storing consultation responses v data protection

2020-11-04T15:00:34Z

Hi, we have recently adopted our new local plan and are using this point in time to pause and do a bit of database management. We have used the consultation portal/ system Objective for all our consultations and have built up a rather unwieldy database of around 8000 public consultees. We have run a simple survey asking if people wish to continue to receive notifications of planning consultations - around 500 people responded positively (statutory consultees were not included in the survey). Objective have then made everyone else 'inactive' so we can ensure they are not contacted again.

I'm just not sure what to do next. We can delete inactive people, but if we do we will lose any previous comments they made. A neighbouring authority have archived an anonymized report collating all comments received and then they have deleted all the personal data from their database. However, we have thousands of comments for each consultation and this will be a huge task in itself. So, I have two questions which I'd really appreciate your thoughts on:

1) Is there a requirement to keep original comments received during the plan making process once the local plan is adopted, keeping in mind that we have consultation statements which summarize the comments received for each consultation?

2) If there is a requirement does this mean we can keep the personal details of respondents with their comments, even when they have not opted in to remain on the database?

Any thoughts or feedback on what other authorities have done would be really appreciated,

Liz