Data Cleansing Policy
Data Cleansing and Retention Policy
Purpose
First Class Support is committed to protecting the personal data it processes and ensuring compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This policy outlines how personal data is reviewed, retained and securely deleted to ensure information is not kept for longer than necessary.
Responsibilities
The appointed GDPR Manager is responsible for informing, advising and monitoring compliance with UK GDPR and data protection legislation.
The GDPR Manager will:
• Regularly review the security of all stored personal data.
• Ensure personal data is held securely and protected from unauthorised access, loss, destruction or misuse.
• Monitor data retention periods and oversee the secure deletion of personal data when it is no longer required.
• Maintain appropriate records of data deletion activities where necessary.
Data Retention
First Class Support will only retain personal data for as long as necessary to fulfil the purpose for which it was collected and to meet legal, regulatory, contractual, safeguarding and business requirements.
Personal data will be reviewed periodically to ensure information that is no longer required is securely deleted.
Unless a longer retention period is required by law, regulation, safeguarding obligations, an ongoing complaint, investigation, audit or legal claim, the following retention periods apply:
• Student support records, assessments, correspondence and support documentation: 6 years after support ends.
• University, funding body and DSA-related records: 6 years after support ends.
• Support worker and contractor records: 6 years after engagement ends.
• Employee personnel records: 6 years after employment ends.
• Financial records, invoices and accounting information: 6 years from the end of the relevant financial year.
• Safeguarding records: 6 years after the matter is closed unless a longer retention period is required.
• Unsuccessful recruitment applicant records: 12 months after the recruitment process concludes.
• Marketing contacts and enquiries: Until consent is withdrawn or the data is no longer required.
Where a complaint, legal claim, audit, safeguarding concern or regulatory investigation is ongoing, relevant records may be retained beyond the standard retention period until the matter has been fully resolved.
Data Cleansing
The GDPR Manager will undertake periodic reviews of stored information to identify data that:
• Is no longer required for its original purpose.
• Has exceeded its retention period.
• Is inaccurate, duplicated or outdated.
• Should be securely archived or deleted.
Where data is identified for deletion, it will be removed using secure deletion methods appropriate to the type of information and storage location.
Requests for Deletion
Individuals may request the deletion of their personal data by contacting:
admin@firstclass-support.co.uk
or writing to:
First Class Support
East Quay House
Sutton Harbour
Plymouth
Devon
PL4 0HX
Requests will be considered in accordance with UK GDPR and other applicable legal obligations.
Where First Class Support has a lawful basis for retaining information, including contractual, legal, safeguarding, audit or regulatory requirements, the request may be refused or only partially fulfilled.
Secure Deletion
All personal data identified for deletion will be securely destroyed or permanently erased in a manner that prevents recovery or unauthorised access.
Electronic records will be permanently deleted from relevant systems where appropriate, and physical records will be securely shredded or disposed of using approved confidential waste processes.
Review of Policy
This policy will be reviewed periodically to ensure continued compliance with applicable legislation, regulatory requirements and organisational practices.