Data Retention Time is a Piece of String (not cake unfortunately)

Data Retention Time is a Piece of String (not cake unfortunately)

Data Retention Time is a Piece of String (not cake unfortunately)

With Google releasing news this week of new data retention controls for Google Analytics in response to GDPR requirements that mean you can now decide how long you hold your users data for, we thought it might be useful to try and figure out just how long should you be holding data for??!

Googles options for data retention are 14 months, 26 months, 38 months and 50 months, but there are no pointers from them on which option you should be selecting.

The GDPR Act in itself does not set out a specific minimum of maximum data retention period, stating as the fifth data protection principle:

Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

The information commissioners office says that in practice this means your company should take the following steps:

  • review the length of time you keep personal data;
  • consider the purpose or purposes you hold the information for in deciding whether (and for how long) to retain it;
  • securely delete information that is no longer needed for this purpose or these purposes; and
  • update, archive or securely delete information if it goes out of date.

So how long should you be keeping peoples data for? Unfortunately like the old idiom  “How long is a piece of string?” there is no set answer but there are some steps you can take to figuring it out.

Review the personal data you currently keep

Look at the current personal information you currently hold about clients and customers, where it came from, who you share it with and the length of time you keep it for. The types of things you will be looking for here might be:

  1. Contact forms
  2. Subscribers
  3. Registered Customers – Orders, Sales, Billing Info
  4. Referrals
  5. Booking Information (on your website or on third party provider)
  6. Manually Entered data from F2F meeting
  7. Analytics and Cookies from website visitors
  8. Social Media

Once you know what data you are dealing with and where it comes from – you can start to figure out what you are using it for, taking the list above:

 

Contact FormsResponding to enquiries, answering complaints, potential sales, potential bookings, technical questions, potential clients, lead generation
Subscribers * don’t forget that you need to check your subscribers want to stay subscribed! *Newsletters, Promotions and Offers, Important information about changes to company or products etc
Registered CustomersPromotions and Offers, Newsletters, Order Information, Sales Reports, Sales Statistics
ReferralsInitial contact, lead generation
Booking Information (on your website or on third party provider)Ensure availability, not over booking, booking reports, marketing (types of people your accommodation appeals to etc

Manually Entered data from F2F meeting

lead generation, quote, follow up contact
Analytics (Google etc)Marketing, SEO
Social MediaLead generation, enquiries, marketing, seo, promotions and offers

 

Once you have an idea of what data you hold and what you do with the data, look at how long you currently hold the different types of data for:

 

Type of DataUseTime Kept Currently
Contact Forms

Responding to enquiries, answering complaints, potential sales, potential bookings, technical questions, potential clients, lead generation

Check in your website to see how far back your enquiries go
Subscribers * don’t forget that you need to check your subscribers want to stay subscribed! *

Newsletters, Promotions and Offers, Important information about changes to company or products etc

Until they unsubscribe?
Registered CustomersPromotions and Offers, Newsletters, Order Information, Sales Reports, Sales StatisticsOngoing?
ReferralsInitial contact, lead generationCheck in your website or CRM to see how far back your referrals are stored
Booking Information (on your website or on third party provider)Ensure availability, not over booking, booking reports, marketing (types of people your accommodation appeals to etcUntil the booking is made? Until you make your annual reports?

Manually Entered data from F2F meeting

lead generation, quote, follow up contactCheck in your website or CRM to see how far back your referrals are stored
Analytics (Google etc)Marketing, SEOCurrently data is held by google analytics for “at least 25 months” but people have reported up to 5 years of data
Social MediaLead generation, enquiries, marketing, SEO, promotions and offersLength of Campaign or Promotion? Length of time for responding?

 

Once you have the current length of time the next step is to ask why you keep it for this length of time and if you need to?

 

Type of DataUseTime Kept CurrentlyIs This The Right Amount of Time?
Contact FormsResponding to enquiries, answering complaints, potential sales, potential bookings, technical questions, potential clients, lead generationCheck in your website to see how far back your enquiries goInformation the users supply on contact forms should be kept as long as it takes to respond to the user and resolve the purpose of the enquiry. Think about your companys response rates and how long it generally takes for different types of enquiry to be dealt with
Subscribers * don’t forget that you need to check your subscribers want to stay subscribed! *Newsletters, Promotions and Offers, Important information about changes to company or products etcUntil they unsubscribe?If your subscribers have opted-in in a GDPR compliant way then you can keep there information for as long as they stay subscribed. But you must state clearly what you will use there information for.

Registered Customers

Promotions and Offers, Newsletters, Order Information, Sales Reports, Sales StatisticsOngoing?Do you hold information for customers that last purchased from your website in 2007? Do you need to? It could be likely they don’t even have the same information – and you are no longer allowed to keep incorrect information.

Referrals

Initial contact, lead generationCheck in your website or linked CRM to see how far back your referrals are storedThink about how long your company usually takes to here back from somebody? If you hold lead information for people from 2 years ago and you have never heard from them since initial contact and follow up – is it worth while holding onto their data?

Booking Information (on your website or on third party provider)

Ensure availability, not over booking, booking reports, marketing (types of people your accommodation appeals to etc

Until the booking is made? Until you make your annual reports?

It seems at least likely that you will store booking information up until the booking has passed – if you also use your booking information for annual reports and marketing analysis – this is fine but you have to let users know this – it might be that you make reports seasonally or annually whichever suits your business needs most – but do you really need the information from the family that booked in for 2 nights 10 years ago? It’s unlikely.

Manually Entered data from F2F meeting

lead generation, quote, follow up contactCheck in your website or CRM to see how far back your referrals are storedThink about how long your company usually takes to here back from somebody? If you hold lead information for people from 2 years ago and you have never heard from them since initial contact and follow up – is it worth while holding onto their data?
Analytics (Google etc)Marketing, SEOCurrently data is held by google analytics for “at least 25 months” but people have reported up to 5 years of dataIf you use Google Analytics for monthly reporting and use these figures frequently then you need to decide how long you need comparative data for –

If you analytics for tracking campaigns, how often do you run these campaigns – do you need to be able to compare new campaigns to previous campaigns?

Social MediaLead generation, enquiries, marketing, SEO, promotions and offersLength of Campaign or Promotion? Length of time for responding?Think about how long your company usually takes to here back from somebody? If you hold lead information for people from 2 years ago and you have never heard from them since initial contact and follow up – is it worth while holding onto their data?

 

Once you get to this stage, you are ready for the final column:

New Amount of Time and Why?

 

You can grab a sample blank form here

For this final column, it’s ok if the new amount of time is the same as the old amount of time as long as you have a reasonable explanation for why you are holding it for this long.

Once you have completed this analysis, update your privacy policy to reflect the information in the table – this lets people know clearly what you are doing with their data, how long you will store it for and why you will store if for that long.

Next delete the out of date and incorrect information that you hold for people.

If you are still unsure of how to deal with your data, get in touch with us and we can offer more individualised advice to your business.

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