Why your church needs one
UK GDPR says you mustn’t keep personal information for longer than you need it. The law rarely sets a period, so you have to decide, and be able to explain why.
A written policy makes those decisions once. Volunteers then know what to keep and what to shred, without guessing.
Legal minimums and your own choices
Some periods are set for you. HMRC needs Gift Aid records for 6 years, and charity law needs accounts kept for at least 6 years. Payroll records must be kept for 3 years.
Everything else is your choice, such as how long you keep someone’s details after they leave. The template marks those in square brackets, with a sensible starting point you can change.
Safeguarding records need special care
Never delete safeguarding records to tidy up. Records of concerns and allegations often need keeping for decades, and denominations set their own periods. The Church of England, for example, publishes its own retention schedule.
DBS certificates are different: don’t keep copies at all. Record the details and your decision instead.
How to adopt it
- Add your church’s details in the boxes above.
- Change the periods in square brackets to suit your church.
- Check the safeguarding rows against your denomination’s guidance.
- Add any records the template misses, such as hall bookings or CCTV.
- Ask your trustees or church council to approve it, and write in the date.
- Put the yearly review in the diary.
Mistakes to avoid
- Keeping everything “just in case”. The ICO is clear that this isn’t a good enough reason.
- Shredding Gift Aid forms too soon. If HMRC asks to see a declaration and you can’t find it, you may have to repay the Gift Aid.
- Forgetting email and phones. An old list in someone’s inbox counts too.
- Deleting a whole record when part of it must stay. When someone leaves, you can remove their contact details but keep the Gift Aid records HMRC needs.
Questions churches ask
- How long should a church keep Gift Aid declarations?
- For as long as you claim on them, then for 6 years after the end of the accounting period of the last gift claimed. If HMRC opens an enquiry, keep everything until it’s finished.
- How long should we keep someone’s details after they leave?
- The law doesn’t set a period, so it’s your choice. The template suggests 2 years, which allows for people coming back. Whatever you choose, write it down and stick to it.
- Can someone ask us to delete their Gift Aid records?
- You can refuse to delete records the law requires you to keep, such as the Gift Aid records HMRC needs. Delete their other details, and explain what you’ve kept and why.
- Does a small church need a written retention policy?
- The ICO says small organisations with low-risk records may not need a formal one. Church records reveal people’s faith, so a short written policy is a sensible safeguard.
Read next
- GDPR for churches: a plain-English guide
- DBS checks: what your church can keep
- Church privacy notice template
- Free Gift Aid Declaration Form Template
- Free Gift Aid Sponsorship Form Template
- Free Subject Access Request Template Letter
- Subject Access Request Response Letter Template for Churches
- Free Church GDPR Consent Form Template
- Free Data Breach Log Template for Churches
- Free Volunteer Agreement Template for Churches
- Free Church Volunteer Application Form Template
- Free Church Welcome Card Template
Sources
This template follows official guidance. It isn’t legal or tax advice, so check anything you’re unsure about with HMRC, the ICO or an adviser.
- ICO: Storage limitation
- HMRC: Gift Aid declarations
- HMRC: Small Donations Scheme
- Charities Act 2011, section 131: keeping accounting records
- GOV.UK: Keeping PAYE records
- RIDDOR 2013, regulation 12: keeping records
- GOV.UK: Handling of DBS certificate information
- Church of England: Records and information management
Let the software keep track of what’s due
Church Member Software lists who’s due for removal under your own retention periods, keeps the Gift Aid records HMRC needs and records each review.