Data Retention Policy
This Data Retention Policy explains how the Peel Professional platform (“we”, “us”, “our”) retains and deletes personal data, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
We apply the UK GDPR's storage limitation principle (Article 5(1)(e)): personal data is kept only for as long as necessary for the purpose for which it was collected. We conduct periodic reviews to ensure compliance.
1. Retention periods
These are the periods the system applies automatically. They are read from the live schedule, so this table is always the current position.
| Information | What it covers | How long we keep it |
|---|---|---|
| Audit and access logs | The audit trail of who did what (sign-ins, record changes, downloads), with IP address and browser, plus file-access and exam-access logs. Kept in the live log, then in the archive, then deleted. | 3 months, then 2465 days in a secure archive (7 years in total) |
| Sign-in attempts | Every sign-in attempt: the username or email typed, IP address and browser. Used to slow down password guessing. | 7 days |
| Closed security alerts | Security alerts (suspicious sign-ins, privilege changes) once resolved or marked a false positive. Open alerts are never removed. | 1 year |
| Request performance logs | One row per page request: address, timing and the signed-in user. Hourly and daily summaries hold no user ids and are kept separately. | 7 days |
| Outgoing email copies | The stored copy of each email the system sent: recipient, subject and content. Unsent mail is never removed. | 30 days |
| In-app notifications | In-app notifications shown under the bell icon, read or unread. | 3 months |
| Data export downloads | The download file produced for a subject access or portability request. The record that the request was made and answered is kept separately. | 7 days |
| Application log files | Diagnostic log files kept on the server (slow queries, performance, audit trail copies, email sending, antivirus, errors). They can name users and IP addresses. The audit log itself is kept in the database under its own period. | 3 months |
| Closed rights requests and complaints | The record of each data protection request or complaint — what was asked, the steps taken and the answer — counted from when it was closed. Open requests are never removed. | 6 years |
| Agreements and consent of closed accounts | Records of the agreements, consents and policy acknowledgements a person gave, counted from the day their account was archived or erased. Kept in full while the account is open. | 7 years |
| Learning records of learners who have left | Everything a learner submitted and everything recorded about it — evidence, answers, exam attempts, feedback, QA, appeals, attendance, diary, pastoral and probation records — counted from the day the learner's account is archived or erased. Due records are listed for an administrator to purge or keep. | 7 years, then reviewed before deletion |
| Backups | Encrypted copies of the whole system, used only to recover from a failure. If a backup is ever restored, every erasure made since is applied again. | Up to 37 days, then deleted automatically (the three most recent verified backups are always kept) |
2. Deletion and anonymisation
Upon expiry of the applicable retention period:
- Personal data is securely deleted from active systems.
- Where data exists in backups that cannot yet be deleted, it is restricted from further processing and deleted when the backup expires.
- Where full deletion is not possible, data is anonymised so that it can no longer identify an individual.
Soft-deleted records (marked as deleted within the system) are treated as deleted for access purposes but may persist in backup storage until the backup retention period expires.
3. Right to erasure
Under UK GDPR Article 17, you may request deletion of your personal data. We respond within one month of receiving your request (extendable by up to two further months for complex requests, and we will tell you if so). You can make a request from your account at /gdpr/requests. Your account is anonymised rather than deleted, so that other people's records are not damaged. Deletion may be refused or deferred where:
- Retention is required by law (for example, educational record-keeping obligations)
- The data is needed to establish, exercise or defend legal claims
- Legitimate interests in security or accountability require retention
To submit a request, contact postmaster@peelprofessional.uk.
4. Legal exceptions
We may retain data beyond the standard periods where required to:
- Comply with a legal obligation under UK law
- Establish, exercise or defend legal claims
- Respond to a regulator or law enforcement request
5. Your rights
Under UK GDPR you have rights to access, rectify, restrict and object to processing, as well as rights to portability and erasure. Complaints may be lodged with the Information Commissioner's Office (ICO) at ico.org.uk.
6. Contact
For questions about this policy or to exercise your rights, contact postmaster@peelprofessional.uk.