Last updated: September 10, 2025
This policy establishes HoneyPSA’s commitment to responsible data management, specifying retention and disposal practices to protect customer and employee data, ensure compliance with applicable regulations, and optimize storage costs.
This policy applies to all data generated, processed, and stored by HoneyPSA, including customer data, employee records, financial records, and operational logs across all storage systems.
HoneyPSA is dedicated to retaining data only as long as necessary for business and legal purposes, ensuring its secure disposal afterward, and maintaining transparency and accountability in data management.
Roles and Responsibilities
- Data Owner: Responsible for defining data retention periods and overseeing compliance within their department.
- Data Steward: Ensures data accuracy, security, and proper disposal according to this policy.
- IT Team: Implements technical controls for data retention, archiving, backup, and disposal.
- Legal & Compliance Officer: Ensures adherence to legal obligations, manages legal holds, and reviews retention requirements.
- Employees & Users: Follow procedures for data handling, reporting data subject requests, and adhering to security protocols.
Data Categorization for Retention
| Data Type | Description | Sensitivity Level | Retention Period |
| Employee Records & HR Data | Employee personal and payroll information | High | 7 years after employment |
| Customer Personal Information | Customer contact, login, and transaction data | High | 365 days from last activity |
| Financial Records & Transactions | Invoices, payment data | High | 7 years |
| Operational & System Logs | System activity, access logs | Medium | 7 years |
Retention Schedules
Customer Data:
- Retained for 365 days from last usage.
- Moved to archive storage for an additional 2 years for active customers.
- Customers may request data retrieval from archive via support ticket.
Terminated Customer Data:
- Deleted 30 days after account termination unless the customer requests earlier deletion.
- Customers are responsible for exporting data before account termination.
Employee Data:
- Retained for 7 years after employment ends.
- Financial Data:
- Retained for 7 years to meet legal requirements.
Operational & System Logs:
- Retained for 7 years.
Legal and Regulatory Requirements
HoneyPSA complies with:
- GDPR: Ensuring data minimization, rights to access, rectify, and delete data.
- Industry-specific guidelines for data retention, including finance and employment data.
There are no additional specific regulations; compliance is maintained through this policy.
Business Justification Criteria
Retention periods are justified based on:
- Regulatory requirements
- Customer Relations management
- Legal disputes or potential litigation
- Operational needs
Any deviations or extensions require approval from the Legal & Compliance Officer.
Legal Hold Procedures
- Upon commencement of litigation or legal investigation, data related to the case will be suspended from deletion.
- Legal team will notify IT to implement legal holds, ensuring data is preserved in secure, read-only storage.
- Legal holds remain until notified otherwise.
Disposal Procedures
Secure Deletion:
- Data is permanently deleted using cryptographic erasure for digital storage.
- Physical media containing data is shredded or incinerated.
Data Destruction Schedule:
- Data exceeding retention periods is scheduled for deletion during routine cleanup.
Verification:
- Disposal processes are documented and periodically audited for compliance.
Archive Management
- Data moved to archive storage (e.g., cold storage systems) will be retained for two years.
- Access to archived data is limited and mediated through support tickets.
- Archived data will be securely stored and periodically reviewed for relevance.
Privacy Rights Management
- Requests for data deletion or access are handled partially automated via customer support portals.
- Customers can submit requests through support tickets.
- Data is reviewed and acted upon within 30 days, respecting GDPR timelines.
- Data is removed or provided in accordance with user rights.
Backup and Recovery Retention
- Backup data follows the same retention schedule as primary data.
- Backup rotation occurs every 30 days to manage storage costs.
- Old backups are securely destroyed after their retention period expires.
Cloud Data Retention
- Cloud-stored data adheres to the same retention schedules.
- Data in cloud environments is encrypted at rest and in transit.
- Cloud providers’ retention and deletion policies are aligned with HoneyPSA’s policies.
Third-Party Data Handling
- Vendors processing customer or employee data are required to comply with HoneyPSA’s retention policies.
- Data sharing agreements specify retention, security, and disposal obligations.
Monitoring and Compliance
- Regular audits and automated monitoring ensure adherence to retention and disposal policies.
- Periodic reviews are conducted annually or following significant process changes.
- Documentation of compliance is maintained for audit purposes.
Exception Management
- Any deviations or extensions to retention periods must be approved in writing by the Legal & Compliance Officer.
- Exceptions are documented with justification and review date.
Training and Awareness
- Employees receive annual training on data retention, privacy rights, and disposal procedures.
- Policy updates are communicated via email and internal portals.
Documentation and Record Keeping
- All retention and disposal activities are logged.
- Records include data subject request tracking, disposal dates, and approval documentation.
- These records are retained for at least 5 years.
This policy is subject to periodic review and updates. HoneyPSA will notify users in advance about significant policy changes via email.