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Data retention policy

Policies

Data retention policy

All information will be held and processed under the UK GDPR legislation and ACC will use the following Data Retention Policy for each type of data sets. Any information that is stored in the database, on any computerised system or paper based is relevant to the purpose it was collected for.

Retention of data and refusal of right to erasure

Under UK GDPR an individual has the right to ask for their data to be removed (right to erasure), this data should then be removed in a timely manner if not immediately. However, there are also approved reasons when removal can be refused:

  • To comply with a legal obligation for the performance of a public interest task or exercise of official authority.
  • For public health purposes in the public interest.
  • Archiving purposes in the public interest, scientific research historical research or statistical purposes.
  • The exercise or defence of legal claims.

This gives ACC the right to refuse a request for removal from current or previous members holding membership types that are subject to professional conduct investigations whether managed by ACC or another relevant party (e.g. a training organisation or other membership body). These include:

  • Register members
  • Overseas Counsellor members
  • Level 4 Students
  • Counselling Affiliates
  • Counselling and Training Affiliates
  • Pastoral Care Sole Affiliates

Below are the retention policies relating to the groups of people and organisations for whom ACC gathers and processes data. Please see ACC’s Privacy Policy for a definition of these roles.

a). Visitor

The personal data that we hold about you in our own systems will be processed and stored within the United Kingdom. Information held as you visit our website by web browsers and google analytics will be stored according to these third party’s policies and processes. ACC will retain on our systems your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting obligations. For example, we may need to retain some of your personal data for 6 years after you have made a purchase form us for legal reasons.

b). Enquirer

All information relating to an enquiry by email or telephone will generally be kept for as long as it is necessary to where it relates to running an Accredited Register of Counsellors and other professions and pastoral memberships. Examples include enquiries about joining ACC, questions from former members and concerns raised by members of the public or other third parties about a current or past member of ACC. General enquires from members of the public for assistance for example in finding a counsellor will be deleted as soon as they have been resolved.

c). Purchasers

This section sets out the timescales that ACC would keep information after each purchase of a service or product and what information will be retained.

  • Data relating to the purchaser will be kept for 6 years after the purchase has been made or (in the case of training events) the event has completed (whichever is the later).
  • After this 6-year period personal data may be retained in the Marketing contacts area of the database if express permission has been given.
  • All information apart from the marketing contacts (stored with express permission as above) will be removed after 6 years.

d) Members/designated contacts for organisational members

This lists the timescales that ACC would keep information for each of the membership types and what information will be removed on cessation of membership. Individual Pastoral Care Members, Friends (including old Accord subscriptions), Pastoral Care Affiliated (Not Sole Affiliated), L2 Students, L3 Students, Fellows and Honorary Fellows and any other membership where complaints would not be heard.

  • On termination of membership all information will be kept for 6 years, this allows for any queries to be dealt with and to meet the requirements of any accounting policies.
  • After 6 years all data held on or linked to the members record will be deleted unless the person has had an additional or linked membership which is or has been active during the six years.
  • This will include personal data of the Designated Contacts for Affiliate Members and personal data of the “Members Referees” e.g. supervisors, Christian sponsors.
  • After this 6-year period personal data for the member may be retained in the Marketing contacts area of the database if express permission has been given.

Any memberships where complaints could be heard by ACC or another counselling register. These include Register members, Counsellor members (overseas), Former Counselling members not on the register, L4 Students, Counselling affiliates, Counselling and Training Affiliates, Pastoral care sole affiliates and any other memberships where complaints could be heard.

  • On cessation of membership (including termination) all information will be kept indefinitely.
  • This will include personal data for Designated Contacts for Affiliate Members and personal data of “Members Referees” i.e. supervisors, Christian sponsors.
  • For register and counsellor members this will also include information gathered as part of Practice Review and Accreditation processes. Whilst any of these processes are on-going, all submitted information will be retained and upon conclusion a summary will be kept indefinitely.
Membership group Membership type Data retention in years
Counselling members Registered counsellor (all types) Indefinite
Counselling organisational member Indefinite
Counselling training organisational member Indefinite
Counselling and training organisational member Indefinite
Student members Student counsellor member L2/L3 6
Student counsellor member L4+ Indefinite
Pastoral care members Pastoral care individual member 6
Pastoral care organisational member 6
Friend Friend 6
Fellow/honorary fellow Fellow/honorary fellow 6

e). Complaints

ACC keeps information for each complaint in line with the then current complaints policy. The complaints policy will follow these principles:

  1. Have a clear statement for the parties and any participants, about what will be held and retained in each stage of the complaint
    process.
  2. A separation of information held about a member in relation to any information that emerges from challenge/s from the courts or
    aggrieved clients.

What is held in the short and longer term. In the short term all records of the investigation and proceedings can

“All records will be held for a period of two years only, except for a summary of the complaint and the decision of the Panel. Complaints upheld against a member/registrant and related sanctions will be published on the website and notified to other appropriate agencies.

Complaint records will include all information gathered and recorded as part of the complaint process from:

  • the complainant
  • the member (individual or organization) against whom the complaint has been made and their representatives,
  • witnesses who have provided information / statements,
  • reports provided by investigators,
  • records of panel meetings

All complaint records will be kept separate from the membership record, but dates and the sanction awarded will be recorded on the electronic record. Any complaints regarding staff and volunteers of ACC will be kept in accordance with employment law or any other legislation that governs this area and will be removed in accordance with these procedures.

f). Members of other bodies in receipt of sanctions from a complaint hearing

A protocol agreed by holders of PSA Accredited Registers means that certain sanctions imposed and removal the Register following a complaint process will be shared with all other PSA Accredited Register holders. This information will be kept indefinitely or until notified by the original provider that it should be deleted.

g). Personnel and service providers’ records

This lists the timescales that ACC would keep personal/sensitive employment information and recruitment records for employees and other individual service providers contracted to ACC (i.e. trainers, assessors, complaint panel members and investigators)

  • Retention of employment records will conform to employment legislation.
  • On termination of employment all records will be kept for 12 months from termination, after this time only the following information may be kept: name, known address, employment dates to and from, No of Sick days in the 12 months prior to termination, dates of and any disciplinary action taken, NI number for payroll purposes only, final salary details, job title on termination. All information will be destroyed after six years from which employment ceased.
  • If there has been a dispute e.g. tribunal claim or complaint, between the ex-employee and ACC within the 12 months after termination the personnel record will be kept for two years after the procedures of the dispute have been completed.
  • Recruitment records for those that are unsuccessful will be kept for 1 year after the post has been advertised after this time all records will be securely destroyed by confidential waste.

Service providers

  • Information will be retained for 6 years after the last service provision.

 

h). Marketing contacts

This lists the timescales that ACC would keep information for all marketing contacts that are kept on the database, on the cloud-based storage system, personal computers off site, and what information will be removed after the following timescales.

  • All marketing contacts will be given the option to opt out of any direct marketing.
  • Once they have opted out their record will be removed within 10 working days. However, data will be retained in-line with the retention policy of any of the items listed above if applicable to the marketing contact.
  • If the contact has not opted out, then information will be kept indefinitely.

 

i). Financial accounts

This lists the timescales that ACC would keep information for all financial accounts and what information will be removed after the following timescales.

  • All financial transaction information is kept for 6 complete financial years after the year in which the transaction occurred in accordance with HMRC requirements.
  • Gift Aid information will be for 6 years after the most recent donation.
  • After this time, all paper records will be disposed of securely.
  • All computer records will be securely archived after this time, as per the software requirements.

 

j). Offsite data storage

This lists the timescales for the removal of information that is kept by service providers working on behalf of ACC (i.e. as assessors, complaint investigators, complaint panel members), who may keep data on personal devices or in non-ACC email addresses that are not accessible to ACC.

  • Any data that has personal or sensitive information must be stored securely.
  • Any data that has personal information must be accurate and only used for the purpose of the service being provided.
  • Once the service being provided has come to its conclusion all data and information must be removed from personal devices or emails. Data and information that should be retained by ACC in line with its processes should be transferred to an ACC SharePoint site.