Who takes care of a request?
The company owner personally handles privacy and deletion requests at [email protected]. This policy sets out manual responsibilities; it does not introduce automatic record deletion.
What is kept, and why
- Accounts & contacts
- While access or the business relationship is needed. On departure/closure, review access and unnecessary contact details; retain only justified history.
- Review: Closure, staff change or a rights request.
- Quotes & enquiries
- Until the enquiry and any agreed follow-up end; then remove or anonymise details without a continuing purpose.
- Review: Enquiry closed or no longer pursued.
- Artwork, proofs & approvals
- While needed for the product, repeat orders, quality evidence or a specific dispute. Review spare versions and personal details separately.
- Review: Project/customer becomes inactive; product ends.
- Messages & translations
- While needed to support the job, relationship or complaint. Translation caches do not justify indefinite retention.
- Review: Job/complaint closes or purpose changes.
- Accounting evidence
- Company accounting records: 6 years from the end of the last company financial year they relate to; longer where applicable exceptions require it.
- Review: Year-end review with accountant; remove an expired hold.
- Operational logs & identifiers
- Only what is needed for access, security and fault resolution. Review inactive notification registrations.
- Review: Access ends; incident resolves; rights request.
- Backups & request records
- Keep recovery copies and minimal request-outcome evidence only for a documented purpose. Agree backup expiry and restore safeguards before promising erasure.
- Review: Backup replacement/restore; request completed.
The owner reviews records at closure, request and incident triggers and carries out a quarterly manual review. This is a manual policy, not an automated deletion schedule or a fixed expiry date.
The six-year rule applies to company accounting evidence, including relevant invoices/orders/delivery records needed for accounts, not automatically to all artwork or conversations. Exceptions and specific holds can require longer.
Retain only relevant records for a real accounting obligation, active dispute/investigation or other documented legal reason; review the hold when its basis ends.
How the owner handles requests
- Recognise and record. The owner handles [email protected]. Forward requests received by phone, in person or another inbox to him; no special form is required. Log receipt date, scope and request type.
- Set the response date. Respond without undue delay. Use one calendar month as the initial access/erasure response deadline, not 30 days. Acknowledge promptly; the internal acknowledgement target is two working days.
- Verify only what is needed. Check identity or a representative’s authority proportionately. Ask promptly if needed. For access requests, apply any lawful identity/clarification timing rule carefully and record it; do not pause every request automatically.
- Find the relevant records. Check the scoped portal records, artwork/files, business email, applicable providers and recovery copies. Preserve material needed for the request or an identified legal hold; avoid deleting evidence while an access request is open.
- Decide by purpose. Separate unnecessary personal data from accounting or dispute evidence that must remain. Record the reason for any partial refusal, the retained minimum and its next review. Company history is not a blanket reason to keep every personal detail.
- Arrange a reviewed action. Use an authorised, checked procedure for correction, export, restriction or deletion. Tell relevant recipients where required. Restrict affected backup reuse and record how deletions would be reapplied after a restore; verify the actual outcome.
- Reply securely and explain. Provide the result, retained exceptions and backup/provider position. If a lawful complexity/multiple-request extension is needed, explain it within the initial month; up to two further months may apply. State applicable complaint/review options.
- Close and review. Record the outcome, action date and verification without retaining an unnecessary copy of supplied identity documents. Review unresolved items and remaining purposes; do not mark a technical deletion complete before it is verified.
Backups and recovery copies
Before fulfilling an erasure request, the owner records affected backups, restricts reuse, identifies an authorised expiry/replacement or other erasure method, and explains unresolved limitations. If a backup is restored, approved deletions must be reapplied before normal use. There is no automatic backup-erasure period.
A proportionate request record
The owner records receipt and scope, the identity-check outcome, due date and justified changes, systems checked, decision, retained-record reason, verified action date and follow-up. Unnecessary identity-document copies are not part of this register.