Surely this is a matter of balance and risk? A Trust cannot, in a privacy notice/policy, list all the retention periods for the information it keeps - well, it can, but it would be an administrative burden of Jim Hacker proprtions. This is why there is a retention schedule and it's publicly available and it contains all this information.
What you can do is refer to the "list" and perhaps extract that list so it is a little easier to read, and maybe index it (or explain the CTRL-F function available on web pages). Why not provide the document in a webpage and provide the user with a search box, so they can home in on whatever they wish?
It's not about obfuscating, it's about providing the information and explaining why it is what it is and, if necessary, providing a means for a person to ask a question directly "Dear DPO, how long do you keep maternity records for?", in an efficient manner.
You could also generalise (not without risk), so "Group A containing records X, Y, Z and Q are kept for a maximum of 7 years from date of last treatment".
Depends how much work you want to make for yourself versus the risk of being open but verbose.
Simon Howarth
-----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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