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Subject:
From:
Tapani Tarvainen <[log in to unmask]>
Reply To:
Tapani Tarvainen <[log in to unmask]>
Date:
Mon, 9 Jul 2018 21:14:36 +0300
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On Mon, Jul 09, 2018 at 12:09:54PM -0400, Stephanie Perrin ([log in to unmask]) wrote:

> As to deleting the records of applicants who were rejected...you do
> need to keep them long enough for individuals to ask for access
> under the GDPR.

Yes.

> Let me get back to you with a proposed retention schedule on that.

Note NCSG Charter 2.7, too (although of course law will override
it in case of conflict).

> I also see no problem in keeping just the name and country, with the
> date of application and reason for rejection, in order to inform
> future committees in the event of persistent application.

I would tend to agree, although that is a bit of a grey area - I don't
know of any precedents. Might be worth asking some DPA.

-- 
Tapani Tarvainen

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