Data Retention Policy

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Data Retention Policy

EDIBLE CUTLERY PTY LTD 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 have data varies widely with the type of data and the purpose for which it was collected. EDIBLE CUTLERY PTY LTD strives to ensure that data is only retained for the period necessary to fulfill the purpose for which it was collected and is entirely deleted when no longer required. This policy sets forth EDIBLE CUTLERY PTY LTD’s guidelines on data retention and is to be consistently applied throughout the organization. 

Scope 

This policy covers all data collected by EDIBLE CUTLERY PTY LTD and stored on EDIBLE CUTLERY PTY LTD owned or leased systems and media, regardless of location. It applies to data collected and held electronically (including photographs, video and audio recordings) and data collected and stored 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, and the EU General Data Protection Regulation (GDPR). 

Reasons for Data Retention 

EDIBLE CUTLERY PTY LTD retains only the data necessary to effectively conduct its program activities, fulfill its mission and comply with applicable laws and regulations. Reasons for data retention include:

  • Providing ongoing service to the data subject (e.g. sending a newsletter, publication or ongoing program updates to an individual, ongoing training or participation in EDIBLE CUTLERY PTY LTD’s programs, processing of employee payroll and other benefits) 
  • Compliance with applicable laws and regulations associated with financial and programmatic reporting by EDIBLE CUTLERY PTY LTD to its funding agencies and other donors 
  • Compliance with applicable labour, tax and immigration laws • Other regulatory requirements 
  • Security incident or other investigation 
  • Intellectual property preservation 
  • Litigation

Data Duplication

EDIBLE CUTLERY PTY LTD seeks to avoid duplication in data storage whenever possible, though there may be instances in which, for programmatic or other business reasons, data must be held in more than one place. This policy applies to all data in EDIBLE CUTLERY PTY LTD’s possession, including duplicate copies of data. 

Retention Requirements

EDIBLE CUTLERY PTY LTD has set the following guidelines for retaining all personal data as defined in the Institute’s data privacy policy.

  • Website visitor data will be retained as long as necessary to provide the service requested/initiated through the EDIBLE CUTLERY PTY LTD website. 
  • Contributor data will be retained for the year in which the individual has contributed and then for 30 days after the last contribution date. Financial information will not be retained longer than is necessary to process a single transaction. 
  • Event participant data will be retained for the event, including any follow-up activities, such as the distribution of reports, plus 30 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 sub grantees, subcontractors and vendors will be kept for the duration of the contract or agreement.
  • Employee data will be held for the duration of employment and then 30 days after the last day.
  • Data associated with employee wages, leave and pension shall be held for the period of employment plus 30 days, except pension eligibility and retirement beneficiary data which shall be kept for 30 days. 
  • Recruitment data, including interview notes of unsuccessful applicants, will be held for 30 days after the closing of the position recruitment process. 
  • Consultant (both paid and pro bono) data will be held for the duration of the consulting contract plus 30 days after the end of the consultancy. 
  • Board member data will be held for the duration of service on the Board plus 30 days after the end of the member’s term. 
  • Data associated with tax payments (including payroll, corporate and VAT) will be held for 30 days. 
  • Operational data related to program proposals, reporting and program management will be held for the period required by the EDIBLE CUTLERY PTY LTD donor, but not more than 30 days. 

Data Destruction 

Data destruction ensures that EDIBLE CUTLERY PTY LTD manages the data it controls and processes it efficiently and responsibly. When the retention period for the data as outlined above expires, EDIBLE CUTLERY PTY LTD will actively destroy the data covered by this policy. If an individual believes that there exists a legitimate business reason why specific data should not be destroyed at the end of a retention period, they should identify this data to their supervisor and explain why it should not be destroyed. Any exceptions to this data retention policy must be approved by EDIBLE CUTLERY PTY LTD’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.