Introduction
This data retention policy sets out the obligations of LTVplus, LLC (“LTVplus” or “us/we/our”)) and the basis upon which we shall retain, review and destroy data held by us, or within our custody or control.
This policy applies to our entire organisation including our officers, employees, agents and sub-contractors and sets out what the retention periods are and when any such data may be deleted.
Objectives
It is necessary to retain and process certain information to enable our business to operate. We may store data in the following places:
This policy applies equally to paper, electronic media and any other method used to store personal data. The period of retention only commences when the record is closed.
We are bound by various obligations under the law in relation to this and therefore, to comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully in respect of their personal data under the General Data Protection Regulation (“the Regulation”).
The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets out the procedures that are to be followed when dealing with personal data and how we aim to comply with the Regulation in so far as it is possible. In summary, the Regulation states that all personal data shall be:
a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;
b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
The Fourth and Fifth Data Protection Principles require that any data should not be kept longer than necessary for the purpose for which it is processed and when it is no longer required, it shall be deleted and that the data should be adequate, relevant and limited for the purpose in which it is processed.
With this in mind, this policy should be read in conjunction with our other policies which are relevant such as our data protection policy and IT security policy.
Legal Basis for Processing
All personal data processed by LTVplus shall be done on one or more of the lawful bases defined under Article 6 of the GDPR:
The specific legal basis for each type of processing activity will be documented and maintained in our Data Processing Register.
Data Subject Rights
LTVplus is committed to ensuring that data subjects can exercise their rights under the GDPR.
Data subjects may exercise the following rights by contacting our Data Protection Officer.
Right to Access: Data subjects have the right to request a copy of the personal data we hold about them.
Right to Rectification: Data subjects have the right to request that we correct any inaccuracies or incomplete data.
Right to Erasure (“Right to be Forgotten”): Data subjects have the right to request that their personal data be deleted, subject to our legal obligations.
Right to Restrict Processing: Data subjects can request a restriction on the processing of their data under certain circumstances.
Right to Data Portability: Data subjects have the right to receive their personal data in a structured, commonly used, and machine-readable
format.
Right to Object: Data subjects may object to processing based on legitimate interests or direct marketing purposes.
Right to Withdraw Consent: Where processing is based on consent, data subjects have the right to withdraw consent at any time.
All requests will be responded to within one month, in accordance with GDPR. Complex cases may require an extension of up to two additional months, in which case the data subject will be notified of the delay and reasons.
Security and Storage
All data and records are stored securely to avoid misuse or loss. We will process all personal data we hold in accordance with our IT Security Policy or take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if there is agreement by them to comply with those procedures and policies, or if there are adequate measures in place.
Examples of our storage facilities are as follows:
We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
(a) Confidentiality means that only people who are authorised to use the data can access it.
(b) Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
(c) Availability means that authorized users should be able to access the data if they need it for authorized purposes.
Bring Your Own Device (BYOD) Security
To mitigate risks associated with personal devices used for work purposes, LTVplus enforces the following BYOD security protocols:
Annual audits will be conducted to assess BYOD compliance and update protocols as necessary.
Data Transfers Outside the EU
Where LTVplus transfers personal data to countries outside the European Union or European Economic Area, such transfers will only occur under one of the following mechanisms, as required by GDPR:
We will ensure that all international data transfers are documented and conducted in accordance with Chapter V of GDPR.
Incident Management
In addition to managing personal data breaches, LTVplus will address all security incidents, including suspected or actual unauthorized access attempts. Our incident management process includes:
This expanded scope ensures that non-breach events are treated with the same diligence as data breaches to protect our systems and data effectively.
Retention Policy
Data retention is defined as the retention of data for a specific period of time and for backup purposes.
We shall not keep any personal data longer than necessary, but acknowledge that this will be dependent on the different types of documents and data that we have responsibility for. As such, our general data retention period shall be for a period of 3 years. Our specific data retention periods are set out below.
| Type of data | Type of data subject | Type of processing | Purpose of processing | Type of recipient to whom personal data is transferred | Retention period | Data accuracy and minimisation review date |
| External Data such as name, gender, ethnicity, age and geographic data Social Data such as job titles, work history, educational background, employment history, certifications, group memberships and professional connections Tracking information such as email, physical address, telephone numbers, IP addresses and geographic information Financial Information such as credit card numbers and bank accounts Communication Information such as telephone recordings, voice mail and email | Customers | Sales, Marketing | Either as: 1) data processor on behalf of a data controller to fulfill a service request of the data controller or 2) data controller for human resources, general marketing, client acquisition or to fulfill a service request by the data subject | Data Controller, Sales & Marketing Team, Executive Management | 3 years | Once a year |
External Data such as name, gender, ethnicity, age and geographic data | Business contacts | Sales, Marketing | Either as: 1) data processor on behalf of a data controller to fulfill a service request of the data controller or 2) data controller for human resources, general marketing, client acquisition or to fulfill a service request by the data subject | Data Controller, Sales & Marketing Team, Executive Management | 3 years | Once a year |
| External Data such as name, gender, ethnicity, age and geographic data Social Data such as job titles, work history, educational background, employment history, certifications, group memberships and professional connections Tracking information such as email, physical address, telephone numbers, IP addresses and geographic information Financial Information such as credit card numbers and bank accounts Communication Information such as telephone recordings, voice mail and email | Employees | HR, Payroll | Either as: 1) data processor on behalf of a data controller to fulfill a service request of the data controller or 2) data controller for human resources, general marketing, client acquisition or to fulfill a service request by the data subject | Operations Team, HR, Executive Management | 3 years | Once a year |
| External Data such as name, gender, ethnicity, age and geographic data Social Data such as job titles, work history, educational background, employment history, certifications, group memberships and professional connections Tracking information such as email, physical address, telephone numbers, IP addresses and geographic information Financial Information such as credit card numbers and bank accounts Communication Information such as telephone recordings, voice mail and email | Contractors | HR, Payroll | Either as: 1) data processor on behalf of a data controller to fulfill a service request of the data controller or 2) data controller for human resources, general marketing, client acquisition or to fulfill a service request by the data subject | Operations Team, HR, Executive Management | 3 years | Once a year |
| External Data such as name, gender, ethnicity, age and geographic data Social Data such as job titles, work history, educational background, employment history, certifications, group memberships and professional connections Tracking information such as email, physical address, telephone numbers, IP addresses and geographic information Financial Information such as credit card numbers and bank accounts Communication Information such as telephone recordings, voice mail and email | Potential employees | Talent Acquisition | Either as: 1) data processor on behalf of a data controller to fulfill a service request of the data controller or 2) data controller for human resources, general marketing, client acquisition or to fulfill a service request by the data subject | Operations Team, HR, Executive Management | 1 year | Once a year |
Retention periods for personal data have been defined based on:
An annual review process will ensure that data retention schedules remain aligned with regulatory and operational requirements.
From time to time, it may be necessary to retain or access historic personal data under certain circumstances such as if we have contractually agreed to do so or if we have become involved in unforeseen events like litigation or business disaster recoveries.
Pseudonymization and Anonymization
To further safeguard personal data retained for archiving, historical, or statistical purposes, LTVplus will apply pseudonymization or anonymization techniques where feasible:
These techniques will be applied particularly to archived or historical data that must be retained beyond the primary retention period for legal, research, or operational reasons.
Destruction and Disposal
Upon expiry of our retention periods, we shall delete confidential or sensitive records categorised as requiring high protection and very high protection, and we shall either delete or anonymize less important documents.
Our General Manager is responsible for the continuing process of identifying the records that have met their required retention period and supervising their destruction. The destruction of confidential, financial, and personnel-related records shall be securely destroyed electronically or by shredding if possible. Non-confidential records may be destroyed by recycling.
Data Protection Impact Assessments (DPIAs)
LTVplus conducts Data Protection Impact Assessments (DPIAs) for any processing activities that are likely to result in a high risk to the rights and freedoms of individuals, as required under Article 35 of the GDPR. Situations warranting a DPIA include, but are not limited to:
The DPIA process involves:
DPIAs will be documented and regularly reviewed to ensure continued compliance with GDPR requirements.
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