Data retention policy

Shiny Planes, Inc. seeks to ensure that it retains only the data necessary to effectively conduct its program activities and work to fulfill its mission.

The need to retain data varies widely with the type of data and the purpose for which it was collected. Shiny Planes, Inc. strives to ensure that data is only kept 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 Shiny Planes, Inc.’s guidelines on data retention and is to be consistently applied throughout the organization.

Scope

This policy covers all data collected by Shiny Planes, Inc. and stored on Shiny Planes, Inc. 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 stored as hard copy or paper files. The

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

Shiny Planes, Inc. retains only the 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 ongoing service to the data subject (e.g., sending a newsletter, publication, or ongoing program updates to an individual, ongoing training or participation in Shiny Planes, Inc.’s programs, processing of employee payroll and other benefits)
  • Compliance with applicable laws and regulations associated with financial and programmatic reporting by Shiny Planes, Inc. 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
  • Litigation

Data Duplication

Shiny Planes, Inc. seeks to avoid duplication in data storage whenever possible. However, 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 Shiny Planes, Inc.’s possession, including duplicate copies of data.

Retention Requirements

Shiny Planes, Inc. 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 Shiny Planes, Inc. website.
  • Contributor data will be retained for the year in which the individual has contributed and then for five years 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 five years; • 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.
  • Employee data will be held for the duration of employment and then five years after the last day of employment.
  • Data associated with employee wages, leave, and pension shall be held for the period of employment plus five years, with the exception of pension eligibility and retirement beneficiary data which shall be kept for five years.
  • Recruitment data, including interview notes of unsuccessful applicants, will be held for five years 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 five years after the end of the consultancy.
  • Board member data will be held for the duration of service on the Board plus for five years after the end of the member’s term.
  • Data associated with tax payments (including payroll, corporate, and VAT) will be held for five years.
  • Operational data related to program proposals, reporting, and program management will be held for the period required by the Shiny Planes, Inc. donor, but not more than five years.

Data Destruction

Data destruction ensures that Shiny Planes, Inc. manages the data it controls and processes it efficiently and responsibly. When the retention period for the data as outlined above expires, Shiny Planes, Inc. 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, he or she should identify this data to his/her supervisor and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by Shiny Planes, Inc.’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.

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