I guess it would depend.
If your schedule is shortish it would make sense to avoid having to rewrite all your privacy notices if you changed the retention schedule
Ours is about 15 pages long so you could easily enough find the data you were after.
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Donald Henderson - CHX
Sent: 20 October 2017 16:04
To: [log in to unmask]
Subject: Re: [data-protection] Retention Transparency under GDPR
Hmm... Our retention schedule is just over 300 pages long and I know of one that runs to more than double that. I'm not sure publishing it would help with transparency!
Donald
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Cartwright, Christine
Sent: 20 October 2017 15:57
To: [log in to unmask]
Subject: Re: [data-protection] Retention Transparency under GDPR
I wonder though if you stated in your PN how long you'd keep the data for, would you not just be repeating your retention schedule? Would it not be simpler to just publish your retention schedule (although I acknowledge that does have inherent dangers of making promises public and then a SAR could unveil excessive record keeping)?
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 20 October 2017 15:38
To: [log in to unmask]
Subject: [data-protection] Retention Transparency under GDPR
There are several new requirements in GDPR relating to retention issues. Prime example Art 13.2 requiring privacy notices to specify "the period for which the personal data will be stored".
Many PN's currently use a vague formula such as, often in the NHS, "shall be either returned or destroyed in line with the NHS Records Management Code of Practice 2016".
Does anyone think this, or similar obfuscation, will be satisfactory or compliant? My view is that it is not. DC should, to be transparent, have the gumption to look it up in the Code and be specific - especially given how obtuse that particular code can be!
Anything less is surely not transparent
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