Data Deletion Policy

Data Deletion Policy

1. Purpose

This Data Deletion Policy outlines the procedures and responsibilities for ensuring that data is securely and permanently deleted in compliance with applicable laws, regulations, and contractual obligations. The goal of this policy is to protect sensitive data, maintain customer trust, and reduce security risks associated with data retention.

2. Scope

This policy applies to all systems, devices, databases, and storage media within the organization where data is processed, stored, or archived. It covers all forms of data, including electronic files, backup copies, and physical records, that are subject to deletion under contractual or regulatory requirements.

3. Key Principles

• Minimization of Data Retention: Data will only be retained as long as it is needed for business, legal, or regulatory purposes. Data beyond the retention period must be deleted promptly and in a secure manner.
• Secure Deletion: Data shall be deleted, purged, or destroyed using industry-approved methods to prevent unauthorized recovery.
• Data Ownership: Each department or team is responsible for reviewing and ensuring the secure deletion of data they own, in coordination with the IT and compliance teams.

4. Data Deletion Scenarios

Data must be securely deleted in the following situations:

1. Customer Request: When requested by a customer, in accordance with applicable laws (e.g., GDPR or CCPA).
2. End of Contract or Agreement: At the conclusion of a contract, when data retention is no longer required.
3. Exceeded Retention Period: When the data retention period defined in company policy has expired.
4. System Upgrades or Decommissioning: When systems, devices, or storage media are upgraded, replaced, or decommissioned.
5. Employee Offboarding: Upon an employee’s departure, all company-owned data on personal or company devices must be deleted.

5. Data Deletion Process

The following steps outline the standard process for secure data deletion:

a. Identification:

• Identify all data and storage mediums subject to deletion.
• Confirm that the data is no longer needed for legal, business, or regulatory purposes.

b. Authorization:

• Obtain approval for data deletion from the relevant data owner (e.g., department head, legal, or compliance team).

c. Deletion Methods:
Depending on the type and sensitivity of the data, the following methods are used:

• Electronic Data: Secure deletion using encryption-based wiping tools or overwriting methods to prevent recovery.
• Physical Media: Physical destruction (e.g., shredding, degaussing, or incineration) of storage devices like hard drives or USB drives.

d. Verification:

• Conduct verification checks to confirm that data has been successfully and permanently deleted.
• Document the deletion process for auditing purposes.

e. Notification (if applicable):

• Notify customers or stakeholders if required under legal or contractual obligations.

6. Recordkeeping

Records of all data deletion activities must be maintained for audit and compliance purposes, including:

• A description of the data deleted.
• The date of deletion.
• Authorization and verification details.

7. Compliance and Exceptions

• This policy complies with relevant legal frameworks, such as GDPR, CCPA, and HIPAA, as well as any applicable contractual obligations.
• Any exceptions to this policy must be documented, justified, and approved by the compliance team or legal counsel.

8. Policy Review

This policy will be reviewed annually, or as needed, to ensure it remains aligned with industry standards, legal requirements, and the organization’s data handling practices.

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Effective Date:

01/05/2024

Approval:

JJ Reynolds
President
VIsion Labs

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