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ELEMENT 84, INC.
DATA RETENTION & DESTRUCTION POLICY

Element 84, Inc. (the “Company” or “E84”) seeks to ensure that it retains only data necessary to effectively conduct its program activities and work in fulfillment of its mission through the website, element84.com and related services (“Website”).

The need to retain data varies widely with the type of data and the purpose for which it was collected. E84 strives to ensure that data is only retained for the period necessary to fulfill the purpose for which it was collected and is fully deleted when no longer required. This Policy sets forth the Company’s guidelines on data retention of all information collected by the Company. This Policy is to be read in conjunction with E84’s Privacy Policy and Terms of Use and Cookie Policy.

Scope

This policy covers all data collected by E84 and stored on the Company owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).

Reasons for Data Retention

E84 retains only that data that is necessary to effectively conduct its program activities, fulfill its mission and comply with applicable laws and regulations.

The Company, from time to time, establishes retention or destruction policies or schedules for specific categories of records in order to ensure legal compliance and also to accomplish other objectives such as preserving intellectual property, etc. While minimum retention periods are suggested, the retention of the documents identified in those schedules and of documents not included in the identified categories should be determined by the Head of the Department responsible for the initial collection, primarily by the application of the general guidelines affecting document retention identified above, as well as any other pertinent factors.

Reasons for data retention include:

  • Providing an ongoing service to the data subject
  • Compliance with applicable laws and regulations associated with financial and programmatic reporting by E84 to its funding agencies and other donors.
  • Compliance with applicable labor, tax and immigration laws
  • Other regulatory requirements
  • Security incident or other investigation
  • Intellectual property preservation
  • Litigation

Retention Requirements and Duration 

Website visitor data, including correspondence data, will be retained as long as necessary to provide the service requested/initiated through the Website, and to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements as noted above.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of Your personal data, the purposes for which we process Your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Data Duplication

The Company seeks to avoid duplication in data storage whenever possible, though there may be instances in which it is necessary for data to be held in more than one place, either for programmatic or other business reasons. This policy applies to all data in E84’s possession, including copies of data.

Data Destruction

Data destruction ensures that E84 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, E84 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.

Exceptions

Any exceptions to this data retention policy must be approved by the Company’s Director of Information Security in consultation with legal counsel. In rare circumstances, a litigation hold may be issued by the Company’s 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.

This policy was last updated: August 26, 2024