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The Registrar recently consulted on refreshing guidance about information publication and retention. Eight responses were received which are very much appreciated, and have helped to further inform the Registrar’s thinking on this important issue.
The Registrar is publishing new guidance today which encompasses the following changes in approach:
Archive of Register – to retain archived copies of the Register on the website for five years, after which time copies will be transferred to the National Archive.
Website information – to remove all information older than 12 months from the News section (and then delete it), and to retain official publications (such as the business plan and statement of accounts) in the Publications section for five years (this latter period has been increased in response to consultation feedback).
Periods of data inaccuracy – the date of any substantive changes will be recorded on the face of the Register. All notes will be removed at the next point the Register is archived (after 12 months have elapsed, the following 1 January each year).
Publication of registration information – in the event that a registrant ceases the business of consultant lobbying, that organisation will be removed from the Register at the next point the Register is archived, after 12 months have elapsed (so on 1 January each year, those organisations that have not conducted the business of consultant lobbying for more than 12 months will be removed).
In the event that that registrant subsequently re-joins the Register, the dates of previous registration(s) will be noted on the record.
Publication of quarterly updates of client information – client information or nil returns will be published on the face of the current Register for three years from the date the information was first published or when the registrant ceased the business of consultant lobbying, whichever is the latest. All quarterly return information will continue to be available for the same five year period that the Register is available, in the archived information.
Offences – to remove information about civil penalty notices from the Register at the next point the Register is archived, after 12 months have elapsed from the point at which the fine was paid ( on 1 January each year). Information will continue to be retained in the archived Registers and Statements of Accounts. This point was the one which generated most disagreement in consultation responses, but this is considered to be a proportionate and balanced position.
Information regarding criminal convictions would be retained until the conviction is regarded as “spent”.
There will be a requirement for a further update regarding data protection early next year to take account of the requirements of the General Data Protection Regulation.
A copy of the guidance on information publication and retention can be found here.