Hi David
In the situation you describe, the EU ERDF requirements imposes a different legal basis for processing under GDPR to that to that of the standard HR record.
As you can rely on the fact that you have a legal basis to retain the records due to the legal obligation imposed by the EU, then the conflict can be resolved and it simply become a matter of being transparent with data subjects about the extended retention period.
I hope that is helpful.
Kind regards
Peter
-----Original Message-----
From: The Information and Records Management Society mailing list <[log in to unmask]> On Behalf Of David Jenkins
Sent: 25 June 2018 17:09
To: [log in to unmask]
Subject: Procedures for managing the retention of HR information for external funding bodies (e.g. ERDF)
Dear Colleagues,
I’m attempting to get views on how institutions have balanced the needs of funders with wider data protection requirements.
We have a number of funding streams (the EU’s ERDF stream in particular) that require records of expenditure (particularly staff salaries) to be retained until a specific date (at least 2025 for ERDF funds) which might not correspond to our normal retention periods for staff files.
I am wondering how other institutions have managed to ensure that they retain sufficient HR related information to satisfy the requirements of funders and what processes they have put in place to support this. One approach I have considered is identifying those files belonging to staff funded by a particular funding stream and ensuring these are exempt from routine disposal of files in accordance to the institutional retention schedule.
Have any organisations made decisions over what types of HR information they retain for funders (I am trying to avoid a ‘keep everything’ approach if possible)?
I’d be grateful for replies on or off-list and I’m happy to summarise findings.
Thanks,
David
David Jenkins
Records Manager
Division of Library, Learning and Information Services, University of Leicester, University Road, Leicester, LE1 7RH, UK
t: +44 (0)116 229 7080
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