Keep a complete copy of the promotion rules, entry route, advertising materials and any amendments. The records should identify the promoter, eligibility requirements, opening and closing dates, entry limits, prize details, selection method, judging criteria, restrictions, winner notification process and arrangements for unclaimed prizes. Keep dated versions so it is clear which terms applied at each stage. This article is part of the reference collection published by Harper James.
Maintain an entry log containing the date and time of each entry, the entry channel, any required consent, and the basis on which an entry was accepted or rejected. Do not collect more personal data than the promotion requires. Store entry data securely, restrict access to people administering the promotion, and document the retention period under the organisation's UK GDPR policies.
For a prize draw, record the eligible entry pool, the date and time of the draw, the selection method, the software or process used, and the people present or responsible for checking the result. For a skill-based competition, retain the judging criteria, judges' identities or roles, scores, reasons for decisions and any tie-break process. These records provide evidence that the promotion was administered in accordance with its published rules.
Save copies of winner notifications, requests for proof of eligibility, responses, consent to publicity where relevant, and records of failed contact attempts. Keep delivery records, prize acceptance or refusal, substitutions permitted under the rules, and the date on which each prize was supplied. Complaints and their resolution should also be recorded, together with any changes made to the promotion or its advertising.
Before launch, assign responsibility for the records and set a retention period based on the promotion's legal, regulatory, tax, contractual and data protection requirements. The organisation should record why that period was chosen and securely delete or anonymise information when it ends. Promotions involving a paid element or chance should also be assessed against the applicable gambling legislation, while advertising and published terms should be checked against relevant advertising standards.