We worked with a number of Credit Unions to document detailed retention policies. This was a complex activity as there are a number of significant pieces of legislation that govern data retention in the Credit Union and it was necessary to identify what regulatory requirements attached to each data record. Many Credit Unions have members whose relationship has spanned more than 50 years and who have only recently undertaken projects to digitise those records. It was also necessary to examine whether records could be digitised and held in digital form only and whether there were still records that needed to be kept in paper form. The result is that the Credit Unions have clear documented guidance around their retention policies enabling them to make better informed decisions about their data management procedures.
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Data Protection Programmes are all the rage these days. It’s great to see the compliance conversation moving in this direction. As a Data Protection Officer (DPO), I know the difference between working with a solid data protection programme and working with none and all.