VOGs and coach screening after the end of a volunteer role
More and more sports associations request a VOG (Verklaring Omtrent Gedrag, certificate of good conduct) from coaches, supervisors and board members working with vulnerable groups. Good policy, but what do you do with the paper document when the coach stops? Keep it forever, just in case? Throw it straight into the recycling? The right route lies between those two extremes. This article sets it out for boards and confidential contact persons.
What is a VOG exactly?
The VOG is issued by Justis and confirms that a person has no relevant criminal record for a specific purpose (in sport usually screening profiles around working with minors). The document itself contains personal data: name, date of birth and sometimes place of birth, plus an issue date and certificate number. Under GDPR art. 10 (data of a criminal nature) it falls under a strict basis.
Retention period: short
A commonly used guideline at volunteer organisations is that the paper VOG document is no longer needed relatively shortly after the start of the role. A common approach in practice:
- You receive and check the VOG at the start of the role.
- You record in the personal file that a VOG has been checked, with date and certificate number.
- The physical document does not need to remain after that registration; a period of a few weeks up to a reasonable administrative duration after verification is common.
- After that you destroy the original document in line with the GDPR.
The idea: you have evidence of the check (the registration), but you do not keep a document with personal data and criminal-record status on file longer than needed. Consult your sport federation's or NOC*NSF's guidance for the exact period that fits your arrangement.
A VOG registration in the file is enough evidence. Keeping the paper document until retirement is not diligence but a breach of the storage limitation principle.
At end of a volunteer role
When the coach or supervisor stops, the basis for retaining personal data in the coach file expires. You then face three piles of paper:
- VOG registration in the file: the document may already have been destroyed earlier; the registration is retained per policy (often until end of role plus a reasonable period).
- Enrolment forms and personal data: destroy after the relevant period for the member records.
- Any disciplinary files: assess separately; sometimes longer retention because of possible legal trajectories.
Disciplinary files and reports of misconduct
Since the sector set up strong protocols on misconduct, disciplinary files appear more often. These items are extra sensitive by nature: they involve allegations, witness statements and inquiry outcomes. Retention periods are usually set by:
- Your sport federation's rules (KNVB, KNLTB, KNHB, NOC*NSF).
- The Tuchtcommissie or Instituut Sportrechtspraak when engaged.
- The association's own integrity policy.
For these files: do not destroy ad hoc. Agree with the board and the confidential contact person which period applies, and document the choice.
Coach enrolment forms
Alongside the VOG, a coach file often contains:
- Enrolment forms with name, address and contact details.
- Copies of coach licences or certificates.
- Hours records and volunteer expense claims.
- Correspondence about rosters, cancellations, tournaments.
For financial items (expense claims) the seven-year tax period applies. For the rest, a reasonable period after the role ends. See also the GDPR retention periods cheatsheet.
How do you carry out destruction?
Coach files often hold slightly more sensitive items than general member records, precisely because the VOG and any disciplinary items have a criminal-record component. Two practical requirements:
- DIN 66399 P-5 for paper with BSN or criminal references.
- No access by unauthorised persons during transport or storage.
On-site destruction at the clubhouse fits this well. The truck comes by, you can watch the boxes disappear into the hopper, and the certificate is ready before you are back in the board room. No boxes that end up in a board member's car and get forgotten somewhere.
Cleaning up coach files?
On-site document destruction at your club grounds in Amsterdam-Noord and surrounding area. P-5 for paper, certificate immediately after, no transport by volunteers needed.
Request a quoteThe role of the confidential contact person
In many associations the confidential contact person (VCP) is involved in managing VOG registrations and reports. The VCP is not the archivist, but often has visibility on which items are sensitive. Engage this role in your annual cycle: have the VCP co-sign before sensitive items go for destruction.
In short
- Do not keep the physical VOG document longer than strictly necessary; register the check in the file.
- End of volunteer role: walk through the file and separate financial (7 years), general (reasonable period) and disciplinary items (separate rules).
- Use an on-site destruction partner that works in place and issues a certificate.
- Keep certificates in the board folder as evidence of GDPR diligence.
See our industry page Document destruction for sports clubs. Unsure about a specific category in your archive? We are happy to think along, before something goes that needed to stay a little longer.