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 | Examples | Retention period | Basis / trigger | Deletion method |
|---|---|---|---|---|
| Prospect / lead data | Contact details from demo requests, website forms, sales conversations that did not convert | [24 months · to be confirmed] from last contact | Legitimate interest in following up; deleted if no engagement | Automated purge / manual deletion from CRM |
| Customer account & billing data | Company name, admin contact details, Subscription history, invoices | Duration of contract + [6 years · to be confirmed] | UK tax and accounting record-keeping (Companies Act / HMRC) | Deletion from billing system after retention period |
| Payment data | Billing address; card data is tokenised via payment processor, not stored directly | As above; token retained only while needed for recurring billing | Contract performance; PCI-DSS obligations sit with payment processor | Processor-side deletion per their retention rules |
| Support & communications records | Support tickets, emails, call notes with Customer contacts | [24 months · to be confirmed] after ticket closure / last contact | Legitimate interest in service continuity and dispute resolution | Automated purge from support tooling |
| Marketing contact data | Newsletter subscribers, webinar attendees, event contacts | Until opt-out, or [24 months · to be confirmed] of inactivity | Consent / legitimate interest, whichever applies | Removal from marketing platform on request or automated purge |
| Website analytics / usage data | Aggregated or pseudonymised site and product usage data | [14–26 months · to be confirmed] per analytics tool default, or as configured | Legitimate interest in improving the Service | Automatic expiry per analytics tool settings |
| Job applicant data (Company's own hiring) | CVs, interview notes for candidates applying to work at the Company | [6 months · to be confirmed] after the recruitment process closes, unless the candidate consents to longer for future roles | Legitimate interest in recruitment; limitation period for discrimination claims | Secure deletion from ATS/email |
| Company's own staff HR records | Employment contracts, payroll, performance and disciplinary records | Duration of employment + [6 years · to be confirmed] | Employment law limitation periods; HMRC/pension record-keeping | Secure deletion or archiving then deletion |
- 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 | Examples | Retention while Subscription active | Post-termination | Deletion method |
|---|---|---|---|---|
| Core employee profile data | Name, address, contact details, employment details | Retained while the employee record is active or per Customer's own configured policy | Exported on request within [30 · to be confirmed] days of termination; then deleted within a further [60 · to be confirmed] days | Secure deletion per DPA Clause 8 |
| Special category / health data | Medical forms, risk assessments, sickness/absence records | As above — access restricted to permissioned roles at all times | Same export/deletion window as core data; treated with the same or greater care | Secure deletion, encryption key destruction where applicable |
| Leave, absence, and lateness records | Annual leave balances/history, absence and lateness logs | Retained for the current and prior [2 · to be confirmed] leave years by default, adjustable by Customer | Included in standard export/deletion window | Secure deletion |
| Probation, performance & review records | Probation review outcomes, one-to-ones, appraisal records | Retained while the employee record is active | Included in standard export/deletion window | Secure deletion |
| Employee relations / disciplinary records | Case notes, disciplinary and grievance documentation | Retained per Customer's own policy (commonly employment duration + [6 years · to be confirmed] under UK employment practice) | Included in standard export/deletion window unless Customer requests earlier removal | Secure deletion |
| Recruitment pipeline data (Customer's hiring) | Candidate details in a Customer's recruitment pipeline | Retained per Customer's own configured recruitment policy | Included in standard export/deletion window | Secure deletion |
| Account activity logs | Login history, audit trail of changes to employee records | [12 months · to be confirmed] rolling, for security and audit purposes | Deleted per standard post-termination window unless required for a live security investigation | Automated purge / secure deletion |
- 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.
6.Legal Holds
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