All emails containing personal data must be encrypted.
      2. All emails containing personal data must be marked “confidential”.
      3. Personal data may only be transmitted over secure networks.
      4. Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative.
      5. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted.
      6. Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient.
      7. No personal data may be shared informally.
      8. All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely.
      9. No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation.
      10. Personal data must be handled with care at all times and should not be left unattended or on view.
      11. Computers used to view personal data must always be locked before being left unattended.
      12. No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
      13. All electronic copies of personal data should be stored securely using passwords and encryption.
      14. All passwords used to protect personal data should be changed regularly and must be secure.
      15. Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method.
      16. All software should be kept up-to-date.
      17. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of JP Ashton-Kinlin (SDF Administrator) to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
  • The following organisational measures are in place within the Company to protect the security of personal data. Please refer to Part 27 of the Company’s Data Protection Policy for further details:
    1. All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s Data Protection Policy.
    2. Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company.
    3. All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so.
    4. All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised.
    5. All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times.
    6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed.
    7. The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed.
    8. All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the GDPR and the Company’s Data Protection Policy.
    9. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s Data Protection Policy;
    10. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under the GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Technical and Organisational Measures for Data Breach Response

  1. Immediate Detection and Containment
  • Incident Identification:
    • Implement automated systems to detect unusual activity (e.g., unauthorised access, data exfiltration).
    • Ensure employees are trained to recognise and report potential breaches promptly.
  • Containment:
    • Immediately isolate affected systems to prevent further data loss.
    • Disable compromised accounts and reset passwords as needed.
  1. Assessment and Investigation
  • Assessment:
    • Evaluate the nature and scope of the breach.
    • Determine the categories and volume of data involved.
    • Assess the risk to individuals’ rights and freedoms (e.g., financial loss, identity theft).
  • Investigation:
    • Conduct an internal investigation to identify the root cause.
    • Gather logs and other evidence to understand how the breach occurred.
  1. Reporting and Notification
  • Notification to the ICO:
    • Notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach, if there is a risk to data subjects’ rights.
    • Include the following details in the report:
      • Nature of the breach.
      • Number of data subjects affected.
      • Categories of data involved.
      • Actions taken or planned to mitigate the impact.
  • Notification to Data Subjects:
    • If the breach is likely to result in a high risk to individuals’ rights and freedoms, inform affected individuals without undue delay.
    • Provide clear information, including:
      • What happened and the potential consequences.
      • Steps the organisation is taking to mitigate harm.
      • Guidance on how individuals can protect themselves (e.g., monitoring accounts, changing passwords).
  1. Mitigation and Remediation
  • Immediate Action:
    • Implement measures to stop the breach (e.g., patch vulnerabilities, change configurations).
  • Remediation Plan:
    • Address systemic issues that led to the breach.
    • Update security policies, procedures, or technologies if needed.
    • Train staff on updated processes.
  1. Post-Breach Review and Documentation
  • Review:
    • Analyse lessons learned and improve breach detection and response capabilities.
    • Test the updated systems to ensure effectiveness.
  • Documentation:
    • Maintain a detailed record of the breach, including:
      • Timeline of events.
      • Actions taken to address the breach.
      • Communications with the ICO and data subjects.

Example of Notification Timelines

  • Internal Reporting: Within 24 hours of discovering the breach.
  • ICO Notification: Within 72 hours if required.

Affected Data Subjects Notification: As soon as possible if there is a high risk to their rights and freedoms.

  1. Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

  • Personal data stored electronically (including any and all backups thereof) shall be deleted.
  • Personal data stored in hardcopy form shall be shredded when no longer required.
  1. Data Retention
    Type of Data Retained Retained for (time period)
    Active Member Data (e.g., contact details, membership details) The duration of membership while members are subscribed to the Jiscmail.
    Lapsed or Cancelled Memberships 6 years after the membership ends, although we add members to Jiscmail and mailchimp, members are free to unsubscribe and this would be immediate.
    Membership Fees and Payment Records (Financial records) 6 years to comply with HMRC regulations, although membership is free of charge at present.
    Mailing List Data (e.g., newsletters, event updates) Until the individual withdraws consent or the purpose for processing the data is no longer valid
    Event Registration Data 1 years after the event, unless required longer for audit or reporting purposes
    Queries and Support Requests 2 years after the resolution of the query, unless they are part of a larger contractual or legal record
    Member Contributions to Research, Publications, or Historical Projects Indefinitely, provided data is anonymised or used with appropriate safeguards for archival purposes
    Health or Accessibility Data (e.g., dietary requirements for events) Only the duration of its relevance (e.g., until the event is completed) and securely deleted afterwards. Since 2020, SDF has not been collecting this data, as most requests are done virtually.
    Board/Committee Member Records 6 years post-tenure for legal and governance purposes.
    Meeting Minutes and Decisions Permanently for governance and archival purposes
    Event Attendee Data (non-members) 1 year post-event, although all events are only attended by members and speakers.
    Prospective Member Data (e.g., enquiries) 1 year if no membership is finalised. 
    Website Analytics Data 3 years depending on the tool used and the individual’s consent. If consent is revoked, content is removed immediately.
    • As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
    • Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.
    • When establishing and/or reviewing retention periods, the following shall be taken into account.
      1. The objectives and requirements of the Company.
      2. The type of personal data in question:
      3. The purpose(s) for which the data in question is collected, held, and processed.
      4. The Company’s legal basis for collecting, holding, and processing that data.
      5. The category or categories of data subject to whom the data relates.
    • If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
    • Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).
    • In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.
    • The personal data obtained for from individuals for subscription purposes is voluntarily provided to SDF. The mailing list and JiscMail (support network forum) are both self-subscription platforms, therefore, personal data is provided, rather than collected.
    • In instances whereby delegates wish to obtain support throughout the subscription process, SDF staff will be provided with personal data, including identifiers, which will be treated within the regulations et out within this document. All retention and privacy regulations dictated throughout this document will be applied to personal data provided to SDF by our delegates for subscription and mailing list purposes.
    • The SDF website is structured in a WordPress frame and uses cookies. The purpose of which is to enhance visitor experience and monitor traffic patterns for continuous improvement. The cookies are strictly necessary, essential for the SDF site to perform basic functions.
    • The SDF website cookies are used to store preferences set by the user, including name, language, and location, where appropriate. Information is collected on how users interact with other websites wo which the SDF website is linked also. These are set by trusted third-party networks. Visitors to the SDF website have the option of turning cookies off upon entry to the site.
  1. Roles and Responsibilities (Data Protection Officers)
    • Dr Rossana Gent – SDF Chair and JP Ashton-Kinlin – SDF Administrator, shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.
    • Dr Rossana Gent – SDF Chair and JP Ashton-Kinlin – SDF Administrator shall be responsible for ensuring compliance with the above data retention periods throughout the Company
    • Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to Dr Rossana Gent – SDF Chair and JP Ashton-Kinlin – SDF Administrator.
  1. Implementation of Policy

This Policy shall be deemed effective as of 27th January 2025. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name: Dr Rossana Gent
Position: SDF Chair
Date: 27/01/2025
Date for Review: 27/01/2026

Policy Updated: 27/01/2025 to reflect update in regulations and change of SDF Administrator