Data Retention
Policy.
This policy explains how long Pintop Technologies Limited retains different categories of personal data, when information should be deleted and when deletion may need to be temporarily suspended.
Keep information only while there is a reason to keep it.
The purpose of this policy is to support the storage limitation principle by defining how retention periods are determined and how information is disposed of when it is no longer required.
It applies to relevant personal data held by Pintop in electronic or physical form when Pintop acts as a data controller.
Where Pintop processes information on behalf of a client, retention is governed by the applicable commercial agreement, Data Processing Agreement, documented client instructions and relevant service configuration.
How retention periods are
determined.
A retention period should reflect the purpose of the information, applicable obligations and the risks connected to keeping or deleting it.
Processing purpose
Information is retained while it is reasonably required for the purpose for which it was collected.
Legal obligations
Applicable tax, employment, contractual, regulatory and record-keeping requirements are considered.
Claims and accountability
Records may be retained where they are reasonably required to establish, exercise or defend legal claims.
Secure disposal
Information that is no longer required is securely deleted, destroyed or anonymised using a method appropriate to the storage medium.
Retention schedule by
information category.
The periods below describe the expected retention approach for the listed categories, subject to applicable holds, contractual instructions and legal requirements.
Client and commercial records
Client contracts
Agreements, order forms, service-level agreements, DPAs, NDAs, renewal records, termination records and related correspondence.
Billing and payment records
Invoices, receipts, payment confirmations, account statements and payment-dispute records.
Client business contacts
Names, roles, business contact details, correspondence and relationship history.
Prospects, marketing and website activity
Prospect and lead information
Enquiries, demo requests, event contacts and related business-development correspondence.
Marketing and CRM information
Mailing-list records, communication choices, consent records and engagement history.
Website analytics
Analytics identifiers, page activity and website-session information collected through approved analytics technology.
Workforce and recruitment records
Employment records
Employment agreements, role records, performance information, leave records, training records and exit documentation.
Payroll and statutory records
Payroll registers, payslips, PAYE records, pension records and applicable statutory contribution records.
Unsuccessful recruitment candidates
Applications, CVs, interview notes and recruitment correspondence for a completed recruitment exercise.
Operational and supplier records
CCTV footage
Security-camera footage from Pintop-controlled premises where CCTV is installed and operating.
Supplier information
Supplier contacts, agreements, bank details, invoices and relationship-administration records.
MeVerify data follows a
limited handling model.
The retention approach for identity-verification information reflects the service architecture, contracted processing relationship and configuration applying to the implementation.
Deletion should match the storage medium.
When a retention period expires, information is securely deleted, destroyed or anonymised using a method appropriate to the system, device or record involved.
Servers and cloud systems
Use approved deletion, purge, overwrite or cryptographic-erasure processes supported by the relevant platform.
Backup media
Allow information to expire through the approved backup lifecycle or use the provider’s documented deletion process where earlier deletion is supported.
Paper documents
Use cross-cut shredding or an approved secure document-destruction service.
Email and collaboration systems
Remove records from active mailboxes and apply the relevant archive, retention and deletion controls available in the service.
Computers and portable devices
Use secure device erasure, approved reformatting, cryptographic reset or physical destruction where reuse is not appropriate.
Deletion may be paused where information must remain available.
A scheduled deletion may be suspended where the information is relevant to an active request, investigation, claim or other documented obligation.
Retention requires
ongoing oversight.
Retention periods and disposal processes are reviewed as systems, contracts, legal obligations and business activities change.
Periodic review
Retention categories and periods are reviewed on a planned basis to confirm that they remain appropriate.
Legal and regulatory change
The schedule may be updated where applicable record-keeping or data-protection requirements change.
Operational change
New products, systems, processors, integrations or business processes may require updated retention and deletion arrangements.
Related privacy and
governance documents.
These documents provide further information about Pintop’s handling of personal data, consent and individual rights.
Questions about how long information is retained?
Share the relevant account, product, relationship or information category so Pintop can route the enquiry appropriately.