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Data Retention Policy

Updated: 23rd, July, 2023

Mooyi is committed to retaining solely the data indispensable to the effective execution of its program activities and the fulfilment of its mission. The requirement for data retention varies significantly based on the nature of the data and the specific purpose for which it was collated. Mooyi endeavours to ensure that data is retained exclusively for the duration necessary to accomplish the intended purpose and is comprehensively eradicated when it ceases to be requisite. The following policy delineates Mooyi's guidelines concerning data retention and is intended to be applied uniformly across the organisation.

Scope

This policy pertains to all data collected by Mooyi and retained on systems and media owned or leased by Mooyi, irrespective of the geographical location. It is applicable to data held in electronic format—including photographs, video, and audio recordings—as well as data maintained as hard copies or paper files. The necessity to preserve specific information may be stipulated by federal or local laws, federal regulations, legitimate business purposes, in addition to obligations arising from the European Union's General Data Protection Regulation (GDPR) and The Nigerian Data Protection Regulation.

Reasons for Data Retention

TMooyi retains only that data that is necessary to effectively conduct its program activities, fulfil its mission and comply with applicable laws and regulations.

Reasons for data retention include:

  • Providing an ongoing service to the data subject (for instance but not limited to sending a newsletter, publication or ongoing program update to an individual, ongoing training or participation in Mooyi’s programs, processing of employee payroll and other benefits)
  • Compliance with applicable laws and regulations associated with financial and programmatic reporting by Mooyi to its funding agencies and other donors
  • Compliance with applicable labour, tax and immigration laws
  • Other regulatory requirements
  • Security incident or other investigation
  • Intellectual property preservation
  • Litigation

Data Duplication

Mooyi 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, Mooyi’s possession, including duplicate copies of data.

Retention Requirements

Mooyi 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 tContributor data will be retained for the year in which the individual has contributed and then for 5 years 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 5 years;
  • 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 7 years after the last day of employment.
  • Data associated with employee wages, leave and pension shall be held for the period of employment plus 7 years, with the exception of pension eligibility and retirement beneficiary data which shall be kept for 3 years.
  • Recruitment data, including interview notes of unsuccessful applicants, will be held. for 2 years 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 3 years after the end of the consultancy
  • Board member data will be held for the duration of service on the Board plus for 10 years after the end of the member’s term.
  • Data associated with tax payments (including payroll, corporate and VAT) will be held for 7 years
  • Operational data related to program proposals, reporting and program management will be held for the period required by Mooyi donors, but not more than 3 years.

Data Destruction

Data destruction ensures that Mooyi 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, Mooyi 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 Mooyi’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.

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