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Internal Policy — Build Your Vision Ltd (BYV People Hub)

Data Retention & Deletion Schedule

  • Last updated 30 October 2026
  • Website: byvpeoplehub.com
  • Policy owner: [name or role · to be confirmed]
  • Next review: [date · to be confirmed]
Contents · 8 sections

1.Purpose

This schedule sets out how long Build Your Vision Ltd ("the Company") retains categories of personal data before secure deletion or anonymisation, in line with the storage limitation principle under UK GDPR. It applies both to data the Company holds as data controller (its own customers, staff, and marketing contacts) and Employee Data it holds as data processor on behalf of People Hub Customers.

The guiding rule: data is kept only as long as there is a genuine business or legal reason to keep it, and is deleted or anonymised promptly once that reason no longer applies.

2.Data Held as Controller (Company's Own Data)

Data category
Prospect / lead data
Examples
Contact details from demo requests, website forms, sales conversations that did not convert
Retention period
[24 months · to be confirmed] from last contact
Basis / trigger
Legitimate interest in following up; deleted if no engagement
Deletion method
Automated purge / manual deletion from CRM
Data category
Customer account & billing data
Examples
Company name, admin contact details, Subscription history, invoices
Retention period
Duration of contract + [6 years · to be confirmed]
Basis / trigger
UK tax and accounting record-keeping (Companies Act / HMRC)
Deletion method
Deletion from billing system after retention period
Data category
Payment data
Examples
Billing address; card data is tokenised via payment processor, not stored directly
Retention period
As above; token retained only while needed for recurring billing
Basis / trigger
Contract performance; PCI-DSS obligations sit with payment processor
Deletion method
Processor-side deletion per their retention rules
Data category
Support & communications records
Examples
Support tickets, emails, call notes with Customer contacts
Retention period
[24 months · to be confirmed] after ticket closure / last contact
Basis / trigger
Legitimate interest in service continuity and dispute resolution
Deletion method
Automated purge from support tooling
Data category
Marketing contact data
Examples
Newsletter subscribers, webinar attendees, event contacts
Retention period
Until opt-out, or [24 months · to be confirmed] of inactivity
Basis / trigger
Consent / legitimate interest, whichever applies
Deletion method
Removal from marketing platform on request or automated purge
Data category
Website analytics / usage data
Examples
Aggregated or pseudonymised site and product usage data
Retention period
[14–26 months · to be confirmed] per analytics tool default, or as configured
Basis / trigger
Legitimate interest in improving the Service
Deletion method
Automatic expiry per analytics tool settings
Data category
Job applicant data (Company's own hiring)
Examples
CVs, interview notes for candidates applying to work at the Company
Retention period
[6 months · to be confirmed] after the recruitment process closes, unless the candidate consents to longer for future roles
Basis / trigger
Legitimate interest in recruitment; limitation period for discrimination claims
Deletion method
Secure deletion from ATS/email
Data category
Company's own staff HR records
Examples
Employment contracts, payroll, performance and disciplinary records
Retention period
Duration of employment + [6 years · to be confirmed]
Basis / trigger
Employment law limitation periods; HMRC/pension record-keeping
Deletion method
Secure deletion or archiving then deletion

3.Employee Data Held as Processor (on behalf of Customers)

The Company processes Employee Data strictly on Customer instruction, per the Data Processing Agreement. The default retention position is as follows, but the Customer, as Controller, may set shorter or longer periods for its own data via account settings or written instruction, subject to Section 5.

Data category
Core employee profile data
Examples
Name, address, contact details, employment details
Retention while Subscription active
Retained while the employee record is active or per Customer's own configured policy
Post-termination
Exported on request within [30 · to be confirmed] days of termination; then deleted within a further [60 · to be confirmed] days
Deletion method
Secure deletion per DPA Clause 8
Data category
Special category / health data
Examples
Medical forms, risk assessments, sickness/absence records
Retention while Subscription active
As above — access restricted to permissioned roles at all times
Post-termination
Same export/deletion window as core data; treated with the same or greater care
Deletion method
Secure deletion, encryption key destruction where applicable
Data category
Leave, absence, and lateness records
Examples
Annual leave balances/history, absence and lateness logs
Retention while Subscription active
Retained for the current and prior [2 · to be confirmed] leave years by default, adjustable by Customer
Post-termination
Included in standard export/deletion window
Deletion method
Secure deletion
Data category
Probation, performance & review records
Examples
Probation review outcomes, one-to-ones, appraisal records
Retention while Subscription active
Retained while the employee record is active
Post-termination
Included in standard export/deletion window
Deletion method
Secure deletion
Data category
Employee relations / disciplinary records
Examples
Case notes, disciplinary and grievance documentation
Retention while Subscription active
Retained per Customer's own policy (commonly employment duration + [6 years · to be confirmed] under UK employment practice)
Post-termination
Included in standard export/deletion window unless Customer requests earlier removal
Deletion method
Secure deletion
Data category
Recruitment pipeline data (Customer's hiring)
Examples
Candidate details in a Customer's recruitment pipeline
Retention while Subscription active
Retained per Customer's own configured recruitment policy
Post-termination
Included in standard export/deletion window
Deletion method
Secure deletion
Data category
Account activity logs
Examples
Login history, audit trail of changes to employee records
Retention while Subscription active
[12 months · to be confirmed] rolling, for security and audit purposes
Post-termination
Deleted per standard post-termination window unless required for a live security investigation
Deletion method
Automated purge / secure deletion

4.Backups

Backups may retain deleted data for a limited period after deletion from live systems, for disaster recovery purposes. [Backup retention / rotation period · to be confirmed] This should be disclosed to Customers on request.

5.Early Deletion Requests

5.1A Customer may request deletion of Employee Data earlier than the default schedule (e.g. following an individual employee's own erasure request to the Customer as Controller). Such requests should be actioned within [30 · to be confirmed] days, subject to any legal requirement to retain specific records.

5.2Where the Company holds data as Controller and receives a valid erasure request from an individual, it will assess the request against the exemptions in UK GDPR Article 17(3) (e.g. legal obligation, defence of legal claims) before actioning or declining it, per the process in the GDPR / Data Protection Policy.

Where the Company reasonably anticipates or is notified of litigation, a regulatory investigation, or an insurance claim, standard retention and deletion periods for relevant data are suspended ("legal hold") until the matter is resolved, even where a routine deletion date would otherwise apply. Authority to place and lift a legal hold: [name or role — e.g. Founder/Director or external counsel · to be confirmed].

7.Review

This schedule is reviewed at least annually, or sooner if there is a material change in law, guidance from the ICO, HMRC record-keeping requirements, or the Company's processing activities, and is approved by [director or role · to be confirmed]. Retention periods above marked with brackets must be confirmed against current legal requirements at each review.

8.Contact

Questions about this schedule should be directed to:

Build Your Vision Ltd
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Data Protection Lead: [name · to be confirmed] — Email: info@buildyourvision.co.uk
Website: byvpeoplehub.com