DATA RETENTION POLICY
TAleatherworks Handmade seeks to ensure that it retains only data necessary to effectively conduct its program activities and work in fulfilment of its mission.
The need to retain data varies widely with the type of data and the purpose for which it was collected. TAleatherworks Handmade strives to ensure that data is only retained for the period necessary to fulfil the purpose for which it was collected and is fully deleted when no longer required. This policy sets forth TAleatherworks Handmade’s guidelines on data retention and is to be consistently applied throughout the organization.
This policy covers all data collected by TAleatherworks Handmade and stored on TAleatherworks Handmade owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).
Reasons for Data Retention
TAleatherworks Handmade retains only that data that is necessary to effectively conduct its program activities, fulfill its mission and comply with applicable laws and regulations.
Reasons for data retention include:
- Providing an ongoing service to the data subject (e.g. sending a newsletter, publication or ongoing program updates to an individual, ongoing training or participation in TAleatherworks Handmade’s programs, processing of employee payroll and other benefits)
- Compliance with applicable laws and regulations associated with financial and programmatic reporting by TAleatherworks Handmade to its funding agencies and other donors
- Compliance with applicable labor, tax and immigration laws
- Other regulatory requirements
- Security incident or other investigation
- Intellectual property preservation
TAleatherworks Handmade seeks to avoid duplication in data storage whenever possible, though there may be instances in which for programmatic or other business reasons it is necessary for data to be held in more than one place. This policy applies to all data in TAleatherworks Handmade’s possession, including duplicate copies of data.
- Website visitor data will be retained as long as necessary to provide the service requested/initiated through the TAleatherworks Handmade website.
- Contributor data will be retained for the year in which the individual has contributed and then for 14 business days after the date of the last contribution. Financial information will not be retained longer than is necessary to process a single transaction.
- Event participant data will be retained for the period of the event, including any follow up activities, such as the distribution of reports, plus a period of 6 business days;
- Program participant data (including sign in sheets) will be retained for the duration of the grant agreement that financed the program plus any additional time required under the terms of the grant agreement.
- Personal data of subgrantees, subcontractors and vendors will be kept for the duration of the contract or agreement.
- Data associated with tax payments (including payroll, corporate and VAT) will be held for 1 week.
- Operational data related to program proposals, reporting and program management will be held for the period required by the TAleatherworks Handmade donor.
- Data destruction ensures that TAleatherworks Handmade manages the data it controls and processes it in an efficient and responsible manner. When the retention period for the data as outlined above expires, TAleatherworks Handmade will actively destroy the data covered by this policy. If an individual believes that there exists a legitimate business reason why certain data should not be destroyed at the end of a retention period, he or she should identify this data to the webmaster at firstname.lastname@example.org and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by TAleatherworks Handmade’s data protection offer in consultation with legal counsel. In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.
- All data of any illegal accounts stored such as fake bots and hackers will be deleted immediately when discovered and confirmed.