Data protection guidance for Electoral Registration Officers and Returning Officers

Document retention policy

Maintaining your document retention policy will help you to: 

  • demonstrate that you are complying with the principles of processing personal data 
  • ensure that data is processed lawfully, fairly and in a transparent manner  

Your document retention policy should set out the following for all documents you receive and hold:

  • whether the document contains personal data
  • the lawful basis on which any personal data was collected 
  • your retention period
  • your rationale for the retention period (which might relate to a requirement in electoral law, for example, home address forms at UK Parliamentary elections must be destroyed after 21 days)

In some cases, maintaining your document retention policy will be straightforward as electoral legislation will require a set period for which documents are retained. For example, at a UK Parliamentary election, specific documents relating to the election must be retained for one year1 and then, unless otherwise directed, be destroyed. 

In other cases, you will need to make a local decision and justify this in your document retention policy.
If you are an ERO, your document retention policy will include (but will not be limited to) how you process and store documents received due to:

  • an application to register (i.e. application form and any documentary evidence where required) 
  • an application for an absent vote 
  • your inspection of council records or your power to require information from any other person for the purposes of maintaining the register
  • a request to an applicant/elector for further information to help you determine if they are resident 
  • your power to require evidence as to age or nationality 

For further information, refer to the relevant section on Access and Supply in our guidance for EROs. 

Our guidance for ROs for each election type contains specific advice on the retention of election documents

Your retention plan should reflect your approach to the retention of all documents. For example, storage and retention of nomination papers and home address forms may differ for each election type. 

You will also need to consider your document retention policy for:

  • notices published for the election 
  • staff records, including appointment and payment records
Last updated: 20 March 2023