Self-Build Register - retention of entries

2022-01-07T13:09:51Z

Wondering if any other authorities have proposed removing entries from their self-build registers after a certain period of time? Other than where people have specifically requested to be removed from the register (ie. simply no longer wish to be on it or have since found a plot within the authority area or elsewhere), and thus are no longer regarded as live entries but are obviously still recorded for the base period they registered, we've not so far removed any other entries (other than data cleansing to deal with duplicate and updated entries evidently from the same people to avoid double-counting). However, we've been wondering if a 4 year timeframe for retention might be appropriate, particularly given GDPR considerations around not retaining people on Council records indefinitely and unnecessarily? Given the requirement to have permitted sufficient potential plot opportunities within 3 years of the end of the base period (and providing the LA has met that requirement), then is there much point in retaining people on the register for more than 4 years? Would it be reasonable to therefore routinely/automatically remove older entries (from more than 4 base periods ago) and require people to then re-register if they wish to continue to be on the register, which would help to ensure those who remain on the register do still indeed need to be on it in terms of having an interest in potentially finding a plot in the area, or should everyone be simply retained for the purposes of ongoing cumulative monitoring?

The Right to Build Task Force guidance note PG9 does provide some advice on removal of registrations, including in para.59 that "Work can be undertaken to remove the details of the individuals from the Registers (in accordance with GDPR), but the duties under the legislation are not removed even where the details of an individual on the Register are removed". PG13 also includes in their suggested summary tables a field for 'Date Left Register'. So can older entries reasonably be removed as live register entries while still retaining them for statistical/numerical purposes for the base period in which they registered? Indeed, there doesn't actually seem to be a legislative requirement to maintain a cumulative register from April 2016 (start of the first base period) onwards.

Any thoughts appreciated!