Changing LanesLimited

Legal

Data retention schedule

How long we keep each kind of record, generated from the rules the software enforces.

Draft for legal review

This document has been prepared from the platform as it is built today and must be reviewed by a UK solicitor before it is relied on. Details marked [to be confirmed: …] are company details we are still confirming (2 in this document).
Version
1.0 (draft)
Effective date
Applies to
Everyone
Owner and next review
Data Protection Lead · by
All legal documents

How this schedule works

The platform keeps a retention policy for each kind of record. Every night a preview shows what is due, and a compliance officer applies it with a deliberate click. Records marked "reviewed by a person" are never deleted automatically — they are checked by hand each year because a law or contract sets their period. The table below is generated from the same rules the software enforces, so it cannot differ from what actually happens.

Retention schedule
RecordHow long we keep itWhat happens thenWhy
Applications that were rejected or withdrawn without enrolment12 months after the decisionAnonymised automaticallyLong enough to answer questions, complaints or a re-application; then name, contact details, date of birth and postcode are replaced so only anonymous counts remain.
Enrolled learner records: enrolment, attendance, assessments, certificates, funding evidence, placementsThe funding year plus six years (seven years), reviewed by a person — never deleted automaticallyReviewed by a personFunding contracts require evidence to be kept for audit; certificates must stay verifiable.
Invoices, payments, refunds and remittancesSix years after the end of the financial year they relate to, reviewed by a personReviewed by a personHMRC and Companies Act record-keeping; card numbers are never held by us.
Staff records, pay history and payroll runsSix years after employment ends, reviewed by a personReviewed by a personHMRC and employment-law record keeping; defending claims.
Audit trail of who did what (references only, never form contents)Seven years, reviewed by a personReviewed by a personEvidence that records were handled correctly (funding audit, complaints, disputes).
Which version of our terms and policies you accepted, and whenSix years after your account closes, reviewed by a personReviewed by a personEvidence of the terms that applied (the Limitation Act 1980 period for contract claims).
Marketing consent records and their history; unsubscribesWhile you are on our records and then seven years; an unsubscribe (suppression) is kept permanently so we never contact you again by mistakeReviewed by a personEvidence of consent and opt-outs under PECR.
Who was sent each marketing email and what happened (address, outcome, unsubscribe link)24 months, then the address is removed and only counts remainAnonymised automaticallyEvidence of what was sent to whom and when.
Internal staff message threads after they are archived24 months, reviewed by a personReviewed by a personBusiness records and employment disputes.
Contact-form messages12 months after the enquiry is closedDeleted automaticallyLong enough to follow up and handle a complaint about the reply.
Employer enquiries24 months after the enquiry is closedDeleted automaticallyCommercial follow-up.
Delivered and read notifications12 monthsDeleted automaticallyProportionality — the underlying record is kept in its own module.
"Report a problem" reports and their session transcripts12 monthsDeleted automaticallyDebugging related issues and improving the service.
Driver check-in survey answers after a placement24 monthsDeleted automaticallyEvidence of the support given after placement.
Log of automated actions (record references and fixed reasons only)24 monthsDeleted automaticallyAudit of what the automation did.
Closed automation proposals (accepted, declined or superseded) — open ones are kept24 months after closingDeleted automaticallyShows what was prepared and which person decided.
History of reports run by staff; scheduled report snapshots12 months (snapshots are cleared after 30 days)Deleted automaticallyAudit of report generation with minimal copies.
Expired or cancelled payment-page sessions90 daysDeleted automaticallyOperational.
Processed internal system events (record references only)90 daysDeleted automaticallyOperational.
Log of certificate look-ups (no personal data)24 monthsDeleted automaticallyDetecting misuse of the verification service.
Cookieless page-view counts (page template, referring site, device type)26 monthsDeleted automaticallyService improvement; no identifiers are kept (the same-day hash is discarded daily).
Aggregate management statistics (counts only)6 yearsDeleted automaticallyManagement information matching the longest funding record period.
Analytics processing run log12 monthsDeleted automaticallyOperational log.
Rate-limit counters (a salted one-way hash of the network address)24 hoursDeleted automaticallySecurity — preventing abuse of public forms.

Other copies

  • Backups of the database are kept by our hosting provider on a rolling basis and expire automatically; restored data is re-checked against this schedule.
  • Error reports (Sentry), service logs (Better Stack) and optional analytics (PostHog) are kept by those processors for the period set in our account with them — [to be confirmed: processor retention settings]. Personal details are removed before error reports and logs are sent.
  • Records needed for a legal claim, a funding audit, a safeguarding concern or an open complaint are kept until the matter is closed, even if the period above has passed (a legal hold).

Changes

Periods can only be changed by compliance staff, and every change is recorded. The Data Protection Lead reviews this schedule every September. Questions: [to be confirmed: privacy and data protection email address].

Change history

Change history for Data retention schedule
VersionDateChangeAcceptance needed again
1.0First draft for legal review, written from the platform as built.Yes — material change