I agree with Jim that I would see these as either financial records kept
for 7 years or alternatively you could view them as a kind of contract/
agreement and keep them in line with those requirements. I don't see a
data protection conflict here as there is a justifiable need to retain
these records but you could try this on the DP listserv perhaps?
Where they fit depends upon how you operate your retention policy at
your organisation, either way I see 12 months for DD records as being
too short.
Mark
>>> Jim Whitaker <[log in to unmask]> 28/09/04 11:54:16 >>>
Would you not keep records supporting financial transactions for the
six
years after the end of the relevant financial year?
Jim
----------------------------------------------
Jim Whitaker
Head of Information Management and Internal Communications
British Educational Communications and Technology agency
Millburn Hill Road
Science Park Telephone 024 7679 7452
Coventry 024 7641 6994 (Ext 3341)
CV4 7JJ Fax 024 7684 7071
===================================================
-----Original Message-----
From: Phillip Bradshaw [mailto:[log in to unmask]]
Sent: 28 September 2004 11:48
To: [log in to unmask]
Subject: Direct Debit Guarantee Scheme
Has anyone considered or taken into account the provisions of the DDGS
in relation to retention periods - in particular the fact that banks
will on request refund a customer who claims payments have been made
after he 'cancelled' the DD - and this part of the guarantee is
without
time limit.
For example we operate a club where monthly subscriptions are
collected
from members by DD. The member resigns in September 2004 and we stop
collecting.
After 12 months (to comply with Data Protection) we destroy our
records
of the member as 'we no longer need to keep them'. A month later he
writes to his bank and alleges he ceased to be a member in 2000 and
the
bank, as it must, refunds 4 years subscriptions and claims it back
from
us. We no longer have any records to show that this is fraudulent (we
cannot keep the financial records without keeping the personal
details).
Do we keep the records indefinitely or do a risk assessment and just
keep them for a couple of years accepting a potential loss in a
(hopefully) small number of cases ?
If I ever emigrate to Brasil I will claim back 20 years Council Tax
paid
by DD just before I leave !
**********************************************************************
This email and any files transmitted with it are confidential and
intended solely for the use of the individual or entity to whom they
are addressed. If you have received this email in error please notify
the system manager.
This footnote also confirms that this email message has been swept by
MIMEsweeper for the presence of computer viruses.
www.mimesweeper.com
**********************************************************************
This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the IS Help Desk - [log in to unmask]
|