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1. Data retention into perpetuity

Schedule 1 to the Public Records Act 1958 defines public records as “records of any office, commission or other body or establishment whatsoever under Her Majesty’s Government in the United Kingdom”. The list of bodies and establishments whose administrative and departmental records are public records includes the Registrar of Consultant Lobbyists. It follows that I have an obligation under the Public Records Act 1958 to identify records which ought to be permanently preserved and to transfer them to the National Archives.

I intend to archive the entire Register (the registration information of all those registered, at end of each calendar year, and the quarterly return information, at the end of each quarter), so it is available to search by interested parties for a period of five calendar years. I will review this period in due course in the light of requests for information received and questions asked, and then consult further if change is proposed. It is my intention that whatever period is finally determined for publication on my website, I will then subsequently transfer the information to the National Archive for permanent preservation.

Information on my website will be removed after 12 months, unless it is in the public interest for it to remain. Any such published information will have the date of next review published on the face of the document. Such information will not be transferred to the National Archive unless it is in the public interest to do so.

Data Protection Act

The Data Protection Act (DPA) controls how personal information is used by organisations, businesses or the Government. The Office of the Registrar of Consultant Lobbyists is registered with the Information Commissioner as a data controller. The DPA definition of “personal data” includes data relating to a living individual who can be identified from the data. This would include names and addresses of registrants and their clients, as well as other information relating to a living person from which they could be identified (such as, depending on the circumstances, a company name and residential address, and details of any convictions under the Act).

Credit card information and banking details are held by partner organisations which process payments on the Registrar’s behalf. Registrants do not have to disclose a personal address (in order to assure their security). Everyone responsible for using data has to follow strict rules called “data protection principles”. They must make sure the information is:

  • used fairly and lawfully
  • used for limited, specifically stated purposes
  • used in a way that is adequate, relevant and not excessive
  • accurate
  • kept for no longer than is absolutely necessary
  • handled according to people’s data protection rights
  • kept safe and secure
  • not transferred

The Office of the Registrar of Consultant Lobbyists subscribes and adheres to these principles. Data obtained pursuant to the Act’s requirements is treated as having been obtained fairly.

In the event that information which is held by the Office is found to be incorrect as a result of the work of the Office, and I consider that erroneous information is detrimental to transparency (anything other than the most minor administrative error), the correction will be published on the Register at the earliest opportunity with the dates during which the information was incorrect. Where the correction covers more than one registrant record, all affected records will be updated, clearly stating that the error was made by the Office.

Guidance will be sought from the Information Commissioner as to whether any breach is reportable.