Data Retention Policy
1. Overview
dykaw retains personal data only for as long as necessary to fulfil the purposes for which it was collected, to meet legal obligations, and to support legitimate business interests such as security, fraud prevention, and service improvement. This policy sets out how long each category of data is stored, why, and how it is deleted.
We follow the principles of UK GDPR, the Data Protection Act 2018, and PECR. Our retention periods are based on regulatory requirements, industry standards, and operational needs.
2. Retention Principles
We determine retention periods based on:
- The purpose of the data
- Legal obligations
- Security requirements
- User expectations
- Contractual limitation periods
3. Secure Deletion Methods
Data is securely deleted using:
- Database purging (including automated cascade deletion of an entire account)
- Automated daily log purging
- Encrypted backup destruction
- Manual deletion for support records
4. Full Retention Schedule
Below is the retention table for the data categories dykaw processes. Where a category isn't yet built as a feature, or its stated period isn't yet enforced by an automated job, that's stated plainly in the Notes column rather than left implied.
| Data Category | Purpose | Legal Basis | Retention Period | Deletion Method | Notes |
|---|---|---|---|---|---|
| Invite Codes | Gate registration to invited people; maintain an identity/referral audit trail | Contract (validating invite-only access); Legitimate Interest (audit trail) | No expiry timer — retained indefinitely | Not yet automated | An invite code never expires. It simply becomes unusable once the invited person's registration is approved by an administrator, which marks the same record as used — nothing is deleted at that point. If the invited person's account is later deleted, their email on this record is overwritten with a non-identifying placeholder, but the invite record itself is kept. |
| Password Reset Tokens | Verify identity before allowing a password change | Contract | 1 hour, or immediately on use | Automated daily purge | Deleted the moment it's used, the moment an expired one is attempted, or by the daily purge if never used at all |
| User Account Data | Provide access to dykaw | Contract | Deleted immediately on account closure | Full cascade deletion | See Section 5 below |
| Password Hashes | Authentication | Contract | Until account deletion | Secure deletion | Never stored in plaintext |
| Mobile API Tokens | Authenticate the mobile app without repeated logins | Contract | 30 days, or until account deletion | Cascade deletion on account closure | A token stops working after 30 days (or if revoked), but the row itself isn't removed until the account is deleted — expired/revoked tokens accumulate in the meantime but can never be reused |
| Email Address (Active Users) | Login + notifications | Contract | Until account deletion | Secure deletion | Required for account recovery |
| Email Address (Closed Accounts) | — | — | Not retained | — | Deleted immediately with the rest of the account (see Section 5); only a one-way, non-identifying hash survives |
| Deleted Account Record | Maintain an honest count of departures | Legitimate Interest | Indefinite | N/A — contains no personal data | One-way hash of the email plus account type and date only; cannot be reversed or linked back to a person |
| Pending Review Records | Hold a sign-up's details (name, contact, company, invite code) while an admin manually reviews a flagged application | Contract (pre-contract steps); Legitimate Interest (fraud/quality control) | Retained until an admin approves, rejects, or removes it — no automatic timeout | Manual (admin action) only | Despite the word "review" suggesting a short window, an unresolved application can sit here indefinitely if no admin acts on it |
| Rejected Sign-Up Records | Permanent record of a sign-up whose rejection was upheld, including who rejected it and why | Legitimate Interest (preventing repeat bad-faith sign-ups; audit) | Indefinite — intentionally a permanent archive | Not yet automated | Contains full identifiable data (name, email, phone, company) — unlike a deleted account, this is not anonymised, since the person never held a real dykaw account |
| Registration Logs | Security & fraud detection | Legitimate Interest | Not currently tracked | N/A | Not yet built as a separate audit trail with IP/user agent |
| Page Activity Logs | Diagnose performance issues; understand navigation patterns | Legitimate Interest | 90 days | Automated daily purge | Records which page was visited, referring page, browser/device string, and load time; no IP address. Any linked account is cleared to anonymous once that account is deleted, ahead of the 90-day purge if it happens sooner |
| Login Logs | Security record-keeping | Legitimate Interest | 12 months | Automated daily purge | Includes IP address & browser/device info; available for investigation if suspicious activity is reported |
| System Audit Logs (Admin Actions) | Compliance, accountability & audit | Legal Obligation | 6 years | Automated daily purge | Includes IP address; retained to support accountability if an admin action needs to be reviewed |
| Circle Removal Log | Audit trail of when/why a user was removed from a skill circle, and by whom | Legitimate Interest | Indefinite — not yet on an automated timer | Not yet automated | Not touched by account deletion — if either person involved later deletes their account, this log still holds their old internal ID with nothing to anonymise it |
| Contract Expiry Warning Log | Record of which contract-expiry warning emails have already been sent, to avoid sending the same one twice | Legitimate Interest | Until the associated user's account is deleted; indefinite for active users | Cleared automatically on account deletion; otherwise not yet on its own timer | Accumulates one row per warning sent for as long as the account stays active |
| Support Tickets | Customer support | Legitimate Interest | Not yet applicable | N/A | Not built as a platform feature yet |
| Error Logs | Debugging & stability | Legitimate Interest | 90 days | Automated daily purge | Contains stack traces; any linked email is cleared once the account is deleted |
| Email Delivery Logs | Deliverability & troubleshooting | Legitimate Interest | 30–90 days | Provider deletion | Depends on our email provider — to be confirmed before go-live |
| Backups (Database) | Disaster recovery | Legitimate Interest | To be confirmed with hosting provider | Encrypted deletion | See Security Policy §8 |
| Analytics Data (Aggregated) | Improve service | Legitimate Interest | Not yet active | N/A | Framework for future use — see Cookie Policy |
| Analytics Cookies | Usage analytics | Consent | Not yet active | N/A | See Cookie Policy §3.2 |
| Essential Cookies | Session handling | Legitimate Interest | Up to 30 minutes of inactivity | Automatic server-side expiry, or browser deletion — whichever comes first | Required for login functionality. The cookie carries a fixed 30-minute lifetime rather than being a pure browser-session-only cookie, so it can persist briefly across a browser restart within that window |
| Email Templates (Sent) | Record of communications | Legitimate Interest | Not yet applicable | N/A | Not built as a platform feature yet |
| Alert Reveal & Billing Records | Record which talent an agency has unlocked, and bill for it | Contract; Legal Obligation (financial records) | Retained indefinitely — not yet on an automated timer | Not yet automated | An agency's "Alerts Revealed" and "PAYG Alerts" pages only display the last 24 hours (or, for PAYG, the current day) as a short-term convenience view — nothing is deleted when that view rolls over. The full, permanent record of every reveal is kept under that agency's Financials page for as long as the account exists. |
| Third-Party Processor Data | Hosting, email delivery | Contract | Follows each processor's own policy | Processor deletion | To be documented in a Data Processing Agreement once providers are confirmed |
5. What Happens When You Delete Your Account
Where the table above says "until account deletion" or "on account closure", we mean this literally: closing your account — whether you delete it yourself or it's closed automatically after prolonged inactivity — triggers immediate, full removal of your account, contract, connection, and referral data. There is no 6-year (or any other) grace period during which a closed account's personal data continues to sit in our database.
The only thing kept afterwards is a single non-identifying record confirming that an account of a given type was deleted, and roughly when. It's a one-way, irreversible hash of the email address, plus the account type and date — no name, no readable email, no other personal detail. It cannot be used to re-identify you; we keep it purely so we have an honest internal count of departures, not as a route back to any individual's data.
6. Your Rights
Under UK GDPR, you may request:
- Access to your data
- Deletion
- Correction
- Restriction
- Data portability
Requests can be made by contacting privacy@dykaw.co.uk.
7. Changes to This Policy
We may update this Data Retention Policy from time to time, including as we automate retention for categories currently marked "not yet automated" or "not yet built" above. When we do, we will update the "Last Updated" date.
8. Contact
For questions or concerns regarding this policy or our data protection practices, contact our Data Protection lead at privacy@dykaw.co.uk.