Data Retention Policy

March 2026

Notice

Parliament recently passed the Data (Use and Access) Act 2025 (DUAA), which amends UK GDPR and the Data Protection Act 2018.

Information contained in this policy may not be up-to-date as we analyse the changes made by DUAA.

For further information on the changes made by DUAA, please click the link below:

Read more about the Data (Use and Access) Act on the Information Commissioner’s Office website. >

Purpose

This is the Data Retention Policy of 1st St Helens (YMCA) Scout Group. This includes all operations for which the Trustee Board is directly responsible.

The purpose of this policy is to specify 1st St Helens (YMCA) Scout Group’s guidelines for retaining different types of data and for how long.

Scope

This policy covers all data in the possession or control of 1st St Helens (YMCA) Scout Group regardless of the medium in which the data is held. Where statute or regulation departs from the requirements of this policy, 1st St Helens (YMCA) Scout Group will comply with the relevant statute or regulation. This policy may be updated from time to time.

Personal Data

Personal data retention is governed by current Data Protection legislation. These data must be kept accurate, up to date and retained for no longer than is necessary for the purpose for which they were obtained. Detail of retention periods can be found in Annex A – Retention periods.

Lawful Purpose for Processing

Where personal data is processed using the lawful basis of legitimate interest or consent, the data subject has a number of rights that they can exercise over this data, such as delete or rectify. Communications with these data subjects will need to clearly sign post them to their ability to withdraw this consent or challenge the legitimate interest that has been assessed, this is commonly known as ‘opt out’. Where appropriate the data subject should be informed every 2 years of the consent or legitimate interest being used to process their data with an option to update this preference. A formal retention period for data processing based on consent has not been defined in this policy and is assumed as permanent until the data subject exercises their rights to cease the processing activity.

Examples of processing covered by this statement are subscribers to newsletters, photograph consents and marketing communications.

Annex A – Retention Periods

Young people

Data ProcessData TypeRetentionJustification
Pre-join enquiriesPersonal data1 year after enquiry or until young person joins, whichever is shorterRequired for placing individual on a waiting list for a place
JoiningPersonal and Sensitive date (special category)10 years after a young person leavesRequired for enquiries on membership and to respond to enquiries from HQ or statutory agencies regarding incidents
EventsPersonal and Sensitive date (special category)2 years after a young person leavesRequired for enquiries on the event and responding to incidents
SafeguardingNA – See TSA Safeguarding policyNA – See TSA Safeguarding policyNA – See TSA Safeguarding policy
Incident – No medical interventionPersonal and Sensitive data7 years after incident, or 7 years after individual turns 18 if laterLegal claims raised against the incident
Training recordsPersonal data2 years after the young person leavesRequired for any re-joins to connect them back to their training records
Attendance registerPersonal data18 monthsRequired to complete annual registration review
HQ Youth award registrationsPersonal and Sensitive data (special category including citation)6 months after the award completionTo retain their award registrations for the duration of the eligibility period
HQ Youth award completionsHQ Youth award completionsHQ Youth award completionsTo retain their award registrations for the duration of the eligibility period Historic record of award completions

Adult volunteers

Data ProcessData TypeRetentionJustification
Pre-join enquiriesPersonal data1 year after enquiry or until adult volunteer joins, whichever is shorterRequired for placing individual on a waiting list for a place
JoiningPersonal and Sensitive data (special category)2 Years after the adult volunteer leavesRequired for enquiries on membership
Adult Information FormPersonal and Sensitive data (special category)12 months or until approval checks and “Getting started” training is complete, whichever is shortestRequired to assist in the appointment process
Identity Checking FormPersonal dataUntil ID data has been submitted to DBS and the vetting process is completeRequired to verify that the identity has been checked.
EventsPersonal and Sensitive data (special category)2 years after eventRequired for enquiries on the event and responding to incidents
SafeguardingNA – See TSA Safeguarding policyNA – See TSA Safeguarding policyNA – See TSA Safeguarding policy
Incident – No medical interventionPersonal and Sensitive data7 years after incident, or 7 years after individual turns 18 if laterLegal claims raised against the incident
Training recordsPersonal data2 Years after the young person leavesRequired for any re-joins to connect them back to their training records
Appointments Advisory Committee notesPersonal data18 monthsRequired to review any training needs of adult volunteers
Adult award registrationsPersonal and Sensitive data (special category including citation)6 months after the award completionTo retain their award registrations for the duration of the eligibility period
Adult award completionsPersonal data and Sensitive data (special category including citation)6 months after the award completion HQ will retain the data permanently for basic data; name, county, award, membership number, completion dateTo retain their award registrations for the duration of the eligibility period Historic record of award completions

Parents

Data ProcessData TypeRetentionJustification
Pre-join enquiriesPersonal data1 year after enquiry or until young person joinsRequired for placing young person on a waiting list for a place
JoiningPersonal data2 Years after the young person leavesRequired for enquiries on membership
One off eventsPersonal data2 years after eventRequired for enquiries on the event and responding to incidents
SafeguardingN/A – See TSA Safeguarding PolicyN/A – See TSA Safeguarding PolicyN/A – See TSA Safeguarding Policy
Incident – No medical interventionPersonal data7 years after incident, or 7 years after individual turns 18 if laterLegal claims raised against the incident

Donors’ details

Data ProcessData TypeRetentionJustification
Individual GiversPersonal Data5 years post last donationTo keep an individual informed of their donation and other fundraising campaigns
Gift aid declaration6 years after the end of the year or accounting period that includes the last donationHMRC Tax Audit
Direct debit mandate6 years after the end of the year or accounting period that includes the last Direct DebitAs proof of Direct Debit Instruction (DDI) and to assist in claims against that DDI
PartnershipsPersonal Data3 yearsTo answer queries on the donations and maintain a record of partner donor
Legacy DonorsPersonal DataIn perpetuity.To maintain record of the donation.
Major DonorsPersonal Data5 years post last donation or last positive interaction with Scouts Fundraising Team, whichever is longer.To keep an individual informed of their donation and other fundraising campaigns.
All donations – transaction information (including Gift aid declaration)Personal Data6 years after the end of the year or accounting period.For audit purposes (including HMRC Tax Audit).

END OF POLICY


Policy approval and review

Policy prepared by:Gavin Jones-Verity
Approved by board / management on: March 9 2026
Policy became operational on: March 9 2026
Next review date: July 9 2026 (amendments pursuant to DUAA 2025)

Review history

Version #Date of reviewReviewed by
1.0March 9 2026Trustee Board

Who to contact?

If you have any queries relating to this Data Retention Policy, please contact Gavin Jones-Verity, Group Lead Volunteer. (info@firstymcascout.org.uk)

Subject access requests

If you wish to make a subject access request under UK GDPR, please click on the button below: