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Data & Privacy
Data Retention and Deletion Schedule
Retention periods, deletion triggers and archival rules for each category of data held by ImpactMiles.
- Version
- v1.0
- Effective
- 2026-07-19
- Last reviewed
- 2026-07-19
- Next review
- 2027-07-19
- Owner
- Data Protection Officer
- Approver
- Executive Team
Anchored by content hashissued 2026-07-29
Payload hash
40d1e9cabaef40edde447941941de59e9976f53a0378bfbebe0f28d982324005SHA-256 digest of the receipt content
Issuer AID
EP1_FGkcwfHAuih6VUzv9kgAVBvvSoaswSUao61lkxhEParty that issued this receipt
ImpactMiles handle
audit:governance:40d1e9cabaef40edThis receipt is anchored by content hash. A resolvable credential SAID is not available for this record.
Applies to
- All data stores
- Backups and audit logs
Jurisdictions
- Hong Kong (PDPO, IRD s.88)
- United Kingdom (UK GDPR, DPA 2018)
- European Union (GDPR)
- Singapore (PDPA)
- Australia (Privacy Act 1988)
- Japan (APPI)
- Wider APAC per country taxonomy
How this is applied in-product
- Scheduled deletion jobs for expired records
- Public retention statement at /privacy
- Immutable KERI credentials retained by design; PII never anchored
1. Retention Table
- Account profile - retained while account is active plus 24 months after closure, then anonymised.
- Donation records - 7 years after the tax year of receipt (IRD, HMRC, IRAS compatible).
- AML/KYB evidence - 5 years after the end of the business relationship.
- Audit logs - 3 years, then aggregated and pseudonymised.
- Support tickets - 2 years.
- Marketing consents - until withdrawn plus 12 months evidentiary window.
- KERI credentials (ACDCs) - retained indefinitely as tamper-evident public artefacts; contain no personal data.
2. Deletion Triggers
- User-initiated erasure request via /privacy.
- Retention period expiry via scheduled job.
- Legal or regulatory hold overrides deletion until the hold is lifted.
3. Backups
Encrypted backups are retained for 35 days on a rolling basis. Deletion requests are honoured in production immediately and in backups within the standard rotation window.
Questions or concerns about this policy? Contact the DPO.