Retention policy about web HOT 8 CLOSED

In short, the when a member leaves the membership register should delete everything except the member ID, membership start date and membership end date.

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I have asked the Charity Commission to confirm how long they need us to keep personal information on the register of members. They should reply by 2020-12-15.

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Charity Commission response;

We would stress from the outset that the Charity Commission is not the absolute authority on GDPR and data retention. You should also direct your enquiry to the Information Commissioner's Office (ICO) after you have considered our advice.

It might be useful to explain the issue from the point of view of our own policy on the subject; for example, once a charity dissolves and is removed from the Register of Charities, so too are the trustee details of that charity. You could say that they have the right to be forgotten once the charity has closed.

By this token perhaps (but you should verify this with the ICO) you should remove any personal details once a member leaves or cancels their membership.

However we would also emphasis that, although your governing document may have a stipulation on the subject, the Commission does not require you to retain membership details after the member has left; this is matter relating purely to the internal administration of the charity and as such is none of our business.

You can find more detailed information at the Information Commissioner's Office (ICO) website: https://ico.org.uk/

See more at:

https://www.gov.uk/government/publications/its-your-decision-charity-trustees-and-decision-making/its-ycision-makixng

in summary then we have no objection to your proposals, providing that the trustees meet the legal requirements outlined

The essential trustee: what you need to know, what you need to do (CC3)

https://www.charitygovernancecode.org/en/front-page

If the trustees remain in any doubt, we would suggest that you also obtain the appropriate legal advice in taking this process forward:

http://solicitors.lawsociety.org.uk/

https://www.lawworks.org.uk/legal-advice-not-profits/free-legal-assistance.

Also the Small Charities Coalition is a national umbrella and capacity-building organisation with over 7,000 members UK-wide. This organisation may be able to guide you further. See more at:

https://www.smallcharities.org.uk/resources/

http://www.smallcharities.org.uk/skills-sharing-mentoring/

[email protected]

I trust this information is of some assistance to you. Very often the quickest way to answer your enquiries will be to look on our website

www.charitycommission.gov.uk.

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Relates to #199

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Maybe requires #223

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I will investigate how to get the task ID from celery

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Does this help @SamWinterhalder?

Celery - Get task id for current task

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Discussed this with @SamWinterhalder and we have decided that

delete account after 120 hours and send email to notify

Is not a pre-go-live feature. Will be implemented alongside #25

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