Data Retention Policy

1. Introduction

This Policy sets out the obligations of Reeclaim, a company registered in The United Kingdom under number 08828062. Our postal address is PO Box 68031, London NW4 9JB. Reeclaim regarding retention of personal data collected, held, and processed by Reeclaim in accordance with EU Regulation 2018 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, 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 Reeclaim 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 Reeclaim for delivery of the Reeclaim service, 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.

For further information on other aspects of data protection and compliance with the GDPR, please refer to Reeclaim’s Privacy Policy.

2. 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 Reeclaim 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 Reeclaim, this Policy also aims to improve the speed and efficiency of managing data.

3. Scope

• This Policy applies to all personal data held by Reeclaim and by third-party data processors processing personal data on Reeclaim behalf.
• Personal data, as held by the above is stored in the following ways and in the following locations:
  1. Reeclaim third-party servers provided and hosted by a GDPR Compliant third-party.
  2. Computers permanently located in Reeclaim’s premises in United Kingdom, London
  3. Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with Reeclaim’s Bring Your Own Device (“BYOD”) Policy;

4. Data Subject Rights and Data Integrity

• All personal data held by Reeclaim is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in Reeclaim’s Data Protection Policy.
• Data subjects are kept fully informed of their rights, of what personal data Reeclaim holds about them, how that personal data is used as set out in Reeclaim’s Privacy Policy, and how long Reeclaim will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).
• Data subjects are given control over their personal data held by Reeclaim including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict Reeclaim’s use of their personal data, the right to data portability, and further rights relating to automated decision-making and profiling, as set out in Reeclaim’s Privacy Policy

5. Technical and Organisational Data Security Measures

The following technical measures are in place within Reeclaim to protect the security of personal data. Please refer to Reeclaim’s Privacy Policy for further details:

1. Personal client data is stored on a secure server with limited access;
2. All personal client data transferred internally is transferred via CSV file password protected;
3. If access is required to any personal data, such access is formally requested from the Data Protection Team;
4. All hardcopies of personal data, along with any electronic copies stored on physical media are stored securely;
5. No personal data are transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of Reeclaim or not, without authorisation;
6. Personal client data must be handled with care always and is not left unattended or in plain sight;
7. Computers used to process personal data are always locked before being left unattended;
8. No personal data is stored on any mobile device, whether such device belongs to Reeclaim or otherwise without the formal written approval of the Data Protection Manager and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is necessary;
9. No personal data is transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of Reeclaim where the party in question has agreed to comply fully with Reeclaim’s Data Protection Policy and the GDPR. The data transferred will always be encrypted;
10. All electronic copies of personal data are stored securely using passwords and encryption;
11. All passwords used to access employee work computers are changed regularly;
12. All software is kept up-to-date. Security-related updates are installed as soon as reasonably possible after becoming available;
13. No software may be installed on any Company-owned computer or device without approval; and
14. Where personal client data held by Reeclaim is used for marketing purposes, it shall be the responsibility of the Data Protection Manager to ensure that the appropriate consent is obtained.

The following organisational measures are in place within Reeclaim to protect the security of personal data. Please refer to Reeclaim’s Privacy Policy for further details:

1. All employees and other parties working on behalf of Reeclaim are made fully aware of both their individual responsibilities and Reeclaim’s responsibilities under the GDPR and under Reeclaim’s Privacy Policy;
2. Only employees and other parties working on behalf of Reeclaim that need access to, and use of, personal data to perform their work have access to personal data held by Reeclaim;
3. All employees and other parties working on behalf of Reeclaim handling personal data are appropriately trained to do so;
4. All employees and other parties working on behalf of Reeclaim handling personal data should exercise care and caution when discussing any work relating to personal data always;
5. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
6. The performance of those employees and other parties working on behalf of Reeclaim handling personal data shall be regularly evaluated and reviewed;
7. All employees and other parties working on behalf of Reeclaim handling personal data will be bound by contract to comply with the GDPR and Reeclaim’s Privacy and Data Retention Policies;
8. All agents, contractors, or other parties working on behalf of Reeclaim handling personal data must ensure that all relevant employees are held to the same conditions as those relevant employees of Reeclaim arising out of the GDPR and Reeclaim’s Privacy and Retention Policies;

6. 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 all backups thereof) shall be deleted securely from our Database and server;
• Special category personal data stored electronically (including all backups thereof) shall be deleted securely from our Database and Server.

7. Data Retention

• As stated above, and as required by law, Reeclaim shall not retain any personal data for any longer than is necessary considering 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 considered:
  1. The objectives and requirements of Reeclaim;
  2. The type of personal data in question;
  3. The purpose(s) for which the data in question is collected, held, and processed;
  4. Reeclaim’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 data category, 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 Reeclaim 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.

Types of Data

When a customer leaves and no longer requires use of the Reeclaim website we will retain all site data for a period of 7 years or until we are requested by the customer to delete all data.

8. Roles and Responsibilities

• Reeclaim have a privacy manager called the Reeclaim Data Protection Manager
• The Data Protection Manager shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, Reeclaim’s other Data Protection-related policies (including, but not limited to, its Privacy Policy), and with the GDPR and other applicable data protection legislation.
• Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Manager.

9. Implementation of Policy

This Policy shall be deemed effective as of 25/05/18. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.