Data Deletion Policy

Pagan World seeks to ensure that it retains only data necessary to effectively conduct its
program activities and work in fulfilment of its mission.
The need to retain data varies widely with the type of data and the purpose for which it was
collected. Pagan World strives to ensure that data is only retained for the period
necessary to fulfil the purpose for which it was collected and is fully deleted when no longer
required. This policy sets forth Pagan World’s guidelines on data retention and is to
be consistently applied throughout the organization.
This policy covers all data collected by Pagan World and stored on Pagan World owned or leased systems and media, regardless of location. It applies to both data
collected and held electronically (including photographs, video and audio recordings) and
data that is collected and held as hard copy or paper files. The need to retain certain
information may be mandated by federal or local law, federal regulations and legitimate
business purposes, as well as the EU General Data Protection Regulation (GDPR).
Reasons for Data Retention
Pagan World retains only that data that is necessary to effectively conduct its
program activities, fulfill its mission and comply with applicable laws and regulations.
Reasons for data retention include:
• Providing an ongoing service to the data subject (e.g. sending a newsletter,
publication or ongoing program updates to an individual, ongoing training or
participation in Pagan World’s programs, processing of employee payroll
and other benefits)
• Compliance with applicable laws and regulations associated with financial and
programmatic reporting by Pagan World to its funding agencies and other
• Compliance with applicable labor, tax and immigration laws
• Other regulatory requirements
• Security incident or other investigation
• Intellectual property preservation
• Litigation
Data Duplication
Pagan World seeks to avoid duplication in data storage whenever possible, though
there may be instances in which for programmatic or other business reasons it is necessary
for data to be held in more than one place. This policy applies to all data in Pagan World’s possession, including duplicate copies of data.
Retention Requirements
Pagan World has set the following guidelines for retaining all personal data as
defined in the Institute’s data privacy policy.
• Website visitor data will be retained as long as necessary to provide the service
requested/initiated through the Pagan World website.
• Contributor data will be retained for the year in which the individual has contributed
and then for [Duration] after the date of the last contribution. Financial information
will not be retained longer than is necessary to process a single transaction.
• Event participant data will be retained for the period of the event, including any
follow up activities, such as the distribution of reports, plus a period of [Duration];
• Program participant data (including sign in sheets) will be retained for the duration of
the grant agreement that financed the program plus any additional time required under
the terms of the grant agreement.
• Personal data of subgrantees, subcontractors and vendors will be kept for the duration
of the contract or agreement.
• Employee data will be held for the duration of employment and then [Duration] after
the last day of employment.
• Data associated with employee wages, leave and pension shall be held for the period
of employment plus [Duration], with the exception of pension eligibility and
retirement beneficiary data which shall be kept for [Duration].
• Recruitment data, including interview notes of unsuccessful applicants, will be held
for [Duration] after the closing of the position recruitment process.
• Consultant (both paid and pro bono) data will be held for the duration of the
consulting contract plus [Duration] after the end of the consultancy.
• Board member data will be held for the duration of service on the Board plus for
[Duration] after the end of the member’s term.
• Data associated with tax payments (including payroll, corporate and VAT) will be
held for [Duration].
• Operational data related to program proposals, reporting and program management
will be held for the period required by the [COMPANY NAME] donor, but not more
than [Duration].
Data Destruction
Data destruction ensures that Pagan World manages the data it controls and
processes it in an efficient and responsible manner. When the retention period for the data as
outlined above expires, Pagan World will actively destroy the data covered by this
policy. If an individual believes that there exists a legitimate business reason why certain data
should not be destroyed at the end of a retention period, he or she should identify this data to
his/her supervisor and provide information as to why the data should not be destroyed. Any
exceptions to this data retention policy must be approved by Pagan World’s data
protection offer in consultation with legal counsel. In rare circumstances, a litigation hold
may be issued by legal counsel prohibiting the destruction of certain documents. A litigation
hold remains in effect until released by legal counsel and prohibits the destruction of data
subject to the hold.