Data Retention Policy
_Last updated: 21 July 2026 · Version 2 (draft)_
CoachComp keeps personal and operational data only for as long as necessary to deliver the Service, meet legal-obligation periods that apply to UK PSV/HGV operators, and satisfy legitimate business needs. Retention periods are enforced automatically by scheduled sweeps in the platform and are logged for audit.
Current retention schedule
| Data type | Period | Action on expiry | Basis |
|---|---|---|---|
| Q&A conversation history | 730 days (2 years) | Delete | Legitimate interests |
| Consent audit log | 1,095 days (3 years) | Delete | Legal obligation |
| Retention sweep audit log | 1,825 days (5 years) | Delete | Legal obligation |
| Completed audit runs | 2,555 days (7 years) | Archive | Legal obligation (O-licence) |
| Archived driver records | 2,555 days (7 years) | Anonymise | Legal obligation (O-licence) |
| Archived vehicle records | 2,555 days (7 years) | Anonymise | Legal obligation (O-licence) |
| Completed erasure requests | 1,095 days (3 years) | Delete | Legal obligation |
The live schedule is maintained inside the GDPR & Security console and may be updated to reflect regulatory change. Operators may configure shorter periods where they act as the controller and where no legal-minimum period applies.
How the sweeps work
- Automated sweeps run on a schedule against the platform database.
- Each sweep is recorded in the `retention_events` audit log with counts, actions taken and any errors.
- "Delete" removes the record irrecoverably. "Anonymise" strips direct identifiers while preserving aggregate statistics. "Archive" moves records into cold storage with restricted access.
Legal holds
Where records are subject to an active legal hold (regulatory investigation, Traffic Commissioner action, litigation, or a Public Inquiry), retention is suspended for the affected records until the hold is lifted, regardless of the schedule above.
Individual rights
Data subjects may request erasure at any time via Settings → Your data, or by contacting us. Erasure requests are processed within one month, subject to lawful exemptions (e.g. records CoachComp or an operator is required by law to retain).
Backups
Encrypted backups are retained for operational recovery and are overwritten on a rolling basis. Erasure requests are re-applied to any restore that occurs before natural backup expiry.