Data Retention Policy and Privacy Notice

Charity No SC035087


  1. Church of Scotland congregations gather personal information from individuals and external organisations as well as generating a wide range of personal data, all of which is recorded in documents and records, both in hard copy and electronic form.
  2. Examples of the types of information accumulated and generated are set out in Appendix 1 of this policy and include but are not limited to minutes of Kirk Session meetings; membership rolls; baptismal information; employment records; newsletters and other communications such as letters and emails.
  3. In certain circumstances it will be necessary to retain documents to meet legal requirements and for operational needs.  Document retention is also required to evidence agreements or events and to preserve information.
  4. It is however not practical or appropriate for congregations to retain all records.  Additionally, data protection principles require information to be as up to date and accurate as possible.  It is therefore important that congregations have in place systems for the timely and secure disposal of documents that are no longer required.
  5. This Data Retention Policy was adopted by the Congregation on 15 May 2019 and will be implemented on a day to day basis.

Roles and Responsibilities

  1.  Congregational office bearers and those involved with safeguarding will adopt the retention and disposal guidance at Appendix 1 of this policy and strive to keep records up to date.
  2. Advice will be obtained from the Law Department or Safeguarding Department of the Church Office at 121 George Street if there is uncertainty about retention periods.

Retention and Disposal Policy

  1. Decisions relating to the retention and disposal of data should be guided by:-
    •  Appendix 1 – Document Retention Schedule – Guidance on the recommended and statutory minimum retention periods for specific types of documents and records.
  2. In circumstances where the retention period for a specific document or category   of documents has expired, a review should be carried out prior to disposal and consideration should be given to the method of disposal.


  1.  Documents containing confidential or personal information should be disposed of either by shredding or by using confidential waste bins or sacks.  Such documentation is likely to include financial details, contact lists with names and addresses and pastoral information.
  2. Documents other than those containing confidential or personal information may be disposed of by recycling or binning.
  3. Electronic communications including email, Facebook pages, twitter accounts etc and all information stored digitally should also be reviewed and if no longer required, closed and/or deleted so as to be put beyond use. This should not be done simply by archiving, which is not the same as deletion.  It will often be sufficient simply to delete the information, with no intention of ever using or accessing it again, despite the fact that it may still exist in the electronic ether. Information will be deemed to be put beyond use if the Congregation is not able, or will not attempt, to use it to inform any decision in respect of any individual or in a manner that affects the individual in any way and does not give any other organisation access to it.
  4. Deletion can also be effected by using one of the following methods of disposal:-
    • Using secure deletion software which can overwrite data;
    • Using the function of “restore to factory settings” (where information is not stored in a removable format);
    • Sending the device to a specialist who will securely delete the data.

Appendix 1

Data Retention Schedule

This Schedule is provided as a guide to common types of documents but is not exhaustive. 

Minutes of meetings 6 years
Kirk Session meetings 50 years – permanent. After 50 years pass the minutes to the principal clerk’s office, who then liaise with the National Records of Scotland for archiving.   
Pre-employment enquiries / applications / notes / letters / references 6 months after completion of recruitment  (unless data to be retained for a future similar opportunity, in which case 1 year)  
Safeguarding – Service confirmation of advice, emails, letters 100 years
Safeguarding – Confidentiality Agreements 100 years
Safeguarding – Covenants of Responsibility (managing those who pose a risk) 100 years
Safeguarding – Risk Assessments 100 years
Safeguarding – Complaints concerning people 100 years
Safeguarding – Audit for Congregations and Presbyteries 100 years
Congregational Roll 100 years
Certificates of Transference / Lines 100 years
Employee / appointments records including: contracts, time records etc Duration of employment + 7 years
Volunteer records Duration of placement + 7 years
Databases for mailing lists / distribution Reviewed annually, delete out of date information
Miscellaneous contact information Delete once there is no longer a requirement to hold such information
Arranged accommodation/placements (e.g. overseas visitors) 3 years following end of event/placement
Documents relating to litigation or potential litigation Until matter is concluded plus 7 years
Hazardous material exposures 30 years
Injury and Illness Incident Reports (RIDDOR) 5 years
Pension plans and retirement records Permanent
Salary schedules; ranges for each job description 2 years
Payroll Records Minimum, 7 years.  No maximum
Contracts 7 years following expiration
Construction documents Permanent
Fixed Asset Records Permanent
Application for charitable and/or tax-exempt status Permanent
Sales and purchase records 5 years
Resolutions Permanent
Audit and review workpapers 5 years from the end of the period in which the audit or review was concluded
OSCR filings 5 years from date of filing
Records of financial donations 7 years
Accounts Payable and Receivables ledgers and schedules 7 years
Annual audit reports and financial statements Permanent
Annual plans and budgets 2 years
Bank statements, cancelled cheques, deposit slips Minimum of 7 years
Business expense records 7 years
Cash/cheque receipts 7 years
Electronic fund transfer documents 7 years
Employee expense reports 7 years
General ledgers Permanent
Journal entries 7 years
Invoices 7 years
Petty cash vouchers 7 years
Tax records Minimum 7 years
Filings of fees paid to professionals 7 years
Environmental studies Permanent
Insurance claims/ applications Permanent
Insurance disbursements and denials Permanent
Insurance contracts and policies (Directors and Officers, General Liability, Property, Workers’ Compensation) Permanent
Leases 7 years after expiration
Property / buildings documentation (including loan and mortgage contracts, title deeds) Permanent
Warranties Duration of warranty + 7 years
Records relating to potential, or actual, legal proceedings Conclusion of any tribunal or litigation proceedings + 7 years



 Charity No SC035087

Purpose of this Notice: This Privacy Notice outlines the way in which the Congregation will use personal information provided to us.  Personal information includes any information that identifies you personally, such as your name, address, email address or telephone number.

The Congregation recognises the importance of your privacy and personal information, and we have therefore outlined below how we use, disclose, and protect this information. The Congregation, jointly with the Presbytery of Lothian & Borders is the data controller, because we decide how your data are processed and for what purpose.  Contact details for us are provided below.

 How we use information:  We use the information you give to us:

  • to administer membership records, including a Communion Roll and Supplementary Roll;
  • for pastoral care purposes;
  • in relation to participation in Congregational activities;
  • to provide you with information about news, events, and activities within the Congregation or the wider Church of Scotland;
  • to provide the services of a parish church to the local community;
  • to fulfil contractual or other legal obligations;
  • to manage our employees;
  • to further our charitable aims, for example through fundraising activities;
  • to maintain our accounts and records (including the processing of Gift Aid applications);
  • if CCTV is in place, we have this for the prevention and detection of crime.

Disclosure of information: The Congregation will only share your personal information where this is necessary for the purposes set out above. Information will not be shared with any third party out with the Church of Scotland without your consent unless we are obliged or permitted to do so by law.

Basis for processing personal information: The Congregation processes your information in the course of its legitimate activities, with appropriate safeguards in place, as a not-for-profit body with a religious aim and on the basis that our processing relates solely to members, former members or people who have regular contact with us, and that this information is not disclosed to any third party without your consent.

We also process information where this is necessary for compliance with our legal obligations; where processing is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests or fundamental rights and freedoms; and where you have given consent to the processing of your information for a particular purpose. 

Storage and security of personal information: The Congregation will strive to ensure that personal information is accurate and held in a secure and confidential environment.  We will keep your personal information for as long as you are a member or adherent or have regular contact with us or so long as we are obliged to keep it by law or may need it in order to respond to any questions or complaints or to show that we treated you fairly.   We may also keep it for statistical purposes but if so, we will only use it for that purpose.  When the information is no longer needed it will be securely destroyed or permanently rendered anonymous. Further information about our data retention policy is available from the church office.

Getting a copy of your personal information: You can request details of the personal information which the Congregation holds about you by contacting us using the contact details given below.  

Inaccuracies and Objections: If you believe that any information the Congregation holds about you is incorrect or incomplete or if you do not wish your personal information to be held or used by us, please let us know.  Any information found to be incorrect will be corrected as quickly as possible.

You have the right to object to our use of your personal information, or to ask us to remove or stop using your personal information if there is no need for us to keep it.  There may be legal or other reasons why we need to keep or use your data, but please tell us if you think that we should not be using it.

If we are processing your data on the basis of your explicit consent, you can withdraw your consent at any time.  Please contact us if you want to do so.

Contact us: You can contact us by getting in touch with Mabel Currie, Session Clerk,at or via the church office.

How to complain: You have the right to complain to the Information Commissioner’s Office about anything relating to the processing of your personal information by the Congregation.  You can contact the ICO via its website at or at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.